Wholesale: Products & Services

Open Product/Process CR PC013002-1 Detail

Description Of Change

Modification after Clarification Meeting:

Establish a process to request the removal of bridge-taps.

Status History

Project Meetings

February 6, 2002 9:00 a.m. (MT) Conference Call 877-564-8688 PC013002-1, Removing Bridge Taps from LADA Circuits

Attendees:

Ric Martin, Qwest Neil Houston, Qwest Jeff Cook, Qwest Cindy Buckmaster, Qwest (Part Time) Steve Kast, Qwest (Follow-up conference call) Doug Worden, Vanion, Inc.

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

Review Requested (Description of) Change Doug advised that on LADA Circuits, which are for low speed data, but can handle high speed they want the ability to request the removal of bridge taps is requested. Doug clarified that LADA was 2-wire dry pair cable. Qwest indicated that this was data/data non-load service. It was clarified that this was for point to point service passing through the same wire center. Doug indicated that he had no way to order repair and provided an example of where Qwest moved a pedestal and added a bridge-tap, which has disrupted a customer’s service. Doug clarified that for this service Vanion was reselling Private Line services for High-Speed data. He also indicated that Vanion was also a Facility Based CLEC. Cindy Buckmaster joined the call and explained the Line Condition that can be ordered for UBL. However, she indicated that we need to review what was offered for Resale Qwest unable to bring Freddie Pennington, Wholesale Product Manager for Resale, into the call. Qwest indicated that they would coordinate internally and may get Doug back on an additional clarification meeting. Doug indicated that it was OK to have the CR follow the normal process, but wanted Qwest to investigate his trouble ticket CD328473 which was closed and was escalated. Doug advised that Steve Kast, Vanion Service Manager, was involved. Qwest advised that if they caused the problem and were responsible to fix it, they would look into it further. Note: it was clarified further with Doug Worden, Steve Kast and Ric Martin that Qwest was not committing to correcting the problem, but would look into it further to see if there was anything else that could be done.

Confirm Areas & Products Impacted It was confirmed that the product was for Resold Private Line . Confirm Right Personnel Involved Network personnel would be involved, but it was agreed that Process person should be the Owner. Qwest will coordinate.

Identify/Confirm CLEC’s Expectation It was confirmed that Vanion was looking for a process to request the removal of a bridge tap.

Identify any Dependent Systems Change Requests None

Establish Action Plan (Resolution Time Frame) Qwest will look into the Trouble Ticket Qwest will coordinate internal reviews of the CR.

CenturyLink Response

Vanion, Inc. Doug Worden Provisioning Manager

SUBJECT: Qwest’s Change Request Response - CR #PC013002-1 Removing Bridged Taps from LADS circuits

This letter is in response to Vanion Inc.’s Change Request PC013002-1 requesting a process for CLECs to request the removal of Bridge Taps from Local Area Data Service (LADS) circuits.

Local Area Data Service (LADS) is ordered in the Colorado Tariffs. Specifically LADS is offered in “Private Line Transport, Services Tariff, COLO. P.U.C. No. 19, Section 5.2”. LADS is described in Section 5.2.4, A.:

Service is offered only for balanced transmission of data signals conforming to the signal power limitations and other parameters specified in the applicable Technical Reference. These circuits are furnished on either a two-wire or four-wire basis, over non-loaded, metallic cable facilities.

Note the facility is non-loaded, but no reference is made to Bridged Tap. Additionally Section 5.2.4, C., 4. states:

No repair will be performed to change the electrical characteristics of the circuit, if they are within the parameters specified in the Technical Publication.

The General Regulations section of COLO. P.U.C. No. 19, Section 2.1.8 states:

It is expressly declared that metallic facilities are in continually decreasing supply and the Company is not obligated to continue to provide such facilities. Due to facility rearrangements, continued use of metallic facilities may be denied to existing customers with no obligation on the Company’s part to pay customer rearrangement costs.

As referenced above, Qwest’s Technical Publication 77314, Local Area Data Service (LADS), Issue C, July 2001 supports the Colorado Tariff on LADS. In addition to qualifying the LADS technical parameters, the General Section 1. states:

The customer should also be aware that Qwest has no obligation to continue to provide this service if suitable facilities are no longer available. Non-availability of suitable facilities may be caused by the continuing need to add new central offices and to transfer areas between serving wire centers, and the increasing use of Digital Loop Carrier technology on lines between the serving wire center and customer locations.

Vanion has stated that their high-speed data has deteriorated with changes in Qwest’s Network, allegedly from the addition of bridged tap to the circuit. LADS is not designed for high-speed data transmission and is not dependent upon the absence of bridged tap. As referenced above, in the Colorado Tariff and Technical Publication 77314, facility rearrangements could impact existing service. Also, as long as the service is within its technical parameters, repair is not required and will not be performed.

Qwest offers a variety of Unbundled Loop products that should meet Vanion’s transmission requirements. These include 2/4/ Wire Non-Loaded Loop, Basic ISDN Capable Loop, DS-1 Capable Loop, and the ADSL Qualified Loop.

Qwest will provide Vanion LADS service as described in its tariffs and technical publications. However, since LADS is not a high speed data service, Qwest declines to initiate a process to remove bridged tap from LADS and respectfully denies Vanion, Inc’s change request.

Sincerely,

Neil G. Houston Staff Advocate-Policy & Law Qwest

Cc: Mary Retka Kathleen Lucero Barry Orrel Jamal Boudhaouia

Open Product/Process CR PC061302-1 Detail

Description Of Change

Status History

Project Meetings

Qwest advised that since Vanion was not on the call, Qwest would get with Vanion independently to go over the response. Qwest reviewed its draft response with the CLEC participants. Eschelon asked how many calls does the retail customer have to make to get DSL. Qwest advised that one call is made and Qwest follows up with the customer after POTS is in service. Eschelon stated that CLECs do not get a follow-up call and the retail customer doesn’t have to call back to get DSL. Qwest confirmed that comment. Eschelon asked if this was a deny and Qwest confirmed that it was.

07/17/02 - July CMP Meeting Minutes: Vanion had to leave the CMP meeting early and asked that their CR be rolled over to the August CMP meeting for presentation. CR status is clarification.

CLEC Change Request Clarification Meeting

June 18, 2002, 11:30 a.m. (MT) Conference Call 877-564-8688 PC061302-1, Process for ordering Megabit DSL service to connect to Mega Central Hubs now installed.

Attendees: Ric Martin, Qwest Cindy Buckmaster, Qwest Jeff Cook, Qwest Steve Kast, Qwest Doug Worden, Vanion, Inc. Becky Watson, Vanion, Inc.

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

Review Requested (Description of) Change Doug reviewed Vanion’s CR. He indicated that they wanted to put in one order (LSR) for Megabit DSL service and POTS. Becky clarified that Vanion was not collocated in Qwest facilities and was not interested in the Line Sharing product. They wanted to order on the customer’s behalf. They would like to order a 1FB with DSL. They want to be able to take the customer out of dealing with Qwest. Becky indicated they currently can’t offer the DSL product because it’s a moving target on whether facilities would be available. Cindy indicated that data would not be available only if the facility can’t support it. Becky confirmed they were only interested carrying data and having Qwest as the voice provider. Cindy clarified that Vanion is looking to be able to provision the POTS circuit on copper cable versus pair gain capable to allow data service.

Confirm Areas & Products impacted It was confirmed that the area impacted was Pre-Ordering, Ordering and Provisioning. The product impacted are Resale POTS and Megabit DSL.

Confirm Right Personnel Involved Qwest indicated that they would need to include their Resale SMEs, Janean Van Dusen and Stacy Hartman.

Identify/Confirm CLEC’s Expectation Vanion’s expectation is to be able to place one LSR and be able to provision DSL on the POTS line ordered.

Identify any Dependent Systems Change Requests There are no related Systems CRs. Qwest advised that there was a similar CR issued by Eschelon, PC122701-2. Qwest requested Vanion to review the Archive Interactive Report for the CR and Qwest’s response.

Establish Action Plan (Resolution Time Frame) The CR will have the collective CLEC clarification and SME input at the July CMP meeting.

CenturyLink Response

Doug Worden Provisioning Manager Vanion, Inc.

SUBJECT: Qwest’s Change Request Response - CR #PC061302-1 Process for ordering Megabit DSL service to connect to Mega Central hubs now installed

This letter is in response to Vanion’s Change Request PC061302-1 requesting that they be allowed to place one LSR and be able to provision DSL on the POTS line ordered.

Vanion’s Change Request is similar to two (2) previously submitted Change Requests, PC122701-1, Qwest to offer line conditioning to qualify a loop for Qwest resale DSL service, and PC122701-2, Qwest to allow 1FB POTS and DSL on one LSR.

Qwest’s response to the two previous Change Requests was that basically the service was not offered to Qwest Retail customers and, therefore, was not going to be offered to Resale customers. Qwest’s responses to each CR can be reviewed in Qwest’s Product/Process CR Archive Report located at URL http://www.qwest.com/wholesale/cmp/archive.html. After additional review, Qwest’s position remains the same. It is not technically and economically feasible for Qwest Retail to offer this service at this time. Qwest does not offer pre-qualification of facilities for DSL prior to the end user’s line being in place. Current process for Retail and Resale is that two (2) orders must be issued. One (1) for the POTs and one (1) for the DSL once the POTS line is loop qualified.

At last month's CMP meeting, there was a question on the Retail process for ordering POTS and DSL. The Retail process does require 2 orders, whether it is an N (new) order or a T (transfer) order. If the end user is interested in DSL, then after the N or T order is installed, a Loop qualification is done on the N (telephone number) or the T (telephone number) and the end user is contacted to place the 2nd order, which would be a C (change) order to add the DSL service.

Sincerely,

Janean Van Dusen (801) 239-4305

Cc:

Open Product/Process CR PC062602-2 Detail

Description Of Change

While some of the rejects proved out that there were no reusable UNE DS0 circuits, the reject reasons did not clearly state the true circumstances. For example one reject stated “no working circuits found”. When further researched, it was found that there were indeed working circuits there but the only working circuits for the End User were DS1s.

Allegiance would also like to collaboratively work with Qwest and other CLECs to establish clear, definitive reject reasons for CLEC to CLEC reuse of facilities orders to insure that all resources available to the SDCs have been utilized to find working circuits. When Allegiance submits CLEC to CLEC reuse of facilities orders, we already have obtained a CSR from the CLEC so we know the numbers we are porting are indeed working on some kind of circuit. These reject reasons should be clear enough to insure the CLEC that there are indeed no working UNE DS0 circuits to reuse. As stated above some of the orders rejected did indeed have available working UNE DSO circuits that could be reused. Allegiance currently does not have confidence that the SDC’s reject reasons are valid and their training is adequate to locate reusable UNE DS0 circuits. In many instances we are having to drop new loops in order to take the customer when there are reusable loops available. Installing new loops is more expensive, more time consuming for the cut over, and there is the risk the orders will be held for lack of facilities. The ability to “reuse” facilities is less expensive, the cut over process is less time consuming, and the end user has less down time.

Expected Deliverable:

Clear, definitive reject reasons that the CLECs can rely on that all resources were utilized to “find” working UNE DS0 circuits for CLEC to CLEC reuse of facilities orders.

Status History

Project Meetings

Qwest requested that Allegiance research to determine if Allegiance personnel is receiving the comments that were agreed to. Attendees agreed that this could be closed off line if Allegince (Mendoza) agreed.

09/18/02 September CMP Meeting The improved comments associated with rejects on CLEC to CLEC Reuse of Facilities were implemented on August 23. The response indicated it was implemented on August 22. Qwest will update the status history to reflect the actual date. Allegiance (Wicks) indicated they were unaware that the process was underway, Terry will check with his people to find out. Eschelon (Johnson) indicated they had encountered a couple of problems with the process, Russ worked through these issues for them. This CR will remain in “CLEC Test” until the October meeting when it is anticipated that the CR will be updated to "Completed."

- 08/21/02 - August CMP Meeting Minutes Qwest (Urevig) reviewed the three scenarios and comments that are associated with the reject reasons. Allegiance (Wicks) inquired about the second scenarios comments. Are they intended to be two separate or one comment? Qwest indicated that they are two distinct comments. This CR was moved to "CLEC Test".

"Wicks, Terry" , Kathleen Thomte/Mass/USWEST/US@USWEST cc: Cheri Hurless/GROUPWARE/USWEST/US@USWEST

Subject: CR

I wanted to get back to you with the different type of comments we are looking at placing on the rejected CLEC to CLEC migrations request, during our last meeting we determined there were 4 different types of rejects which would require different comment.

1. Wrong type of circuit being requested does not match what was requested by CLEC. 2. Multiple circuits at customer location not all circuits being migrated. 3. No circuits found for migration 4. CLEC to CLEC reuse of facility show detail of which CLEC migration is from (This is probably going to be included in the first scenario).

These are the scenarios and the comments that will reject will contain, I combined the 2 and 3

1. When Qwest finds the circuit at the requested address is NOT the same type of circuit to which the migrate has been requested, the comment remark associated with this will read: Circuits at request address do not match the type of circuit indicated on the LSR for migration. The circuits found are (ex. LX-N or AD--, HCE-, etc)

2. Multiple circuits are found at the requested address, if the number of circuits at the address do NOT match the number of migrations indicated on the LSR. It is very important that the CLEC indicate who the OLSP (old local service provider) is when requesting migration because this will aid in determining whether multiple circuits are really an issue. Qwest will provide these comment remarks for the reject: Multiple circuits have been identified at request address, circuits are currently not those of the indicated OLSP or Multiple circuit have been identified for the OSLP but do not match the number of loops requested for migration.

3. Qwest has searched all available records to identify circuits at end user address, but was NOT able to identify circuit for migration. Qwest will review all data on LSR to obtain circuits to be migrated. Additional data that is recommended to aid in the migration request are: the TN that is being ported to the NLSP’s (new local service provider) switch and the name of the OLSP. If Qwest can NOT find the circuits, the following comment remarks will be provided on the reject: Qwest has search for circuits at the requested address, using the end user name, address, OLSP, and TN provided. Qwest can not find circuits please verify data on LSR for accuracy.

If these cover additional comments or consistent comments will help the CLEC determine the reason for the reject I will place these into the Job aid for Migration then cover this with the SDC's, coaches, SME's and SDC to make sure everyone has the same understanding.

If you have any comments or concerns maybe we can talk or discuss this at the next CMP meeting.

August 12, 2002

Terry Wicks Allegiance Russ Urevig Qwest Kit Thomte Qwest

Notes from follow up meeting: PC062602-2 Rejects on CLEC to CLEC Reuse of Facilities order for no Circuit Ids found. Qwest agreed to hold follow up meeting to collaborate with Allegiance regarding comments associated with reject reasons.

The team agreed that Russ would put together proposed comments for Terry to review. The group also agreed to talk through on the call what the 3-4 scenarios are that exist that could drive the comments.

1. Wrong type of circuit being requested does not match what was requested by CLEC. 2. Multiple circuits at customer location not all circuits being migrated. 3. No circuits found for migration 4. CLEC to CLEC reuse of facility show detail of which CLEC migration is from (This is probably going to be included in the first scenario).

The team agreed that Russ would put together scenarios and new comments for Terrys review.

07/17/02 - July CMP Meeting Minutes: Allegiance (Wicks) reviewed the CR and indicated that his representatives were not using the prescribed process. When analyzed he discovered that the reject reasons did not really make sense. Through discussions with Qwest it appeared that our SDC need access to a special database. Qwest and Allegiance will review the reject reasons to help clarify them. Qwest will provide an initial response prior to the August meeting. This CR will carry a “Clarification” status

Date: July 3, 2002 Place: 1005 17th St Room 1770-C Call-In No.: 877 550-8686 PC062602-2 CR No.:PC062602-2 CLEC Change Request Clarification Meeting

Attendees Name/Company: Terry Wicks Allegiance Russ Urevig Qwest Debbie Osborne Qwest Neil Houston Qwest Kit Thomte Qwest

Meeting Agenda: Action 1.0 Introduction of Attendees See list above

2.0 Review Requested (Description of) Change Terry Wicks reviewed the CR with the SME from Qwest. Process to find working circuits needs to be re designed and reviewed with personnel. Update reject reasons to be clearer specify scenarios that relate to the reject so the SDC can provide better information to the CLECs.

2.1 Terry believes that a collaborative process should be used to allow input from Allegiance and other CLECs in the development of the error messages. We agreed that we could discuss at the CMP meeting and determine the level of interest. 2.2 Terry presented an example that the SMEs reviewed to ensure a level of understanding for the problem. 2.3 Qwest inquired about what changed in May 2002 that seemed to impact thee errors. Allegiance clarified that was when they discovered that the process was not being used.

3.0Confirm Areas & Products impacted 3.1CLEC to CLEC migrations Qwest wanted to clarify that this was a specific issue associated with one product (UNE). And not a global issue. Allegiance indicated it was not global. Qwest inquired about what changed in May 2002 that seemed to impact thee errors. Allegiance clarified that was when they discovered that the process was not being used. 4.0Confirm Right Personnel Involved 4.1Russ Urevig will have the lead on this CR. Neil will stay involved as required.

5.0 Identify/Confirm CLEC’s Expectation 5.1Ensure that Qwest personnel understand the process and are trained. Improve the reject remarks to be more specific to scenarios thus providing the CLECs a better idea of the problem.

6.0Identify any Dependent Systems Change Requests 6.1 None apply

7.0 Establish Action Plan 7.1 No systems are impacted the time frame would be dependent on the participation of the CLEC in the meeting and the timing of updating the documentation. 7.2

CenturyLink Response

Terry Wicks, LEC Manger Allegiance Telecom, Inc

SUBJECT: Qwest’s Change Request Response - CR # PC062602-2 Rejects on CLEC to CLEC Reuse of Facilities orders for no circuit IDs found

This is in response to the request from Allegiance where as Allegiance would like to collaboratively work with Qwest to establish clear, definitive reject comment reasons for CLEC to CLEC reuse of facilities orders to insure that all resources available to the SDCs have been utilized to find working circuits.

After meeting with Terry Wicks several times to discuss the application of the comment remarks that are associated with the reject for CLEC to CLEC migration, we have clarified the comments and have modified the comments as set forth below to address the following scenarios.

1. When Qwest finds the circuit at the requested address is NOT the same type of circuit to which the migrate has been requested, the comment remark associated with this will read: Circuits at request address do not match the type of circuit indicated on the LSR for migration. The circuits found are (ex. LX-N or AD--, HCE-, etc)

2. Multiple circuits are found at the requested address, if the number of circuits at the address do NOT match the number of migrations indicated on the LSR. It is very important that the CLEC indicate who the OLSP (old local service provider) is when requesting migration because this will aid in determining whether multiple circuits are really an issue. Qwest will provide these comment remarks for the reject: Multiple circuits have been identified at request address, circuits are currently not those of the indicated OLSP or Multiple circuit have been identified for the OSLP but do not match the number of loops requested for migration.

3. Qwest has searched all available records to identify circuits at end user address, but was NOT able to identify circuit for migration. Qwest will review all data on LSR to obtain circuits to be migrated. Additional data that is recommended to aid in the migration request are: the TN that is being ported to the NLSP’s (new local service provider) switch and the name of the OLSP. If Qwest can NOT find the circuits, the following comment remarks will be provided on the reject: Qwest has search for circuits at the requested address, using the end user name, address, OLSP, and TN provided. Qwest can not find circuits please verify data on LSR for accuracy.

A review of the internal documentation for Qwest has been completed and several changes have been made to streamline the search for unbundled loop circuits. The completed changes and notification to the Wholesale Service Delivery centers will be complete by August 22. The change notifications will be distributed with an MCC, the details of the MCC are the TOPIC is Standardized Comments for CLEC to CLEC Migration Rejects, the SUBJECT is Unbundled Loop, the USER GROUPS AFFECTED are Wholesale. A joint review meeting with the Team Leads, Coaches and SMEs (subject matter experts) will also be held to review the changes and clarify the importance of this process. We have accepted the request to modify the comment remarks on the rejected migration, so that the comments are more standard for the problem encountered. If the Qwest deviates from the standard comments it will be only to provide additional information about that reject.

Sincerely,

Russell Urevig Sr Process Analyst Wholesale Service Delivery

Open Product/Process CR PC062602-3 Detail

Description Of Change

Status History

Project Meetings

Allegiance advised they would withdraw this CR which will be satisfied with the System CR’s, providing Qwest opens a Global Action Item to research if a column with their Trouble Ticket Number could be added to the current spreadsheet they receive from their Service Manager. Qwest advised that they are looking into this action item. Qwest expressed that development of the spreadsheet is a complicated process. No participating CLEC indicated that they wanted to assume sponsorship of this CR. The CR will be status Withdrawn and a Global Action Item will be opened.

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08/30/02 Conference Call

Ric Martin and Craig Suellentrop, Qwest, held a conference call with Terry Wicks, Allegiance to discuss the manual and system aspects of their CR. Qwest advised that the system aspect of Allegiance’s CR would be covered under the resultant Systems CR from combining the various System CRs on Trouble Tickets and Repair Charges. Qwest advised that the Systems resolution would look at the “Input” aspect (CEMR and MEDIACC) of getting CLEC Trouble Tickets and the “Output” aspect (Bill) of cross-referencing trouble tickets and Circuit IDs, etc. Allegiance was in agreement with the handling of the systems aspect of their CR. Qwest explained that there might be something that could be done on the manual process aspect, but there wouldn’t be any meaningful output until the systems fix was accomplished. Qwest indicated that they would still pursue the manual aspect if Allegiance were interested in this. Allegiance indicated that they didn’t want Qwest to duplicate efforts on a manual and systems fix. Allegiance asked if Qwest would look into modifying the spreadsheet they get from their Service Manager to include their internal Ticket Number. Qwest advised that they would open a Global Action Item to look at this and asked Allegiance to send an e-mail with a copy of the spreadsheet and details on what they would like included and at the September CMP meeting we would discuss the disposition of their CR.

08/21/02 August CMP Monthly Meeting Minutes

Qwest reviewed its draft response and advised that this CR would be reviewed in conjunction with other CRs related to trouble tickets, repair charges, etc. scheduled for August 27, 2002. The CLEC participants agreed to have this CR reviewed at that meeting. Qwest clarified that a manual process could be developed to request the CLEC trouble ticket, but it would be input into the remarks field that doesn’t have any sorting capability. Allegiance indicated that they currently receive a spreadsheet with the Qwest trouble ticket identified and asked if Qwest couldn’t put Allegiance’s ticket number on the spreadsheet. Qwest confirmed that the spreadsheet is created from a Web site and maintained by Nancy Tangeman.

07/17/02 - July CMP Meeting Minutes: Allegiance introduced their Change Request. Qwest stated the need is to create a process to capture the information Allegiance has requested. CR status is evaluation.

CLEC Change Request Clarification Meeting

July 2, 2002 9:00 a.m. (MT) Conference Call 877-564-8688 PC062602-3, Cross Reference CLEC Trouble Ticket number on Qwest Trouble Ticket Numbers

Attendees: Ric Martin, Qwest Lynn Stecklein, Qwest Craig Suellentrop, Qwest Alice Matthews, Qwest Terry Wicks, Allegiance

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

Review Requested (Description of) Change Terry indicated that this CR was different than the Systems CR that has to do with the CEMR update. Allegiance does not use CEMR and call in their trouble to the AMSC. Allegiance wants to be able to call tickets in, provide their internal number, have it cross referenced with Qwest’s number and to have their internal number show up on the bill. Terry indicated that they would like to see a process change that would require Qwest to get an Internal Ticket number from the CLEC before they open up a trouble ticket. Terry indicated that they intend to e-bond with MEDIACC in the future, which allows them to electronically report trouble without making a phone call. Craig confirmed that the trouble tickets called in are entered into WFA-C and Qwest would need to look into what the flow through systems are. Additionally Qwest will need to look into what is needed to have Allegiance’s ticket number appear on the bill. Terry indicated that no matter how we open up a ticket, the cross-reference to the CLEC Ticket on the bill is what matters. Terry will look into how e bonding to MEDIACC would be communicated and if there is a field currently that would allow this. He will look into whether a systems CR would be required for MEDIACC.

Confirm Areas & Products impacted It was confirmed that the area impacted was Billing and Maintenance & Repair. The product impacted is UBL.

Confirm Right Personnel Involved Qwest confirmed that Craig would remain the SME for now.

Identify/Confirm CLEC’s Expectation Terry confirmed that they were looking for: 1. A process to have the AMSC not open a trouble ticket without first getting a CLEC internal trouble ticket. 2. Determine best method to get CLEC trouble ticket number on the bill.

Identify any Dependent Systems Change Requests Systems CR SCR030702-1 has to do with CEMR update to include a field for CLEC Trouble Ticket. Systems CR SCR042902-01 has to do with getting the CLEC trouble ticket number onto the bill.

Establish Action Plan (Resolution Time Frame) The CR will have the collective CLEC clarification and SME input at the July CMP meeting.

CenturyLink Response

Terry Wicks LEC Manager Allegiance Telecom, Inc.

SUBJECT: Qwest’s Revised Change Request Response - CR PC062602-3 “Cross Reference CLEC Trouble Ticket number on Qwest Trouble Ticket numbers.”

This CR requests that “the CLECs internal trouble ticket number to be a required item to be provided to the Qwest Representative issuing the Qwest trouble ticket. This will allow for both the Qwest trouble ticket number and the CLECs internal trouble ticket number to be cross referenced to each other.” Allegiance would also like the CLEC’s trouble ticket number to appear on bills for maintenance and repair charges.

Because of the large number of Charge Requests related to Maintenance and Repair, a meeting was held on August 27, 2002 to discuss possible synergies between the various CRs. As a result of this meeting and further consultation with Allegiance on August 30, 2002, it was determined that the system CRs SCR030702-1 – CLEC Trouble Ticket Cross Reference and SCR042902-01 – Use CLEC Internal Repair Ticket number on CLEC bill to identify maintenance and repair charges would address the concerns raised by this CR relating to cross-referencing trouble ticket numbers and CLEC trouble ticket numbers appearing on the bill. Allegiance agreed that a separate manual process would not be required with the development of the system enhancements covered by these CRs.

Allegiance also raised an issue concerning a spreadsheet they receive from their Qwest Service Manager that contains all of the TOK and NTF tickets. Allegiance would like to see their trouble ticket number on this spreadsheet. Qwest and Allegiance agreed that this issue could be pursued as a Global Action Item and that Qwest will continue to investigate this issue.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest Catherine R. Garcia, Senior Process Analyst, Qwest Alice Matthews, Senior Process Analyst, Qwest Dan Busetti, Lead IT Analyst, Qwest

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August 13, 2002

Terry Wicks LEC Manager Allegiance Telecom, Inc.

SUBJECT: Qwest’s Change Request Response - CR PC062602-3 “Cross Reference CLEC Trouble Ticket number on Qwest Trouble Ticket numbers.”

This CR requests that “the CLECs internal trouble ticket number to be a required item to be provided to the Qwest Representative issuing the Qwest trouble ticket. This will allow for both the Qwest trouble ticket number and the CLECs internal trouble ticket number to be cross referenced to each other.” Allegiance would also like the CLEC’s trouble ticket number to appear on bills for maintenance and repair charges.

The current repair process for Designed Services allows a CLEC to offer the CLEC trouble ticket number to the Qwest representative opening the Qwest trouble ticket. The CLEC trouble ticket number will be entered into a remark field. This field is not “searchable” and does not appear on CLEC bills. This option is not available for Non-Designed Services. Qwest would agree to a process change to ask all CLECs for their internal trouble ticket number, but without systems changes this would not address the majority of Allegiance’s concerns.

Open System CR’s SCR030702-1 – CLEC Trouble Ticket Cross Reference and SCR042902-01 – Use CLEC Internal Repair Ticket number on CLEC bill to identify maintenance and repair charges also would require a very similar process. A meeting will be scheduled for late August to discuss the similarities between these and some other CR’s involving maintenance and repair. Further clarification and direction for this CR will be determined after this meeting.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest Catherine R. Garcia, Senior Process Analyst, Qwest Alice Matthews, Senior Process Analyst, Qwest

Open Product/Process CR PC062602-1 Detail

Description Of Change

While there is a process in place to be able to submit CLEC to CLEC reuse of facilities orders without providing circuit ID information, 90% of the orders submitted by Allegiance since late May 2002 are being rejected for various erroneous or unclear reasons regarding the circuit ID information. (I will be addressing that issue in a separate change request.) Allegiance believes that having this additional capability, will greatly enhance our ability to get reuse orders successfully processed and in a more timely manner.

Expected Deliverable:

A process for CLECs to be able to request Circuit IDs up front for CLEC to CLEC reuse of facilities orders that is in parity with Retail’s capability to get such circuit IDs before placing a reuse order for UNE DS0 loops.

Status History

Project Meetings

09/18/02 September CMP Meeting Qwest reviewed its draft response and summarized the September 4th conference call with Allegiance, walking through Raw Loop Data Tool. When the end user location was a single tenant address the circuit ID was produced. When the end user location was a multi-tenant address, the circuit ID was produced when the suite number was included and when the suite number was in PREMIS database. Allegiance appreciated the assistance with RLD, and, said that providing the circuit ID will get migration orders through the first time with fewer rejects. This CR will stay in development status while determining the tool for CLEC’s to obtain circuit IDs is identified. Eschelon asked if Qwest is not able to come to a systems solution, would a single point of contact be implemented for CLEC’s. Qwest responded that such a solution may be entertained but it was more likely that a mechanized process would be identified.

-- 08/21/02 - August CMP Meeting Minutes: Qwest reviewed its draft response. Allegiance would like to walk through on the phone with Qwest and use Raw Loop Data Tool. Eschelon asked how to identify which CLEC owns the circuit. Qwest stated that the RLDT will provide the circuit ids and that retail and CLECs rely on Qwest Wholesale to identify the local provider. Allegiance indicated they would like to move this CR into development.

07/17/02 - July CMP Meeting Minutes: Allegiance presented their Change Request. Qwest stated that current tools will be reviewed for their capability to look at curcuit IDs in conjunction with end user addresses, including specific addresses that have suite numbers. CR status is clarification

Time/Date: 9:00 a.m. (MDT) / Monday, July 8, 2002 Place: Conference Call Conference: TEL: 877.521.8688 Call-In No: CODE: 7901848 CR No: PC062602-1" Circuit IDs on CLEC to CLEC Reuse of Facilities orders"

Attendees: Terry Wicks, Allegiance Russ Urevig, Qwest Neil Houston, Qwest Bob Mohr, Qwest Michael Keegan, Qwest

Introduction of Attendees Attendees introduced. Review Requested (Description of) Change Description: Allegiance wants the capability to get CLEC circuit ID information from Qwest on UNE DS0 loops prior to submitting a CLEC to CLEC reuse of facilities order. If Qwest Retail wants to reuse facilities when porting a customer from a CLEC back to Qwest, they have the capability to "look up" circuit ID information. Qwest Retail does not have to get this information directly from the CLEC, thus the ability to access circuit ID information speeds up their process of submitting orders to Wholesale and eliminates rejects for "bad or missing" circuit IDs. Giving the CLECs a process to obtain CLEC circuit ID detail up front for reuse orders, will allow the CLECs the same parity in submitting accurate orders in a timely manner. This capability will also allow more frequent use of the CLEC to CLEC reuse of facilities process. In many instances, some CLECs that are loosing a customer will not provide circuit ID information to the winning CLEC, thus inhibiting the process of reusing the facilities. When facilities are not reused and the CLEC submits new loop orders, the results may be held orders for lack of facilities. Also installing new loops is much more expensive.

While there is a process in place to be able to submit CLEC to CLEC reuse of facilities orders without providing circuit ID information, 90% of the orders submitted by Allegiance since late May 2002 are being rejected for various erroneous or unclear reasons regarding the circuit ID information. (I will be addressing that issue in a separate change request.) Allegiance believes that having this additional capability, will greatly enhance our ability to get reuse orders successfully processed and in a more timely manner.

Discussion: Allegiance stated they cannot force a CLEC to provide circuit ID information. Allegiance is dependent on Qwest to provide this information. Reuse of facilities benefits both the CLEC and Qwest. Qwest stated that the current tools will be reviewed for their capability to look at circuit IDs in conjunction with end user addresses. Confirm Areas & Products Impacted Areas Impacted: Ordering, Provisioning Products Impacted: Unbundled Loop, UNE Loop Confirm Right Personnel Qwest confirmed the correct personnel were on the call.

Identify/Confirm CLEC’s Expectation A process for CLECs to be able to request Circuit IDs up front for CLEC to CLEC reuse of facilities orders that is in parity with Retail’s capability to get such circuit IDs before placing a reuse order for UNE DS0 loops. Identify any Dependent Systems Change Requests None Establish Action Plan (Resolution Time Frame) Allegiance can present this Change Request to the CLEC community at the July Product/Process CMP meeting scheduled for July 17 Qwest will issue draft response to this Change Request by Aug 14 (one week prior to the Aug 21 CMP meeting). Qwest will discuss the draft response at the Aug 21 CMP meeting.

CenturyLink Response

Lori Mendoza LEC Account Manager Allegiance Telecom

SUBJECT:Qwest’s Change Request Revised Response - CR # PC062602-1 Circuit IDs on CLEC to CLEC Reuse of Facilities orders

At the September CMP meeting, Qwest agreed to continue to research the issues, to determine the most suitable path forward in determining circuit ID information to allow the CLECs the ability to get circuit ID information on DSO type loops for CLEC to CLEC migrations.

Qwest has reviewed the current process of obtaining loop circuit ID’s using the Raw Loop Data (RLD) Query for CLEC to CLEC migrations. We find the tool meets the needs of the change request to provide CLECs a process to obtain Loop Circuit ID details for reuse orders. To clarify, the RLD Query can be used as follows: - Enter a valid address, this must be suite or unit specific if address is multi-tenant. - If address is valid, RLD will provide information on all working TN’s or circuits. - If no matches are found for a specific address, RLD will return a message indicating no information found.

When no circuit information is found, proceed with submitting the LSR and Qwest will determine the circuit and migrate the end user as requested.

The current process provides parity with migrations between Wholesale CLEC to CLEC migrations and migrating end users back to Qwest Retail. The work performed, the results and the responses are handled in the same manner between Retail and the CLECs

LSRs for CLEC to CLEC migration do not require that the Circuit ID field be populated. - Qwest will accept the requests for migration without circuit information. - Qwest will research and determine the circuit or circuits at that address. - If the Loop Circuit ID cannot be determined, Qwest will provide a standard remark associated with the reject of a migration request as follows:

1. When Qwest finds the circuit at the requested address is NOT the same type of circuit to which the migrate has been requested, the comment remark associated with this will read: Circuits at requested address do not match the type of circuit indicated on the LSR for migration. The circuits found are (ex. LX-N or AD--, HCE-, etc).

2. Multiple circuits are found at the requested address: If the quantity of circuits at the address do not match the quantity of lines migrating, as indicated on the LSR, Qwest will use the OLSP information provided by the CLEC to try to determine which services will be migrated. It is very important that the CLEC indicate who the OLSP (old local service provider) is when requesting migration because this will aid in determining whether multiple circuits are really an issue. Qwest will provide these comment remarks for the reject: Multiple circuits have been identified at request address, circuits are currently not those of the indicated OLSP or Multiple circuits have been identified for the OSLP but do not match the number of loops requested for migration.

3. Qwest has searched all available records to identify circuits at the end user address, but was not able to identify circuit for migration: Qwest will review all data on the LSR to obtain circuits to be migrated. Additional data that is recommended to aid in the migration request are: the TN that is being ported to the NLSP’s (new local service provider) switch and the name of the OLSP. If Qwest can not find the circuits, the following comment remarks will be provided on the reject: Qwest has searched for circuits at the requested address, using the end user name, address, OLSP, and TN provided. Qwest can not find circuits, please verify data on LSR for accuracy.

- The CLEC should review the reject remarks, validate any issues in question, and re-submit the LSR once the information is found and the LSR is corrected. - Qwest provides a method to escalate questions on rejects or clarification on remarks for rejects.

Sincerely,

Russ Urevig Senior Process Analyst Wholesale Service Delivery

Open Product/Process CR PC071502-1 Detail

Description Of Change

This is resulting in Allegiance spending extra time, effort and money to isolate the NDT issue to the Qwest side. What would resolve this is if the Pair Information was also on the PTA notification next to the telephone number. With this information showing what pairs Qwest is testing to, we can identify the error quicker.

Expected Deliverable:

Receiving the PTA email notifications of NDT with the CFA information provided in addition to PON, TNs and DD

Status History

Project Meetings

11/20/02 November CMP Meeting Qwest (Thomte) indicated that she thought some problems had been identified recently through a comment from Lori Mendoza. Linda Hendricks confirmed that was true. Allegiance (Mendoza) indicated that they were getting CFA on the PTA about 50 percent of the time. Other CLECs indicated they were seeing problems as well. This CR will remain in CLEC Test.

10/16/02 October CMP Meeting Qwest initiated a Level 1 notification (PROS.10.14.02.F.00598.CFAEmailNotice) on October 14 advising the CLEC community that CFA information would be provided on PTA E-mail notifications. This CR moved to “CLEC Test”

09/18/02 September CMP Meeting This CR should be discussed in conjunction with PC050302-1. Qwest provided an updated response indicating this Change Request has been accepted, although it is dependent on the implementation of PC050302-1. Participants agreed that PC071502-1 CR can implement with a Level 1 notice after comments cycle is completed for PC050302-1. This CR will change to "Development"status with agreement to update to "CLEC Test" once Level 1 notice is sent.

08/21/02 - August CMP Meeting Minutes

This CR is dependent on CR PC050302-1. This CR status changed to "Evaluation"

Date: July 22, 200 Place: 1005 17th St Room 1770-C Call-In No.: 877 550-8686 CR No.: CLEC Change Request PC071502-1 Clarification Meeting

Attendees Name/Company: Terry Wicks Allegiance Russ Urevig Qwest Linda Hedricks Qwet Steve Hilleary Qwest Phyllis Sunnins Qwest Kit Thomte Qwest

Meeting Agenda: Action 1.0 Introduction of Attendees See list above 2.0 Review Requested (Description of) Change Terry Wicks reviewed the CR with the SMEs from Qwest. 2.1During the trial that was held in May and June Allegiance investigated situations that resulted in NDT. *One scenario was due to the Service Order being written with information that was different than what appeared on the LSR. *Another scenario was due to the Central Office being wired incorrectly. 2.2Terry indicated that if Allegiance knows up front what CFA Qwest is testing to it allows them to resolve the issue faster. Allegiance can review based on what they passed on the LSR and what Qwest FOCd back. 2.3

3.0 Confirm Areas & Products impacted 3.1 UNE, Unbudled Loop 4.0 Confirm Right Personnel Involved 4. The team agreed that Linda Hendricks would be the respondent Steve will participate, and Phyllis and Russ would have no further action.

5.0 Identify/Confirm CLEC’s Expectation 5.1 Receive notification regarding CFA used in no dial tone situations

6.0 Identify any Dependent Systems Change Requests 6.1

7.0 Establish Action Plan (Resolution Time Frame) 7.1 No systems are impacted the time frame would be dependent on the participation of the CLEC in the meeting and the timing of updating the documentation.

CenturyLink Response

Terry Wicks Allegiance

SUBJECT: Qwest’s Change Request Response - CR #PC071502-1 Include CFA Information on PTA Email Notifications of NDT.

This is a preliminary response regarding Allegiance CR PC071502-1 (Include CFA Information on PTA E-Mail Notifications of NDT). As discussed in the August Product & Process Monthly CMP Meeting, this CR is dependent on the outcome of PC050302-1 (Email Notification of No Dial Tone at 48 Hours).

The implementation of Change Request PC050302-1 is being pursued as a CMP Level 3 change as agreed to in the July Product & Process Monthly CMP Meeting. Based upon the issuance of notice PROD.09.05.02.F.00818.AnalogLoop24Wire, Change Request PC050302-1 is currently in a comment cycle.

Upon the implementation of Change Request PC050302-1 Qwest anticipates being able to make changes as described in PC071502-1. Specifically, Qwest expects to be able to include CFA information in addition to PON, TNs and DD in PTA e-mail notifications.

Assuming the successful implementation of e-mail notifications of No Dial Tone (NDT) per Change Request PC050302-1, Qwest would propose to notify the CLEC community of the changes specified in PC071502-1 as a Level 1 change (i.e. “additional information that does not change the product or process”). Qwest will seek concurrence with this approach at the September Product & Process Monthly CMP Meeting.

Sincerely,

Linda Hendricks Lead Project Analyst Qwest

Open Product/Process CR PC072902-1 Detail

Description Of Change

Status History

Project Meetings

Allegiance advised that they had a conference call with Qwest where it was clarified the difference between requesting an extension of a jack versus a NID/DEMARC. It is Qwest’s policy that CLECs cannot request an extension to a NID/DEMARC and only in Minnesota and Oregon is it mandated that CLECs can request and extension of a Jack. Allegiance advised that based on this clarification, they would like to withdraw their CR. Qwest asked if any other CLEC would like to sponsor the CR and no CLECs expressed an interest. It was agreed that the CR would be status as withdrawn.

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Subject: RE: CR PC072902-1 Clarification Meeting Minutes Date: Mon, 5 Aug 2002 13:41:39 -0500 From: "Wicks, Terry" To: "'Richard Martin'"

The department that we fax a form to for Southwestern Bell , to get an estimate of cost, is called the LSC (Local Service Center). This is the department that processes our LSRs.

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

CLEC Change Request Clarification Meeting

August 2, 2002 10:00 a.m. (MT) Conference Call 877-564-8688 PC072902-1, Request for estimate of cost for extending or moving a DMARC beyond the MPOE prior to doing the work

Attendees: Ric Martin, Qwest Russ Urevig, Qwest Shirley Tallman, Qwest Bob Mohr, Qwest Linda Sanchez-Steinke, Qwest Terry Wicks, Allegiance

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

Review Requested (Description of) Change Terry indicated that when Allegiance is taking a customer, they may want to move or extend the DMARC beyond the MPOE. They want to get an estimate of the cost before the work is performed. Currently they put their request in when they place the order and get billed for the work after the order is completed. Terry indicated that another ILEC has a form that they complete and submit to get an estimate before the order is submitted. Terry indicated that they have an 800 number and a fax number to which this form is sent. He believes they are dealing with the ILECs engineering department. Terry will confirm what department they deal with. The department is the LSC, Local Service Center at Southwestern Bell. Terry indicated that they were billed for the estimate and would be willing to pay for the estimate. He agreed that an estimate was acceptable with actual costs being billed per their agreement with Qwest. Russ asked if Allegiance was looking at a multi-tenant facility and looking more at an individual customer’s DMARC. Terry indicated that Allegiance is looking at extending the DMARC or sometimes moving the DMARC beyond the MPOE for an individual tenant of a multi-tenant building.

Confirm Areas & Products impacted Terry indicated that their product focus was UBL. Qwest may have to look at other products that would have the same need. It was agreed that the area impacted was Pre-Ordering and Ordering.

Confirm Right Personnel Involved Qwest confirmed that the Network department would be responsible.

Identify/Confirm CLEC’s Expectation Terry confirmed that they wanted a process to request and receive a written cost estimate for extending or moving a DMARC beyond the MPOE prior to submitting an order.

Identify any Dependent Systems Change Requests There are no systems changes associated with this request.

Establish Action Plan (Resolution Time Frame) The CR will have the collective CLEC clarification and SME input at the August CMP meeting.

Open Product/Process CR PC050302-1 Detail

Description Of Change

Status History

Project Meetings

Qwest explained this process was implemented effective October 11, 2002. No issues have been identified with the process and Qwest requested to close this CR. Lori Mendoza - Allegiance advised they are using the process and it is working without any issues. Allegiance and the other CLECs in attendance agreed to close the CR.

10/18/02 October CMP Monthly Meeting Minutes Qwest explained this process was implemented effective October 11, 2002. As of October 16, four CLECs have signed up to receive E-Mail Notification of NDT via the PTA tool. Eschelon verified that if you do not sign up for email notification via the PTA tool then you will not get any NDT notification, as the only method of NDT notification is now the PTA tool. CLECs can continue to sign up at any time. Qwest agreed to leave the CR in CLEC Test since this process was just implemented, with potential closure in November.

09/18/02 September CMP Monthly Meeting Minutes

Qwest advised that the Level 3 notification had been issued and that the comment cycle was scheduled to end this Friday, September 20th. Qwest advised that Qwest Service Managers had sent out notifications to their CLECs advising them to provide their e-mail address. The CLECs expressed concern over the 48-our language as written and intervals that were longer than the standard intervals. Qwest confirmed that the 48-hour notification was from the due date and this would be clarified in the PCAT or in writing. CLECs expressed concern over participation in the trial. It was agreed that next time Qwest does a trial, Qwest could evaluate if additional CLECs need to be involved. CLECs requested that the final notification advise the CLECs of the impact of the e-mail notification change. Qwest advised that they would add language in the final notification that advises the CLECs that if they do not provide an e-mail address they would not receive the No Dial Tone notifications.

08/21/02 August CMP Monthly Meeting Minutes

Qwest provided a status update on issuance of the Level 3 notice. Qwest indicated that they were holding off until the current 2-wire 4-wire PCAT language gets published to the Web on August 26, 2002. Allegiance expressed concern that issuance was based on the no dial tone PCAT language since they have taken exception to the language. Qwest advised that this could be addressed during the 1:00 p.m. discussion on issuance of the PCAT language. Eschelon advised that they were disappointed that they will need to wait longer for issuance of the Level 3 notice. They stated that Qwest advised last month that it would be issued by this month’s meeting and now they have to wait longer. AT&T asked if they could only have one e-mail. Qwest advised that they could only have one and it must be different than the e-mail if they are receiving test results.

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07/17/02 - July CMP Meeting Minutes: Qwest will continue with the trial that began May 6, 2002. It is available to all CLECs. Allegiance asked if all CLECs had to request the process in order for it to proceed. Qwest responded that the answer is yes, it is all or nothing. Allegiance stated that there should be a choice and that the Qwest response does not reference the “all or nothing” position. Qwest responded that the Level 3 process will support this effort and will allow other CLEC participation.. Qwest will issue the Level 3 initial notice prior to the August CMP meeting. CR status was changed to development.

Subject: Allegiance - NDT Trial E-mail Notification Final Spreadsheet 5/6 - 5/31/02 Date: Mon, 10 Jun 2002 11:36:25 -0500 From: "Wicks, Terry" To: "'Cheri Hurless'" , "'Deni Toye'" , "'Kathie Simpson'" , "'Linda Hendricks'" , "'Mary Pat Cheshire'" CC: "Reece, Mamie" , "Best, Doreen" , "Hill, Todd"

Here is the finalized spreadsheet with the data and comments captured for May. The trial is continuing through June and I will have a separate spreadsheet for June.

<>

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

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CLEC Change Request Clarification Meeting

May 9, 2002, 3:30 p.m. (MT) Conference Call 877-564-8688 PC050302-1, E-Mail Notification of No Dial Tone at 48 Hours

Attendees: Ric Martin, Qwest Neil Houston, Qwest Mike Raleigh, Qwest Deni Toye, Qwest Terry Wicks, Allegiance

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

Review Requested (Description of) Change Terry reviewed Allegiance’s CR. He explained that the initial phone call would roll to voice mail and the issue is with the voice mail notifications falling through the crack. He would like to get an e-mail to have a record to hold Allegiance personnel accountable. Terry advised that there is currently a trial with Qwest and Allegiance on this process that started in February with the QCCC. Deni advised that the trial started May 6th and is to be concluded May 31st. Currently they are having the PTA System send the e-mail. Terry advised that the CR was submitted in addition to the trial to have this process implemented for all CLECs.

Confirm Areas & Products impacted It was confirmed that the area impacted was Provisioning for coordinated hot cuts and basic cuts. The product impacted is UBL, LX—Reuses.

Confirm Right Personnel Nvolved Qwest confirmed that Neil Houston would be the SME for response to this Change Request.

Identify/Confirm CLEC’s Expectation Allegiance would like this process implemented for all CLECs.

Identify any Dependent Systems Change Requests There are no related Systems CRs.

Establish Action Plan (Resolution Time Frame) The trial will complete May 31st. The CR will have the collective CLEC clarification and SME input at the June CMP meeting.

CenturyLink Response

Terry Wicks LEC Manager Allegiance Telecom, Inc.

SUBJECT: Qwest’s Change Request Response - CR # PC050302-1 E-mail notifications of NDT at 48 hours through PTA tool

This is in response to Allegiance’s Change Request (CR) PC050302-1. This CR requests that all notifications of No Dial Tone (NDT) at 48 hours prior to the cut date be provided to the CLEC via e-mail using Qwest’s Plant Test Access (PTA) tool. The current trial of PTA e-mail notifications with Allegiance began on May 6, 2002. The trial with Allegiance will continue during the implementation phase for this CR.

Qwest is able to provide all NDT notifications via e-mail using the PTA tool. PTA notifications require that CLECs provide Qwest with an e-mail address separate from the e-mail address provided for test results. CLECS should send their NDT PTA e-mail location to Deni Toye, dtoye@qwest.com. Qwest will add the CLECs NDT PTA e-mail address to the notification list upon receipt. To provide an efficient and uniform notification, Qwest will provide NDT notifications via the PTA tool to all CLECs.

Based upon Qwest’s understanding of the scope of this CR, Qwest views the implementation of this CR as a Level 3 Product & Process change. Timing of the implementation of this change will be dependent upon the quantity and nature of CLEC comments.

Qwest will seek concurrence for this approach at the July Monthly Product & Process CMP Meeting.

Sincerely,

Neil Houston Staff Advocate Policy & Law

cc: Mary Retka, Director, Technical Regulatory Interconnection Planning

Open Product/Process CR PC010302-1 Detail

Description Of Change

Qwest does not allow the provisioning of an Unbundled Loop within a colocation when an End User is serviced by a Remote Switching Unit (RSU). The orders are cancelled and a reject notice is sent to the CLEC. At this time, the CLEC has absolutely no recourse to be able to switch this customer's local service over to that CLEC. The inability to switch an End User that is serviced by a RSU over to a facility based CLEC is unacceptable and anti-competitive. The End User also has no capability to choose another carrier for local service. Allegiance has spent tremendous amounts of money to co-locate in Qwest Central Offices in order to be able to swith Qwest customers over to Allegiance facilities. Allegiance is requesting that Qwest develope a means to allow the switching of End Users service by a RSU to CLEC facilities .

Status History

Project Meetings

Subject: Re: CR Location Date: Fri, 28 Jun 2002 14:05:05 -0400 From: John Sheehan Organization: Frontier / ELI Carrier Services To: Richard Martin

Rick, Sounds fine. This can be closed.

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Subject: CR Location Date: Fri, 28 Jun 2002 10:56:25 -0600 From: Richard Martin Organization: Qwest Communications International, Inc. To: johnsheehan@frontiercorp.com

John,

Go to URL, http://www.qwest.com/wholesale/cmp/changerequest.html

Click on, "CLEC Qwest Change Request - Product/Process Interactive Reports" to launch the interactive report. The report is in Adobe Acrobat.

When in the report, click on the blue button with CR number PC010302-1. Review Action Item No. 5.

If the response satisfies the intent of Peder's question, please advise. If further clarification is required, please let me know.

Thanks

Ric

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Subject: Action Item 4 to CR PC010302-1 Date: Fri, 28 Jun 2002 09:28:57 -0600 From: Richard Martin Organization: Qwest Communications International, Inc. To: Mike Zulevic CC: Craig Saunders , Kelly Trachsel

Mike,

Based on our conversation regarding Action Item 4 to the subject CR, the response, which is stated below, didn't fully answer what you were looking for.

Action Item 4 Question and Answer:

Q. Covad expressed the need to have the geographical area of a RSU and the number of lines served by the RSU included in the ICONN database tool.

A. The ICONN database has not been set-up to provide the geographical area of a RSU. This is done through utilization of the DA Maps (refer to CR PC110201-1 and PC012902-1). The number of lines in a RSU will be delineated if the RSU does not share a NXX with another wire center. The number of lines associated with a Central Office NXX can be identified by performing a search on the NPA NXX under the Cetral Office Find tool located at the same URL as Action Item No. 3.

It is my understanding, from our call, that Covad would like to identify what RSUs are tied to a CO, where are the RSUs and what area do they cover.

If this is not correct, please provide further clarification.

Thanks

Ric

-- Subject: CR PC010302-1 Action Item EEL Pricing Comparison Date: Mon, 15 Apr 2002 10:38:51 -0600 From: Richard Martin Organization: Qwest Communications International, Inc. To: Terry Wicks CC: Robert Mohr , Robyn Libadia , Cindy Buckmaster

Terry,

The attached rate sheet is in response to the Action Item on your Change Request PC010302-1 requesting that Qwest provide pricing for an EEL from the Denver Dry Creek to an end-user fed from the Denver Tech Center wire center. You also requested rates for an Unbundled Loop to feed this same user from the one wire center.

The attached rates are for the EEL and UNE products for an EEL from the Drycreek office to an end-user fed from the Tech Center wire Center. As the only way to feed a customer located in the Tech Center Wire Center on an Unbundled Loop is with a collocation placed in the Tech Center Wire Center, the pricing example for the Unbundled Loop is for an Unbundled Loop feed from a collocation space located in the Tech Center Wire Center.

The rates for the EEL were taken from the Qwest templated agreement and, because Allegiance currently doesn’t have the ability to order EELs in Colorado in their contract, a request of this kind would require an amendment to the Allegiance Interconnection Agreement (ICA) before ordering could commence on this product. Rates for the loop were taken from the Allegiance ICA . Collocation would also need to be established at the Tech Center wire center for this example.

Please contact us if you require additional information on these products, or have any questions.

Sincerely,

Ric Martin - CRPM (303) 896-9823 Robyn Libadia- EEL Product Manager (253) 445-0234 Bob Mohr- Unbundled Loop Product Manager (303) 896-2160

PC010302-1 Allegiance response 4-12-02.xls

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CLEC Change Request Clarification Meeting

March 4, 2002, 9:00 (MT) Conference Call

PC010302-1, RSUs – the inability to provision UNEs

Attendees: Ric Martin, Qwest Cheri Hurless, Qwest Bernadette Derlein, Qwest Cindy Buckmaster, Qwest Terry Wicks, Allegiance

Introduction of Attendees Introduction of the participants on the Conference Call was made. Qwest explained that they wanted to review the current situation and get feedback from Allegiance.

Review Requested (Description of) Change Cindy advised that Qwest would be providing a drawing explaining how the Dry Creek CO was configured to the Tech Center RSU. Cindy explained that the Tech Center was connected to the Dry Creek CO by a transport medium (umbilical) and the end user would have a loop to the Tech Center. Cindy explained that there were two ways a CLEC could get a loop for the end user connected to the Tech Center. The first would be for the CLEC to be physically collocated in the Tech Center. The second would be to request an EEL from the dry creek office at whatever transmission level for the end user. Terry wanted to know how to tell if a customer was serviced out of an RSU. Cindy advised that the Raw Loop Data Tool cable field designation of EX would indicate this. Terry advised that it wasn’t practical for them to obtain a certificate for all their sales folks and to check each address separtely. Cindy explained that there is a Raw Loop Data Dump for each central office that would allow for various sorts on the data in the RLDT. A sort could be made on cables with EX and then by address. Terry asked if Qwest could provide information on how the transport for an EEL works and a narrative on the Raw Loop Data Dump. Terry asked about the RSUs that were tied to Dry Creek CO, Eagan, MN and Chandler AZ. Qwest will identify those RSUs tied to those Central Offices Qwest Identified the following Action Items to address: 1. Breakdown how an EEL works that uses a MUX, riding a higher capacity transport 2. Identify how collocation would occur in the different types of RSUs. 3. Identify the Raw Loop Data Tool Training available. Terry requested Qwest to address why the CLEC cannot obtain a loop for an end user that is identified out of the Central Office of record.

CLEC Change Request Clarification Meeting

Date: January 11, 2002, 9:00 (MT) Place: Conference Call 877-564-8688 Subject: PC010302-1, RSUs – the inability to provision UNEs

Attendees: Ric Martin, Qwest Neil Houston, Qwest Laurel Neher, Qwest Bernadette Derlein, Qwest Cindy Buckmaster Terry Wicks, Allegiance

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 Terry reviewed Allegiance’s CR. He explained that they had several orders they had to cancel due receiving reject notices on orders for UNEs. The problem indicated that COs customers given service by RSUs and routes to the CO where they are collocated and there is no place to cross connect. They are unable to port because they are in a RSU. He explained that they do not know they are in a RSU when processing an order. Laurel explained that the RSU would look like a CO. The switch depends on another switch for intelligence. She said that the LERG should have the CLLI. Qwest will look at the LERG to see if it has the information. Qwest thought that the NPNAXX would have the CO location. Neil advised that the Account Manager should advise which Colos have RSUs. The following COs have RSUs: Colorado – Dry Creek ? Center Park ? Denver SE ? Denver Tech Center – ISDN ? Aberdene ? Northglen Minnesota – Egan Arizona – Chandler Laurel explained that the RSU would need to the loop extended to the CO and this is done by ordering an EEL. Terry indicated that they look at customers that are serviced out of the CO where they are collocated at. Neil asked if Allegiance had any volume on the number of instances this is happening. Terry indicated that he did not. He advised that the reject notice was 10/24. Terry provided the TNs that were involved: RFG Management, Inc. 8400 E Cressent Parkway, suite 475, Greenwood Village, 80111, 303-771-0321. Banta, Hoyt, Everall 7979 Tufts Parkway, sutie 1050, Denver 80237, 303-220-8000 Terry indicated that he could go to the Raw Loop Data Tool and pull the address which provides the cable name fixed EX, but he could not identify on a CSR. Terry asked how Qwest determines a customer is in a RSU. Neil advised that it was a matter of Geography. The RSU is an electronic switch with a switch module connected by a TI to the CO. Neil advised that the customers referenced by Terry are in the Denver Tech Center. He explained that the loop is coming out of the RSC and doesn’t extend to the CO. Terry asked what is covered and what is available to view by CLEC. He does not want to have the cost of adding the EEL. He wants to be able to port from the CO where the records show the CO. His record is the CSR. Laurel indicated that the LERG should be used to determine the CO. Terry advised that another ILEC, GTE, put a card in their switch.

Identify/Confirm CLEC’s Expectation Allegiance wants to be able to port a UNE serviced out of an RSU from the CO where the records show the RSU’s CO is serviced and do not want to pay an additional cost.

Establish Action Plan (Resolution Time Frame) Qwest will identify what is contained in the LERG. The CR will have the collective CLEC clarification and SME input at the February CMP meeting.

CenturyLink Response

Terry Wicks Allegiance Telecom Inc

SUBJECT: Qwest Change Request Supplemental Response - CR PC010302-1 Remote Swiching Unit- Inability to provision UNEs

This letter is in response to the additional clarification requirements provided at the April 17, 2002 CMP Monthly Meeting on your Change Request PC010302-1 and supplements Qwest’s response dated March 12, 2002. The additional clarification requirements requested that Qwest:

1) Consider the reduction of the Non-Recurring Charge (NRC) for the EEL to allow a CLEC to order the EEL at the Loop NRC price. 2) Consider the elimination of transport rates where the transport would otherwise be billed in the EEL product. 3) Consider the identification of RSUs upon application of the CLECs for a collocation so as to ensure the CLECs make sound decisions about where to spend their collocation monies.

In response to items 1 and 2 above, Qwest’s research indicates that Qwest is in alignment with other ILECs on the handling of RSUs. As described in Qwest’s March 12, 2002 response, Qwest deploys RSUs in a number of situations. Primary among these situations is the deployment of augment switches to accommodate growth in a given geographic area. Installation efforts for EELs are more time and labor intensive than those for UBL, thus the higher NRC. In regard to transport, at times, the new RSU is either programmed to have the same NXX as the host, or has a unique NXX. Where the NXX is the same as the host, mileage is rated at $0. If the NXX is unique, mileage is calculated and the appropriate band rate applies. Reduction of the non-recurring charge or the elimination of the transport rate would tend to undermine both the embedded EEL and Collocation base. Based on our alignment with other ILECs, and the additional cost of the EEL product, Qwest is unable to reduce the NRC or eliminate the Transport charge from EELs provisioned under this arrangement.

In response to item 3, CLECs have access to several resources that indicate the structure of the Qwest network. Among these resources, the Raw Loop Data Tool indicates remotes via the ‘EX’ cable naming convention and the ICONN Database is being modified to identify remotes assigned to a given Central Office. As Qwest is not in a position to counsel CLECs on the construction of their network, Qwest would encourage CLECs to perform their own analysis and research.

Sincerely,

Cindy Buckmaster Product Manager Unbundled Loop Qwest Communications

CC: Bill Campbell – Product Director Qwest Communications Richard Martin – CMP Project Manager Qwest Communications

-

March 12, 2002

Terry Wicks Allegiance Telecom Inc

SUBJECT: Qwest Change Request Response - CR PC010302-1 Remote Swiching Unit- Inability to provision UNEs

This letter is in response to your Change Request PC010302-1 requesting that Qwest develop a process to allow the switching of end users service via an RSU to CLEC facilities.

General Information

The structure of the Qwest network occasionally results in the placement of Remote Switching Units (RSUs). These RSUs are a “spin off” of a host wire center and are created where geographic distance and/or population density requires. For the purposes of the Unbundled Loop, an RSU becomes the serving wire center for the end users it touches. As RSUs are deployed, end users served by the RSUs are terminated at the RSU. The structure between the host and the remote units becomes transport, therefore, there is no contiguous loop between the host and the end-users served by the RSU. End users of the remote are not individually identified at the host.

The underlying requirement of an Unbundled Loop is a Collocation in the serving wire center. The serving wire center for end users in the remote is the remote Central Office. Unbundled Loop can be ordered out of the remote only if the CLEC is collocated in the remote.

How to tell if an end user is in a RSU

The Raw Loop Data Tool (RLD) provides the CLEC with the information during pre-order to determine that the end user customer is served from an RSU. In the Raw Loop Data Tool the end user’s cable pair will indicate an “EX” prefix when the facility originates from an RSU (i.e., F1 ca EXA7).

There are two versions of the RLD tool. Using the IMA version a CLEC can view information specific to an end user address. With a digital certificate the CLEC can use the wire center version of the Raw Loop Data Tool. Data from this version of the RLD tool can be downloaded into an Excel spreadsheet or a database provided by the CLEC. Using the “File, Save As” commands from the browser software the CLEC can save the information to the location and in the format they prefer. Approximately 50 – 150 MB of disk space is needed per wire center. The process may be time intensive, as each wire center is checked separately.

See Loop Qualification and Raw Loop Data- CLEC Job Aid on URL http://www.qwest.com/wholesale/training/coursecatalog.html

How to serve customers in an RSU

The first option available to CLECs, to serve end users in a Remote Serving Unit (RSU), is to Collocate in the RSU.

Central Office Collocation:

For Central Office Collocation, each Central Office will be evaluated to determine if your Collocation requirements can be met (e.g., space, power, and heat dissipation).

Three types of Central Office Collocation are available:

Physical Caged Collocation – Allows the CLEC to physically collocate the CLECs own equipment in a Qwest Central Office in a space that is completely enclosed via chain link fencing. The CLEC installs, maintains and repairs their collocated equipment.

Physical Cageless Collocation - Allows the CLEC to physically collocate the CLECs own equipment in a Qwest Central Office in a space shared by Qwest and other CLECs that opt for Cageless Collocation. The CLEC installs, maintains and repairs their collocated equipment.

Virtual Collocation - Allows the placement of the CLECs equipment in a Qwest Central office, however, Qwest will install, maintain and repair the CLECs collocated equipment. In a Virtual Collocation arrangement, the CLEC does not have physical access to the virtually collocated equipment in the Qwest Central Office.

More information can be found in the Collocation Product Catalog (PCAT) at: http://www.qwest.com/wholesale/pcat/collocation.html

Enhanced Extended Loop (EEL):

The second option available to CLECs to serve end users in an RSU, is to request an Enhanced Extended Loop (EEL).

As the facility between the host Central Office and the remote Central Office is transport, the requested EEL would originate in the host office, extend through the remote Central Office and terminate at the end users premises. EEL can be ordered in two configurations; point-to-point (one transmission level from point of origination to point of termination) or Multiplexed EEL (a higher transmission level between the two central offices and a lower transmission level to the end user).

The "Multiplexed EEL" most closely resembles the network Allegiance has described. The CLEC can order a Multiplexed EEL with transport from their Collocation to another Qwest wire center. The Multiplexed EEL must be turned up before ordering EEL links (loops) to be connected to the Multiplexer. The EEL link orders must provide CFA (CKTID and slot number from the Multiplexed EEL). Each EEL, whether link or multiplexed, is ordered via an LSR. Standard intervals apply to each LSR EEL request. Intervals may be found under EEL/LMC in the Interconnection Service Interval Guide (SIG), also located on the Qwest wholesale website: http://www.qwest.com/wholesale/guides/sig/index.html

An abbreviated copy of that SIG has been attached to this document for ease of discussion (see Attached).

More information can be found in the EEL Product Catalog (PCAT) at: http://www.qwest.com/wholesale/pcat/eel.html

Billing elements are further described in the EEL PCAT and each billing element is labeled on the PCAT diagram. Billing elements for this situation are defined below.

Monthly recurring charges for a DS1 or DS3 multiplexed EEL, originating from a collocation, include: ITP, for the connection to the collocation, transport between the two Qwest wire centers, and multiplexing. Multiplexed EEL nonrecurring charges include transport and are applied to the multiplexer.

Monthly recurring charges for the DS1 or DS0 EEL links would be for the link only. EEL link nonrecurring charges include transport and are applied to the link.

Channel Performance charges may also apply (for DSO only).

A CLEC requiring EEL will need both EEL language and all applicable rate elements in their Interconnection Agreement in order to prevent rejection of the LSR. A CLEC with incomplete or no EEL information will need an amendment before EEL can be ordered. All rates and charges associated with EEL can be found in the CLEC Interconnection Agreement or the SGAT, Exhibit A.

Summary

As described above, Qwest will provide CLEC access to all end users, including those served by an RSU. As Qwest’s network complexities are vast, requests may require individual case basis (ICB) review. Qwest continues to modify its process to ensure CLEC access on a timely basis. Status will be provided in accordance with Change Management Process notification methods as updates to the process warrant.

Sincerely,

Bernadette Derelin Product Manager Unbundled Loop Qwest Communications

CC: Bill Campbell – Product Director Qwest Communications Cindy Buckmaster- Product Group Manager Unbundled Loop Qwest Communications Debra S Smith- Product Manager Unbundled Loop Qwest Communications Neil Houston – Network Qwest Communications Richard Martin – CMP Project Manager Qwest Communications

Open Product/Process CR PC081902-1 Detail

Description Of Change

Qwest has been pointed out that this is not a new or even a changed process. Qwest has stated that this information has been in the SGAT for approximately 6 years. Allegiance has never opted into the SGAT language for our ICA and up until 8/02/02, Allegiance was never aware that this information was documented in the SGAT.

Here is the wording for reference:

“If you are not ready within thirty (30) minutes of the scheduled appointment time, then you must reschedule the installation by submitting a supplemental LSR. If Qwest is not ready within thirty (30) minutes of the scheduled appointment time, Qwest will waive the nonrecurring charge for the installation option. You and Qwest will attempt to set a new appointment time on the same day and, if unable to do so, Qwest will issue a jeopardy notice and a FOC with a new Due Date.”

The statement implies that “if for any reason” the CLEC is not ready, then it will be SUPd at 31 minutes. It does not take into account that if Qwest fails to notify us of a no dial tone issue, according to the current 48 hour dial tone testing requirements, then the CLEC is still held accountable for not being ready and the order will be SUPd. At the maximum, we may have 1 hour and 30 minutes from the start time of the cut to resolve a no dial tone issue if no notification was sent prior to due date. This has happened to Allegiance several times, and some QCCC testers hold fast to this policy. We have had to escalate on these instances and in some cases it has been denied and the order was JEPd. The wording needs to change to identify exceptions to the rule.

If Qwest is not ready for whatever reason according to this policy, Qwest will work with the CLEC throughout the day to get it cut. But if the CLEC is not ready, Qwest is only allowing a maximum of 1 hour and 30 minutes ( less in many instances) to "get ready" or the order will be JEPd.

Qwest is not taking it into consideration when Qwest fails to follow all steps of the 48 hour dial tone testing requirements and timely notification to the CLEC. When Qwest fails to do this, Qwest is considering that the CLEC is not ready. Allegiance believes that in this type of situation, it is Qwest that is not really ready because Qwest has not followed all steps of the process. Qwest’s consequence for not doing the cuts on due date is the potential that Qwest may have to pay penalties. The current policy is allowing Qwest to work with the CLEC to get it done on cut date to avoid such penalties. The consequence to the CLEC is we can lose that customer if we cannot get the order cut on due date as promised and we only have a limited time to “get ready” in order to complete the cut.

Status History

Project Meetings

02/19/03 February CMP Meeting

Deni Toye–Qwest provided statistics regarding PTA NDT Notifications. All were sent within the 24-36 hour time frame. The QCCC has not been out of compliance so we have not executed the 30 minute rule. Lori Mendoza–Allegiance reported they have not had any problems, except they have gotten some PTA notifications without CFA information. This information has been provided to their Service Manager to investigate. Sharon Van Meter–ATT advised she will be meeting with her company to determine whether they will begin to use the PTA tool. This CR will be left in CLEC Test status until next month. At that time we will review additional feedback from the CLEC Community and determine a close date.

01/15/03 - Janaury CMP Meeting

Toye-Qwest stated that Qwest had distributed a notification on this CR and had responded to CLEC comments to the changes. Johnson-Eschelon stated that she had not yet read the Qwest response. Mendoza-Allegiance stated that Qwest has been much better, recently, on no-dial-tone notifications. This CR remains in CLEC Test.

12/18/02 - December CMP Monthly Meeting Minutes Qwest-Linda Hendricks advised the PCAT is out for CLEC comments with a planned implementation date of January 31. This CR will change to CLEC Test.

11/20/02 - November CMP Monthly Meeting Minutes Qwest (Hendricks) reported the PCAT is under development. This project will remain in Development status.

10/16/02 - October CMP Meeting Minutes Qwest reviewed the Acceptance Response to this CR and outlined when the exception will apply and when it will not apply. Eschelon clarified the following scenario: If Qwest can not reschedule the CHC for the same day the exception process will not apply. ATT expressed their concern that the exception process does not apply to VP Expedites. Qwest clarified the current VP Expedite Process does not change and this CR does not override the current VP Expedite Process. Qwest obtained agreement this CR would be handled as a Level 3 change and will follow the Level 3 process. This CR will move to Development status.

09/24/02 - September CMP Meeting Minutes Terry Wicks - Allegiance introduced and explained this CR would allow for an exception to the 30 minute rule for CHC process if CLECs do not get at least 24 - 48 hours NDT notification from Qwest. This applies to CHC only, not basic. In the case of not receiving notification QCC would work with the CLEC to reschedule the technician for sometime the same day instead of sup the LSR at 31 minutes. Jonathan-ATT said this should reduce the number of C01 misses. Linda Hendricks - Qwest explained if we are not doing the PTA email notification we won't be able to track whether the 48 hour NDT notifcation occurred. Eschelon and Allegiance expressed their support of the PTA tool. Qwest advised a response would be provided at the October meeting.

1:30 p.m. (MDT) / Monday 26th August 2002 1-877-561-8688 PC738 5723# Review CR PC081902-1 30 minute rule for Coordinated Hot Cuts

In Attendance: Terry Wicks - Allegiance Linda Hendricks - Qwest Bob Mohr – Qwest Cheri Hurless – Qwest Neil Houston – Qwest Cindy Macy – Qwest Ric Martin – Qwest Linda Sanchez-Steinke – Qwest Deb Smith – Qwest Deni Toye - Qwest

Introduction of Attendees

Review Requested (Description of) Change : Reviewed CR and confirmed business issues this CR will address. Terry requests the wording in the PCAT be changed to reflect an exception to the 30 minute rule if Qwest does not follow the 48 hour DT testing process. If Qwest notifies CLEC with 24 hours or less advance notice an exception process needs to be available. The exception process would allow Qwest and the CLEC to set a new appointment time on the same day, instead of jeopardizing the order and requiring the installation to be rescheduled by submitting a supplemental LSR. The business issue this CR is addressing is prevention of customer loss.

Confirm Areas & Products Impacted : Unbundled Loop / UNE / Loop Conversion orders existing customers PCAT – Ordering Wholesale UNE Installation Option Coordinated Installation with / with out testing

Confirm Right Personnel Involved : Linda Hendricks – confirmed as Lead SME Neil Houston – Network Regulatory Bob Mohr – Product Manager Cheri Hurless – Service Manager Cindy Macy – Change Request Project Manager

Identify/Confirm CLEC’s Expectation : Terry requests the wording in the PCAT be changed to reflect an exception to the 30 minute rule if Qwest does not follow the 48 hour DT testing process. If Qwest notifies CLEC with 24 hours or less advance notice an exception process needs to be available. The exception process would allow Qwest and the CLEC to set a new appointment time on the same day, instead of jeopardizing the order and requiring the installation to be rescheduled by submitting a supplemental LSR.

Identify any Dependent Systems Change Requests : CR PC 081902-2

Establish Action Plan (Resolution Time Frame) Document and issue meeting minutes within 5 business days (9-3-02) - Qwest Present CR at September CMP Meeting - Allegiance Present Draft Response at October CMP Meeting - Qwest

CenturyLink Response

October 16, 2002 For Review by CLEC Community and Discussion at October's CMP Meeting

Allegiance Telecom, Inc

SUBJECT: Qwest’s Change Request Response - CR #PC081902-1 The 30 minute rule for Coordinated Hot Cuts

Allegiance Telecom, Inc is requesting that Qwest change the wording and current process to allow the CLEC to work with Qwest on due date to get the cut done, when Qwest has failed to timely notify the CLEC according to the notification of NDT process, just as Qwest is allowing itself to do when Qwest is not ready. Update the PCAT with any changes resulting from this CR.

Qwest will accept the “30 Minute Exception” CR with the following guidelines:

-All CLECs must be enrolled in the NDT PTA Notification procedure in order to have accurate tracking and parity to ensure the success of the “30 minute rule” process.

-If Qwest fails to notify the CLEC within the timeframe of the NDT notification procedure, we will attempt to reschedule at a mutually agreed upon time for the same day.

-If Qwest is able to reschedule the same day it will not require a Customer Not Ready jeopardy and will not require a supp to the LSR. However the order will be in a CLEC delay status documented on the OSSCN screen in WFA/C.

- Rescheduling the Coordinated Hot Cut may not be workable on the same day. The appointment may require another date and time. This will result in a Customer Not Ready jeopardy.

- This process will be rework for Qwest in several departments and will require the CLEC to supp their LSR if another day and time is required.

The “30 Minute Exception” will not apply when:

- If Dial Tone is found at 48 hours before Due Date and noted in the OSSLOG, then at 1 hour before the due date the Dial Tone is no longer present.

- If the CLEC is not using the PTA NDT Email Notification.

- If the email systems of either Qwest or the CLEC were not working during the notification period, tracking would be invalid.

- If the CLEC has requested a VP Expedite and the interval does not allow the appropriate time for DT verification and CLEC notification (This process does not over ride the VP Expedite Process)

Qwest will issue this as a Level 3 change and seek concurrence of this approach at the October CMP Meeting.

Sincerely,

Linda Hendricks Lead Project Analyst Qwest

Cc: Mary Pat Cheshier, Diane Diebel

Open Product/Process CR PC081902-2 Detail

Description Of Change

*********************************************************************************************

Announcement Date: July 19, 2001

Effective Date: July 29, 2001

Document Number: PROS.07.19.01.F.00012

Notification Category: Process Update

Target Audience: CLEC

Subject: Dial Tone Test 48 Hours Before Due Date

Effective July 29, 2001, a process enhancement will be added to both the Coordinated and Basic Installation Option Processes. Qwest will verify the CLEC’s Dial Tone at the CLEC’s CFA 48 hours prior to the Due Date. This will assist CLECs in identifying dial tone concerns prior to the due date.

Central Office Technicians (COT’s) will check for CLEC Dial Tone 48 hours prior to the Due Date. The Dial Tone check will be for the Unbundled Loop Analog (Voice Grade) Product.

The COT will check for Dial Tone at the CLEC CFA. The COT will document the results from the Dial Tone test and the results will be forwarded to the Implementer/Coordinator (C/I).

If the COT does not detect Dial Tone 48 hours prior to the Due Date, then the (C/I) will contact the CLEC with the information. The CLEC should investigate and supply the dial tone by the Due Date or issue a supplement to the LSR to change the due date.

If the CLEC has requested a Coordinated Installation, the COT will check for Dial Tone one hour prior to the Coordinated Installation time. If dial tone is not detected at that time, then the COT will report this to the C/I who will in turn inform the CLEC.

This Process will be put in place to ensure that the CLEC will receive their circuit on the due date.

*********************************************************************************************

Allegiance believes that Qwest is not complying with the process as stated above. The testing for dial tone is actually being conducted on DVA date (48 hours after Application Date not 48 hours prior to Due Date). Also it is not clear as to when Qwest is notifying the CLEC of no dial tone conditions. This process implies that once the COT forwards the results to the QCCC tester at 48 hours prior to due date, then the tester will immediately notify the CLEC of No Dial Tone conditions. In actual practice, Qwest is not consistently notifying the CLEC at 48 hours prior to cut date. There are inconsistencies between the process and Qwest's actual application of the process. Qwest needs to comply with its published process. This process is not published in the PCAT. The only reference to this process that Allegiance could find was the mailout sent to CLECs on July 19, 2001.

Expected Deliverable

Qwest will comply with its published process. Qwest will update the PCAT to include this process.

Status History

Project Meetings

- 10/16/02 October CMP Meeting Linda Hendricks with Qwest reviewed the draft response to this CR dated 10/3/02. Language was updated in the 2-Wire 4-Wire PCAT Version 10 which was published on 10/11/02. There were no questions from the CMP participants and this CR will be updated to CLEC test.

- 09/18/02 September CMP Meeting Minutes Allegiance reviewed the CR submitted and explained that they would like to have the dial tone testing and notification sync up in the PCAT documentation because the process document, PROS.07.19.01.F.00012, is not clear. Allegiance and Eschelon would like the testing process and the notification process of a no dial tone condition on 5-day interval and on longer than standard interval orders clarified. If the CLECs understand when the dial tone testing is done, then, they can adjust the date their translations are complete. Qwest explained that the CLEC is notified 24 - 36 hours before the due date of a no dial tone condition. The dial tone test is performed on DVA, which on 5-day interval orders is 48 hours after application date. Qwest will clarify the process, for 5-day and longer than standard interval orders, in the PCAT. Allegiance said that clarification in the PCAT would satisfy this CR.

- CLEC Change Request Clarification Meeting 3:00 p.m. (Mountain Time) / Monday 26th August 2002

1-877-554-8688 1930099 # PC081902-2 The 48 Hour Dial Tone Testing Requirements

Attendees Terry Wicks, Allegiance Deb Smith, Qwest Linda Hendricks, Qwest Bob Mohr, Qwest Cindy Macy, Qwest Neil Houston, Qwest Linda Sanchez-Steinke, Qwest

Introduction of the participants on the Conference Call was made and the purpose of the call discussed.

Review Requested (Description of) Change Terry indicated that Qwest is not following the process in document number PROS.07.19.01.F.00012. The process is interpreted that Qwest does the dial tone test and then calls the CLEC right away. The following is extracted from the CR submitted by Allegiance: Allegiance believes that Qwest is not complying with the process as stated above. The testing for dial tone is actually being conducted on DVA date (48 hours after Application Date not 48 hours prior to Due Date). Also it is not clear as to when Qwest is notifying the CLEC of no dial tone conditions. This process implies that once the COT forwards the results to the QCCC tester at 48 hours prior to due date, then the tester will immediately notify the CLEC of No Dial Tone conditions. In actual practice, Qwest is not consistently notifying the CLEC at 48 hours prior to cut date. There are inconsistencies between the process and Qwest's actual application of the process. Qwest needs to comply with its published process. This process is not published in the PCAT. The only reference to this process that Allegiance could find was the mailout sent to CLECs on July 19, 2001.

Confirm Areas & Products Impacted Unbundled Loop 2 wire 4 wire Analog Voice Grade, Coordinated and Basic Option

Confirm Right Personnel Involved Qwest confirmed the correct personnel were on the call. Identify/Confirm CLEC’s Expectation

Allegiance requests the following deliverables on this CR: - Update the PCAT with the Qwest process, and the agreed upon number of hours before due date the dial tone check is done, and, the agreed upon number of hours before the due date that the CLEC is notified of a no dial tone condition. - Provide notification of the process above - Improve on the CLEC notification process when there is a no dial tone condition. Determine the minimum number of hours before due date that the CLEC’s would like to be notified of a no dial tone condition.

Identify any Dependent Systems Change Requests PC081902-1, PC050302-1

Establish Action Plan (Resolution Time Frame) Allegiance will clarify and review this CR at the 9/18/02 CMP Meeting. Qwest will present the draft response at the 10/18/02 CMP Meeting.

CenturyLink Response

Lori Mendoza LEC Account Manager Allegiance Telecom, Inc.

SUBJECT: Qwest’s Change Request Response - CR #PC081902-2 48 Hour No Dial Tone Notification

This in response to Allegiance Telecom’s Change Request (CR) PC081902-2. This CR requests that Qwest clarify its 48 Hour No Dial Tone notification process and to document the process in the PCAT.

Qwest accepts this CR and the following language has been added to the 2-Wire or 4-Wire Analog (Voice Grade) Loop V10 PCAT.

Qwest verifies for dial tone at your CFA 48 hours after Qwest’s APP (application) date. If Qwest finds No Dial Tone (NDT), Qwest will retest 48 hours prior to due date. If dial tone is still not present, Qwest will email the NDT results to you through Qwest’s Provider Test Access (PTA) email system. You will receive the NDT PTA email notification approximately 24 to 36 hours prior to the due date. Qwest will email only when there is No Dial Tone. You will need to supply the dial tone by the due date or supplement the LSR, changing the due date.

This language is in document review and will be published to the Wholesale PCAT web site on October 11, 2002.

Sincerely,

Neil Houston Staff Advocate Policy & Law

Linda Hendricks Lead Project Analyst

cc: Mary Retka, Director, Technical Regulatory Interconnection Planning

Open Product/Process CR PC061002-1 Detail

Description Of Change

Expected Deliverable:

Qwest to change this process ASAP, give the CLEC a reasonable amount of time (90 minutes) to correct a no dial tone situation on a reuse of existing facilities and give loops to the CLEC if there is continuity to the spot pair on new facilities

Status History

Project Meetings

- 10/16/02 October CMP Meeting Michael Buck with Qwest said that final notification PROD.10.11.02F.00839.Final24WireLoop was sent on 10/11/02 and the implementation date is 10/27/02. The CR is currently in Development Status and Qwest would like to move it to CLEC Test on the deployment date later this month. Byron Dowding with Alltel said that it was appropriate to move to CLEC test and discuss again at the November CMP meeting.

09/18/02 September CMP meeting Minutes Qwest discussed the revised draft response and provided an update that Qwest would no longer require dial tone on new unbundled loops effective mid-October. Conversion orders will continue to require dial tone. Qwest explained that the effective date is following the PCAT update for 2-wire 4-wire, Version 11, which is effective October 21, 2002. Allegiance and Eschelon appreciate Qwest changing to the no dial tone requirement on new unbundled loops. Allegiance also noted a clarification from the August Meeting minutes regarding the conversation on this CR. At the August meeting Lyndall Nipps – Allegiance asked why doesn't Qwest check for continuity on DS0 loops like you do for DS1 and above loops by plant test date. Qwest responded that it was not in the infrastructure to test for continuity on DS0 loops. A pre-survey is done for all UBL except for LX - -. LX - - is worked on the due date. This CR was moved to Development status.

9/12/02 2:29 p.m. To: cc:

Subject: RE: Updated Draft Response to CR PC061002-1

Byron -

The following is in response to Alltel's questions in your e-mail dated 8/27/02:

1. CHC means Coordinated Hot Cut (Y or N). You can have a Hot Cut with the Basic Option. Hot Cut means we go from one service provider to another on an existing service, this option can be ordered Coordinated or Basic.

2. Qwest is preparing to only require dial tone on reuse LX-- in mid-October.

3. The polarity of the Qwest wiring and facilities, from the CFA to the NI at the end user locations, can be checked using normal Qwest test systems and sets. The polarity of the supplied CLEC service can not be tested without the CFA operationally in service. If the CLEC provides service on the CFA with reversed polarity, Qwest will not reverse their wiring or facilities to correct, as this would impair Qwest’s ability to properly maintain the circuit in service. The polarity of a loop start line is of significant importance when the facility provided is anything but a plain copper loop. Pair Gain facilities require correct polarity of supplied service to operate correctly.

4. Qwest is preparing to only require dial tone on reuse LX-- in mid-October.

Please call me if you have any questions.

Thank you

Linda Sanchez-Steinke Change Request Project Manager Qwest

-- From: Byron.Dowding@alltel.com on 08/27/2002 08:03:51 a.m. To:

Subject: RE: Updated Draft Response to CR PC061002-1 Linda This is ALLTEL's response to the Qwest response I don't have any feedback yet to verify Qwest allowing more than 30 mintutes to provide dial tone on a loop. Byron

SUBJECT: ALLTEL response to Qwest response regarding change request PC061002-1 dated 08/19/2002

ALLTEL would like to make the following points.

1. The first statement in Qwest’s response states that this CR is about Qwest’s Hot Cut process. CR PC061002-1 has nothing to do with Hot Cuts. This CR is about ordering an unbundled loop with the Basic option and no testing (CHC is N). The service being ordered is 2/4 wire analog with the NC code of LX--. Due date on the loop being turned over to the CLEC and actual customer in service date don’t have a direct relationship. 2. The CLECs have stated several times that ordering a new loop and reuse should be handled as 2 different issues. We are willing to provide dial tone in a reasonable time when we are reusing a facility. When ordering a new loop no dial tone should be provided. 3. Our techs check for polarity when shooting trouble and can reverse the jumper/drop to correct the problem. Polarity should never be an issue with loop start dial tone. I would like to know how Qwest could check for polarity on loop start dial tone when dial tone is provided. 4. For the most part providing dial tone requires CLECs to program dummy numbers in their switch and then reprogramming when the service is actually turned up. This places a costly and unneeded burden on the CLECs.

ALLTEL is planning to charge Qwest for providing joint test capabilities when ordering unbundled loops that Qwest requires dial tone on. ALLTEL is also going to work with the regulatory agencies to significantly reduce the one-time charges associated with provisioning these types of loops.

-- 08/21/02 - August CMP Meeting Minutes: Qwest provided an updated draft response dated August 19, 2002 because information was missing in the August 13, 2002 draft response. The updated draft response is available on line and was handed out to participants in the meeting. Allegiance expressed concern that the 2-wire 4 wire PCAT updated language does not distinguish between new loops and conversions and that Allegiance and other CLECS are trying to find out the technical reasons why Qwest requires dial tone on new loops when there are other ways to check for continuity. Allegiance asked if Qwest checks for continuity from demarc to the central office before plant test date. Eschelon also asked for Allegiance’s question to be answered; does Qwest dispatch for continuity. Qwest stated (Hilleary) that we are pushing for dial tone on due date and dial tone 48 hours before due date is not a requirement. Allegiance disagreed. Qwest stated (Hendricks) that dispatch for continuity is not done, and the pre-survey is done to make sure there are facilities. Qwest stated (Braegger) that on services provided on UDC there is no way to verify correct service operation without Dial Tone on the circuit. Covad said that on digital loop carrier card verified set options correctly if have dial tone. Qwest (Braegger) stated that if Dial Tone is coming in reversed to the card, the card will not operate correctly and won’t operate unless there is battery to it.

Covad asked what would prevent Qwest technician from putting dial tone on temporarily from ICDF at cosmic frame. Qwest (Retka) asked that Covad send in procedure on a CR for Qwest to use spare dial tone temporarily from the ICDF.

Allegiance indicated that Qwest was the only ILEC requiring dial tone on new loops and is a burden on all CLECs when changing from T1 to UNE loop because translations are required for two different numbers and when Qwest checks for ANI the line is not the right number. Eschelon said there is effort that they must go through internally assigning dummy numbers to CFA to provide dial tone for Qwest.

Allegiance asked how Qwest identifies a fault and what does it mean in PCAT wording, pages 5-6 under the ordering section, asked if the purpose of notification is relationship managing. Eschelon asked if they should receive a jeopardy rather than a call if there was a short. Qwest (Boudhaouia) stated Qwest will re-write the PCAT. Allegiance said that the language creates concern over PIDS managing to process and Allegiance does not want the PCAT updated on 8/26/02. Qwest (Maher) stated that for Qwest and the CLECs to follow the CMP, the PCAT would be updated on 8/26/02 because there were comments from the CLEC community on the PCAT change, and Qwest had followed CMP and responded to those comments. Qwest (Schultz) clarified that the PCAT update included documentation of processes that were currently in effect. Allegiance objected to the PCAT update on 8/26/02.

Alltel asked for status of CR. Qwest (Graham) reviewed draft response part 1 reviewing why tests are done and the technical reasons for dial tone requirement.

Qwest (Hendricks) reviewed draft response part 2 reviewing the procedure for the basic option. When the CLEC selects the basic option and is not ready on due date, the technicians go on to their other work. If the CLEC calls back later in the day, then Qwest will try to get technicians back out. Alltel (Dowding) will check with Alltel people that asked for CR because they had said at 31 minutes the order has to be supplemented. Qwest explained that the 31 minutes would be applicable on the appointment time option but is not applicable on the basic option.

Due to another scheduled meeting, which many CMP participants wished to attend, the meeting was adjourned before discussion on the final disposition of the CR was concluded. Qwest will work offline with Alltel regarding the status of the CR and bring the CR back up for discussion at the September CMP meeting.

CLEC – Qwest Change Management Process Monday, August 12, 2002 Ad-Hoc meeting to discuss CLEC comments and CR Conference Bridge: 877.521.8688, passcode 7901848#

NOTE: These DRAFT meeting minutes were developed August 19, 2002 by Qwest following a meeting on the 2Wire 4Wire CLEC Dial Tone Requirement

MEETING MINUTES

The meeting was initiated by Qwest via Change Management notice CMPR.08.06.02.F.01307.CMPMtgFinalized that was distributed to the CLECs on August 6, 2002. Qwest scheduled the meeting to discuss the following two items with members of the CLEC community:

1) CLEC comments received for Notice PROD.07.12.02.F.00784.AnalogLoop24Wire 2) CMP Change Request PC061002-1 titled, “LSR put in Jeopardy when no dial tone present when Qwest installs Unbundled Loop” from Alltel.

The meeting began with Qwest reviewing the Qwest response to CLEC comments from Allegiance, Alltel, and Eschelon on the Level 3 notification sent out by Qwest on July 12th, 2002, PROD.07.12.02.F.00784.AnalogLoop24Wire. Several CLECs asked when the comments response had been distributed and Qwest responded that the notification had gone out the evening of August 9th, 2002, via notice PROD.08.09.02.F.00807.AnalogLoop24Wire and that the Qwest response to the comments had been posted under the Qwest CMP Product/Process Archive Document Review site under PROD.07.12.02.F.00784.AnalogLoop24Wire. Qwest then reviewed the response to comments with the attendees on the call. Allegiance stated that the Qwest posted comments referred to both conversion of analog loops as well as new installations, and that Allegiance did agree that CLEC dial tone should be required on conversion orders but not on new orders. Eschelon asked why the PCAT was being updated associated with PROD.07.12.02.F.00784.AnalogLoop24Wire. Qwest responded that the PCAT was being updated to reflect the requirement that Qwest currently has in place for these types of orders, and that the requirement was for CLEC dial tone prior to order completion. Eschelon, Allegiance, and ATT requested that the PCAT update be delayed until there was final resolution of the Alltel CR. Qwest responded that this request was out of process because the PCAT update needed to take place August 26th based on the final notice PROD.08.09.02.F.00807.AnalogLoop24Wire, but Qwest would take the request to delay the PCAT update back for final determination. Eschelon stated that there was no reason for CLEC comments if Qwest did nothing with them. Qwest responded that Qwest does take CLEC comments under consideration, but there is no CMP requirement to revise product/process changes based upon CLEC comments. Allegiance then stated that Qwest was the only ILEC requiring CLEC dial tone prior to order completion on NEW orders, and that Qwest needed to reevaluate the requirement. Covad stated that the issue could be resolved by Qwest providing Qwest dial tone to test the circuits, or that there were other test alternatives Qwest could implement. Qwest responded that the requirement for CLEC dial tone was still in effect due to technical requirements outlined in the response to CLEC comments, and that Qwest would provide a response to the Alltel CR at the August 21st CMP Monthly Product/Process meeting. The CLECs requested that a specific block of time be set aside at the CMP Monthly Product Process meeting to discuss this issue so they could have their technical subject matter experts on the call. Qwest agreed to set aside a specific time on August 21, 2002 to further discuss this. The time will be 1PM MT. The call-in number is 877 572-8687 passcode 3393947. The meeting then adjourned.

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07/17/02 - July CMP Meeting Minutes: Alltel introduced their Change Request. Alltel requested the wording in the meeting minutes for the clarification meeting held on June 18, 2002 be changed from “48 hours before the Due Date” to “48 hours after application date”. Allegiance stated that Qwest is the only ILEC requiring dial tone testing for testing continuity. Covad stated it should be the CLECs responsibility for providing dial tone. Eschelon stated all CLECs are interested in this Change Request. CR status is presented.

Clarification Call Time/Date: 11:00 qa.m. (MDT) / Tuesday, June 18, 2002 Place: Conference Call Conference: TEL: 877.521.8688 Call-In No: CODE: 7901848 CR No: PC061002-1 "LSR put in Jeopardy when no dial tone present when Qwests installs Unbundled Loop"

Attendees: Byron Dowding, Alltel Neil Houston, Qwest Linda Hendricks, Qwest Steve Hilleary, Qwest Michael Keegan, Qwest

1.0 Attendees introduced. 2.0 Description: The following is extracted from the CR submitted by Alltel: When ALLTEL orders an unbundled loop with a NC Code of LX--and the CHC marked N, Qwest checks for dial tone at the end user (new loops) or at the spot pair (reuse facilities). If there is no dial tone present, Qwest contacts the CLEC gives them 30 minutes to get dial tone on the loop or the LSR is put in Jeopardy and a new LSR has to be written with a new due date. If the order contains multiple loops and one of the loops does not have dial tone, all of the loops are placed in Jeopardy. Qwest has responded to our concerns saying that this has always been their procedure but it was not being followed. Because these orders are not coordinated hot cuts, Qwest can make their cut anytime during the day. It could even happen over a lunch hour. We have also had situations where Qwest has put a loop on the wrong spot pair, had no dial tone at the customer’s premise and placed the order in Jeopardy.

Clarification Call Discussion: Alltel indicated that this problem started recently (60 – 90 days ago) and has occurred at both Omaha and Grand Island, Nebraska

Alltel said the problem is they get a call from Qwest on the due date when no dial tone is present and the order is placed in jeopardy if the problem is not corrected in 30 minutes.

Qwest does a Dial Tone check on both Basic and Coordinated LX - - (2W/4W Analog)type orders on DVA (Design Verify Assign) which is approximately 48 hours after application Date. If there is no Dial Tone at that time Qwest contacts the CLEC to let them know there is no dial tone at this time. The notification is approximately 24-36 hours before the Due Date. I have verified a couple of orders and we have called Alltel after the Dial Tone Check to notify them that there was No Dial Tone at DVA. On Due Date Qwest does another Dial Tone check before they do the install or hot cut before Qwest starts to do the work. If Dial Tone is not present, the COT calls the QCCC (Qwest CLEC Coordination Center) Coordinator. The QCCC Coordinator calls the CLEC and lets them know that Dial Tone is not present at their CFA (Connecting Facility Assignment). The CLEC is given 30 minutes to correct the Dial Tone situation. If the CLEC is not ready in 30 mintues they are requested to send a supplement to their LSR for a new Due Date. If the LX- - has a Reverse Battery or No Signal NCI (Network Channel Interface) Qwest does not require Dial Tone to be present at the CLEC’s CFA. If the order has multiple loops the CLEC may split out the LSR and accept those that do have Dial Tone. The order without Dial Tone may be put on a separate LSR. The Coordinated Appointment Time Option allows the CLEC to choose exactly when they want the installation or hot cut to be performed. The Basic Option allows Qwest to start the installation or hot cut any time between 8AM and 5PM regional time. The COT should be doing the ANI test on the loop before and after they perform the lift and lay. The correct number should be identified. This is the process in place and should be followed to insure the accuracy of the request.

Linda Hendricks will prepare the Qwest response.

3.0 Confirmed that UNE Loop is the product impacted.

4.0 Qwest confirmed the correct personnel were on the call.

5.0 CLEC expects Qwest to change this process ASAP, give the CLEC a reasonable amount of time (90 minutes) to correct a no dial tone situation on a reuse of existing facilities and give loops to the CLEC if there is continuity to the spot pair on new facilities

6.0 No Dependent Systems Change Requests were identified,.

7.0 Action Items Alltel can present this Change Request to the CLEC community at the July Product/Process CMP meeting scheduled for July 17 Qwest will issue draft response to this Change Request by Aug 14 (one week prior to the Aug 21 CMP meeting). Qwest will discuss the draft response at the Aug 21 CMP meeting.

CenturyLink Response

Byron Dowding OSS Coordinator Alltel

SUBJECT: Qwest’s Change Request Revised Response - CR #PC061002-1 LSR put in jeopardy when no dial tone present when Qwest installs unbundled loop Alltel is requesting that Qwest change its Hot Cut process to allow for 90 minutes when no Dial Tone is present at the CFA and not to reject orders with multiple service requests when one of the requests must be rescheduled. (Part 1, No Dial Tone) Dial tone is required to provide a quality installation of the service ordered. To ensure adequate circuit level performance, installation and operational tests are performed. Dial tone must be present to perform these tests across the entire circuit: - To verify the assurance of the assignment and translation of the CFA. - To confirm the Competitive Local Exchange Carrier (CLEC) Connecting Facility Assignment (CFA) is operational and test hard wiring from the Qwest Interconnection Distribution Frame (ICDF) to the CLEC CFA. - To perform a polarity test at the termination of the Network Interface Device (NID) and to perform an overall end to end operational circuit test to ensure reliability and functionality. - When provisioning over Digital Loop Carrier (DLC), to perform ground start, loop start and polarity check tests to assure the electronic card in the DLC is operational and optioned correctly. These operational tests require dial tone to minimize trouble reports immediately following test and turn up. If the NC/NCI codes are such that the circuits do not require Dial Tone, Qwest does not require Dial Tone to be present at the CLEC’s CFA.

Qwest is preparing to no longer require the CLEC to provide Dial Tone on new Unbundled Loops (LSR ACT = N) in mid-October and will follow all appropriate CMP timelines. Prior to new Unbundled Loop Basic or Coordinated Hot Cuts, the Qwest Technician will conduct performance testing to assure the new Unbundled Loop complies with its respective NC/NCI standards.

(Part 2, 90 minutes) Perhaps the CLEC request reflects a misunderstanding. Qwest believes that the process in place more than meets the needs of the CLECs. The Basic Option allows Qwest to start the installation or hot cut any time between 8AM and 5PM regional time. Qwest actually allows more than 90 minutes when a Basic Installation is ordered.

Here is the procedure when the Basic Installation Option is ordered:

On Due Date when Qwest is finished doing the installation and core tests, we call to notify the CLEC that we are done and that the test has been completed. If the CLEC wants to do more testing on their own or they can't get something working on their end, Qwest waits 30 minutes, then calls the CLEC again. If the CLEC still isn’t ready Qwest lets the field tech and the Central Office Technician (COT) go to their next jobs.

Qwest will hold the order open and if we do not have a CLEC resolution by the end of day we will have the COT disable the circuit. If the CLEC calls back on the same day and is ready, we will try to get a tech back out (if applicable) and the COT back in the central office. If it is too late in the day, or the resources are not available, Qwest will jeopardize the order and the CLEC must supplement the LSR with a new desired due date.

If the order has multiple loops the CLEC should accept the loops that have Dial Tone and supplement the LSR to remove the loop that does not have Dial Tone. The loop without Dial Tone should be put on a separate LSR with a new desired due date.

In mid-October, on a New order the Outside Technician (OST) will check for dial tone. If the OST does not have dial tone they will: - Call the Central Office and have the COT check for dial tone. If dial tone exists, the OST needs to check the facilities and resolve. - If no dial tone exists, the COT needs to check for dial tone at the Connecting Facility Assignment (CFA). If dial tone exists at the CFA, the COT needs to check the wiring in the CO and resolve. - If dial tone does not exist, the COT will notify the OST and the COT will wire in temporary Qwest dial tone for the OST to perform core tests to complete the order. The QCCC Coordinator / Implementor will not need to notify the CLEC.

Sincerely,

Linda Hendricks Lead Project Analyst Qwest

Cc: Mary Retka, Mary Pat Cheshier, Diane Diebel

Open Product/Process CR PC102802-1 Detail

Description Of Change

- Pre-ordering (http://www.qwest.com/wholesale/clecs/preordering.html),

- LOA/POA (http://www.qwest.com/wholesale/preorder/index.html), and

- the IMA User’s guide (http://www.qwest.com/wholesale/downloads/2002/020916/ugpreorder_101_091302.pdf).

The Pre-Ordering website states "Before initiating activity, obtaining a CSR and placing orders on behalf of an end-user, you are required to have a Letter of Authorization or Proof of Authorization giving you authorization to do activity on their behalf." In a separate paragraph, the website provides "While it is not necessary for the LOA to accompany your request, the indication of authorization is required when you request a CSR for an account owned by Qwest or another CLEC." The initial reference to “Letter of Authorization or Proof of Authorization” by itself is fine, but the later reference only to "LOA" suggests written approval from the customer is required for access to the CSR. This is not the case. AT&T understands that customer authorization is required, but a written authorization is not. See 47 CFR Section 64.2007(b). This section of the federal rules identifies the methods by which a carrier may obtain customer approval to access CPNI. It states that "A telecommunications carrier may obtain approval through written, oral or electronic methods." State requirements in the Qwest territory largely mirror the federal rules.

The LOA/POA document states "Prior to obtaining records or placing orders for an end-user you must obtain permission from the end-user to act on their behalf in matters pertaining to the communications services." The following paragraph states "Proof of authorization can be arranged through a Letter of Agency" -- indicating there are options for obtaining authorizations from the customer. The third option cited is "oral authorization verified by an independent third party (with third party verification as POA)." Third party verification is necessary for a transfer of service, but is not required just to view a CSR. The website further states "While the Letter of Agency need not accompany your request for records or services, the indication of agency authorization is a required field entry when you request customer service records or submit Local and Access Service Request forms." As written, this language seems to require a written letter of authorization from the customer in order to view customer records. This is not consistent with the federal and state rules referenced above.

In the IMA user’s guide, "Reviewing Customer Service Records", 10.01 page 1-18 also provides that "Proof that a CLEC has received a Letter of Authorization (LOA) is required if the CLEC attempts to retrieve a CSR for a customer account owned by Qwest or another CLEC". Once again, this language suggests that a written letter of authorization is required. It is not.

While AT&T understands it is necessary to obtain customer consent prior to reviewing CSRs, it is not necessary to obtain written consent or third party verification of oral consent. Qwest does not have the authority through its PCAT, or otherwise, to demand more of CLECs than applicable law requires. AT&T would like to believe that the Qwest language referenced in this CR is simply inadvertent and does not represent Qwest’s intent to require more of CLECs than applicable law requires. However, AT&T does find this documentation troubling and believes that it is important that Qwest clean up its documentation to reflect what is required by applicable law. Please make these corrections and clarifications as soon as possible to avoid further confusion among Qwest’s CLEC customers. Suggestions AT&T would offer include: (i) do not use LOA interchangeably with other forms of authorization that may be obtained; and (ii) simply refer to applicable law in the places where the requirement for authorization needs to be referenced.

Expected Deliverable

AT&T expects Qwest to provide uniform instructions, in accordance with applicable law, within 60 days of submission of this CR.

Status History

Project Meetings

02/19/03 February CMP Meeting This CR is in development status and Donna Osborne-Miller with AT&T said that Qwest will incorporate the PCAT changes requested, the submitted comments, and they would like to leave the CR open another month. This CR will remain in development status.

01/15/03 January CMP Meeting Michelle Thacker with Qwest gave an update on this CR. Documentation for IMA will be effective 1/21/03 with IMA release 11.01. PCAT documentation is targeted to be available in late January. LSOG documentation and Preparation Guide will be available with the 12.0 IMA release in April. This CR will stay in Development status.

12/18/02 December CMP Meeting Linda Sanchez-Steinke with Qwest presented the draft response to this CR and said that CLEC facing documentation and the IMA User’s Guide will be updated. AT&T agreed with the Qwest response and Liz Balvin with Worldcom asked if there would be updates to the Preparation Guide. Qwest will e-mail an answer to Liz Balvin’s question and include in meeting minutes. This CR will be moved to Development status.

11/20/02 November CMP Meeting Carla Pardee with AT&T presented this CR and said that three of the Qwest pre-ordering web sites have different requirements ranging from oral to written approval prior to CLECs reviewing the customer service record. AT&T Legal interpretation is that only oral approval from customers is required prior to reviewing the CSR. Qwest will present the draft response at the December CMP Meeting.

CLEC Change Request Clarification Meeting

November 5, 2002, 3:00 p.m. (MT) Conference Call 1-877-554-8688 PIN 1930099 # PC102802-1 Correction/clarification of Qwest documentation (PCAT, IMA User’s Guide, etc.) describing customer authorization requirements for retrieval of CSR’s.

Carla Pardee, AT&T Mike Johnson, Qwest Sharon King, Qwest Cap Hamilton, Qwest Beth King, Qwest Michelle Thacker, Qwest Linda Sanchez-Steinke, Qwest

Introduction of the participants on the Conference Call was made and the purpose of the call discussed.

Review Requested (Description of) Change The description of change requested in the CR was reviewed. Carla indicated that AT&T is asking that there be consistency in all Qwest documentation associated with the review of customer service records (CSRs). AT&T Legal interprets the wording in the following Qwest websites to be inaccurate according to federal rules, 47 CFR Section 64.2007(b) - Pre-ordering (http://www.qwest.com/wholesale/clecs/preordering.html), - LOA/POA (http://www.qwest.com/wholesale/preorder/index.html), and - the IMA User’s guide (http://www.qwest.com/wholesale/downloads/2002/020916/ugpreorder101091302.pdf) AT&T’s interpretation is that approval to view the customer service record (CSR) can be in written, oral or electronic format.

Confirm Areas & Products Impacted Carla indicated that all products are impacted.

Confirm Right Personnel Involved Qwest confirmed that the right personnel were involved in the conference call.

Identify/Confirm CLEC’s Expectation Carla confirmed that AT&T is not disputing oral approval from customer to review CSR. The documentation wording sounds like the CLECs have to get written permission from customers to view their CSR and AT&T is asking that Qwest documentation be revised.

Establish Action Plan (Resolution Time Frame) This CR will be presented by Carla at the November CMP Meeting.

CenturyLink Response

Carla Pardee LSAM Manager AT&T

SUBJECT:Qwest’s Change Request Response - CR # PC102802-1 (Correction/clarification of Qwest documentation (PCAT, IMA User’s Guide, etc.) describing customer authorization requirements for retrieval of CSRs.)

This is in response to AT&T’s Change Request CR PC102802-1. This CR requests that Qwest clarify and correct as needed Qwest documentation (PCAT, IMA User’s Guide, etc.) that describes customer authorization requirements for retrieval of CSRs.

Qwest accepts this CR and will review and clarify CLEC facing documents pertaining or referencing customer authorization requirements.

The IMA User Guide 11.01, is targeted for review in late December and Qwest External Documentation is targeted for review in late January.

Sincerely,

Michelle Thacker Process Specialist Qwest

Open Product/Process CR PC110702-1 Detail

Description Of Change

Expected Deliverable

Notifications/mailouts list the precise rates effected.

Status History

Project Meetings

01/15/03 January CMP Meeting Barb Cornwell with Qwest gave an update on this CR and said that a generic Exhibit A will be provided with the Arizona Phase II A cost docket. This CR will remain in Development status.

12/18/02 December CMP Meeting Barb Cornwell presented the Qwest draft response and said that starting with the next Cost Docket, Qwest will include an Exhibit A in the notification. The Exhibit A will include the rates that are changing and timeframe the rates will be changed. Individual contract rate sheets are available from Qwest service managers. Joan Matzler added that SGAT rate changes are also available on the web site. This CR will be moved to Development status. Stichter-Eschelon provided updates to the notes to include the following: Would any change in the SGAT rate because of a cost docket apply to Eschelon? And Qwest responded yes.

11/20/02 November CMP Meeting Carla Pardee with AT&T presented this CR and said that the rate change notifications that Qwest currently provides do not meet AT&T’s needs. Carla said that they would like to have the new rates included in the notifications. Mike Zulevic with Covad said this is something he requests from the Account Team. Once rates are effective, Covad wants to understand the impact prior to implementation. Bonnie Johnson said that Eschelon has asked for rate changes many times and Kathy Stitcher added that previous change requests have been denied. A CR was denied in the May timeframe, because of the number of staff hours required. Sue Burson with Qwest said that she remembered the change request. Mike Zulevic said that Qwest might want to look at the dispute resolution process for billing and determine if providing the new rates is unduly burdensome. Judy Schultz with Qwest asked if AT&T was looking for rates associated with specific USOCs applying to AT&T. Carla Pardee said that last week they received notification about Arizona and the week before on Utah. They would like to know what the elements are, and what the new rate will be. With the Colorado UNE, we never received rates and it causes confusion, and the account team doesn’t always provide what is needed. Kathy Stitcher said that Eschelon submitted CR number PC053002-2X and it was denied because it was economically not feasible. Kathy said that on Arizona they did contact their service manager and also received a spreadsheet for Utah with some items missing. It was agreed this CR would move to clarification status.

- CLEC Change Request Clarification Meeting

November 14, 2002, 2:30 p.m. (MT) Conference Call 1-877-554-8688 PIN 1930099 # PC110702-1 Request that rate change notifications/mailouts contain rates effected. Introduction of the participants on the Conference Call was made and the purpose of the call discussed. Attendees Carla Pardee, AT&T Sue Kriebel, Qwest Barb Cornwell, Qwest Laurel Neher, Qwest Cliff Dinwiddie, Qwest Cindy Pierson, Qwest Dana Nielsen, Qwest Linda Sanchez-Steinke, Qwest

1 Introduction of Attendees Introduction of the participants on the Conference Call was made and the purpose of the call discussed.

2. Review Requested (Description of) Change The description of change requested in the CR was reviewed. Carla indicated that AT&T receives the mailouts when there is a Commission order or Cost Docket for rate changes and they would like to review the rates in a more efficient way and would like ability to compare the old rates to the new rates. Laurel Neher with Qwest asked if this would apply to Exhibit A SGATs. Carla said that most would be applicable and the Utah Order is what prompted the CR and it would be helpful to compare the new rates that were effective and be able to distribute throughout AT&T. Cindy Pierson with Qwest said that today on the Qwest web site Utah 10/16/02 is available in Exhibit A in the SGAT. Carla asked if there is a footnote that references the commission order and Cindy said that the note section lists the dockets approved in. Barb Cornwell with Qwest said that when the notice is received that if interested in AT&T specific rate sheets, an electronic copy of the rate sheet can be sent by the Service Manager. Barb also said that a notification for Arizona would be received today by AT&T. Carla will contact her Service manager and get with the AT&T people who requested the CR to provide information on the web site information available.

3. Confirm Areas & Products Impacted Carla indicated that all products are impacted.

4. Confirm Right Personnel Involved Qwest confirmed that the right personnel were involved in the conference call.

5. Identify/Confirm CLEC’s Expectation Carla confirmed that AT&T is interested in comparing the old rates to the new rates and that they are interested in AT&T specific rates.

6. Establish Action Plan (Resolution Time Frame) This CR will be walked on by Carla at the November CMP Meeting.

CenturyLink Response

Carla Dickinson Pardee ILEC Relations Manager AT&T

SUBJECT: Qwest’s Change Request Response - CR PC110702-1 Request rate change notifications/mailouts contain rates effected.

As a follow up to the December 18, 2002 CMP Meeting, Qwest will enhance the current process to additionally provide an Exhibit "A" rate sheet customized to specifically reflect only the rates Ordered in the Docket. This document will be attached as a communication piece with the rate change notifications/mailouts for CLEC distribution and reference.

Qwest plans to have this solution coordinated and operational to coincide with the implementation of the Arizona Cost Docket Phase IIA. Notification of the Arizona rate change is expected on or about January 15, 2003. Level 1 Process Change, PROS.12.26.02.F.00973.CRRateChange, was sent on December 26, 2002.

Sincerely,

Barb Cornwell Senior Process Analyst Qwest

December 3, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at December’s CMP Meeting

Carla Dickinson Pardee ILEC Relations Manager AT&T

SUBJECT:Qwest’s Change Request Response - CR PC110702-1 Request rate change notifications/mailouts contain rates effected.

Currently, Qwest notifications/mailouts advising of a rate change do not identify the affected rates. The purpose of the notification is to advise the CLEC of the pending implementation of a rate change as Ordered by a Public Utilities Commission. Qwest’s standard operating procedure is to ensure Interconnect Contract Agreements are updated with the Ordered rates are available to CLECs during the implementation process.

In response to this request, Qwest will enhance the current process to additionally provide an Exhibit "A" rate sheet customized to specifically reflect only the rates Ordered in the Docket. This document will be attached as a communication piece with the rate change notifications/mailouts for CLEC distribution and reference.

Qwest plans to have this solution coordinated and operational to coincide with the implementation of the New Mexico Cost Docket. Notification of the New Mexico rate change is expected on or about January 15, 2003.

Sincerely,

Barb Cornwell Senior Process Analyst Qwest

Open Product/Process CR PC012302-1 Detail

Description Of Change

Status History

Project Meetings

Attendees: Terry Bahner, AT&T Esther Scherer, AT&T Sharon Van Meter, AT&T Jonathan Spangler, AT&T Laurel Burke, Qwest Craig Suellentrop, Qwest Joan Wells, Qwest Peter Wirth, Qwest

Introduction of Attendees: Attendees introduced.

Review Requested (Description of) Change: AT&T would like to see more detail included in Qwest’s embargoed central office notifications. Specifically, AT&T seek great clarification about the cut-over process and the planned timing of cut-overs. AT&T also seek clarification on the product implications of this process.

Terry Bahner, AT&T reviewed the CR and added the following points that need to be addressed: 1) AT&T would like additional information on notices for both “switch embargoes” and “frame conversions” including the specific URL in the Qwest Wholesale web page identifying the schedule dates for embargoes/conversions in Qwest CO facilities. Joan Wells, Qwest identified the URL [http://www.qwest.com/cgi- bin/iconn/iconnembargoreport.pl?function=14]. Information was also requested regarding the Qwest contact for notice issuance, and the frequency and time interval for notices transmitted via e-mail to potentially affected CLECs. 2) AT&T indicated that current Qwest notices are incomplete in that “ordering embargo implications” are not addressed. AT&T expressed a need for written language in the notice directing the CLEC to the applicable Qwest procedures for product ordering during the associated “quiet time” and “embargo” periods. This would assist AT&T in planning orders, thus minimizing potential rejected orders during the actual embargo timeframes. Craig Suellentrop, Qwest indicated that current Qwest notices provide information on the physical cut-over process only and not overall product ordering during the entire embargo timeframe. Joan Wells, Qwest will investigate the location of Qwest procedures within the SGAT and PCAT. An example notification was submitted to Qwest via e-mail. This notification was transmitted to the Qwest participants prior to the clarification meeting. 3) AT&T raised questions regarding IMA 9.0. Terry Bahner, AT&T asked “what the different product embargo intervals are in regards to an LSR being rejected because of the IMA 9.0 edit?” Jonathan Spangler, AT&T indicated that the IMA edit was generated under a Qwest internal UR sometime in the November 2002 time frame. Qwest will investigate this IMA edit and determine the impact to product orders during the embargo time frame.

Confirm Areas & Products Impacted: LNP product added to CR.

Confirm Right Personnel Involved: Qwest & AT&T confirmed appropriate personnel were in attendance. Qwest will engage any other additional personnel, as required, to address the IMA 9.0 edit.

Identify/Confirm CLEC’s Expectation: Qwest to evaluate CR. During the February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR; or provide an expedited response to the CR.

CenturyLink Response

Terry L. Bahner Supervisor AT&T 1875 Lawrence St Denver, CO 80202-1847

SUBJECT: Qwest’s Change Request Response - CR # PC012302-1: Qwest to provide more detail in embargoed central office notifications.

AT&T is asking Qwest for more information regarding service order embargoes that occur because of switch conversions. During clarification meetings AT&T had several items that required information. AT&T would like the notices that are sent out about switch conversions to contain specific information about service order embargoes and what products are affected. AT&T is also interested in information about whether a service order embargo applies to LNP port-out activity. Finally, AT&T asked about the IMA 9.0 edit and what orders would be rejected because of this edit. AT&T was particularly concerned about LNP port-out activity regarding the IMA 9.0 edit.

Notices regarding trunk-side services are sent out 90 days and 30 days prior to conversion. These notices are sent to carriers (CLEC’s, IXC’s, and wireless providers) that have LIS, Feature Group, or Type II trunks in the affected switch. If any carrier would like to augment their existing trunks in the new switch, orders to disconnect from the old switch and connect to the new switch must be provided 60 days prior to the conversion. If the carrier only wants to have their trunks transferred on a “like-for-like” basis, the disconnect and new orders must be received 30 days prior to the conversion. Service orders for trunk side facilities are embargoed for 35 days during the conversion process. This interval is established as 30 days prior to the conversion until 5 days post conversion. These dates are stated on the notices.

For line side facilities a service order embargo is in place approximately 5 days prior to the conversion and continues until 2 days after the conversion. Centrex orders will have a standard 5 week embargo (10 days prior to the conversion and 4 weeks post conversion). Service orders with due dates falling within these periods will be rejected. The only exceptions are for disconnects, service denial/restoral, and LNP port-out activity. Some switch conversions (an ISDN only switch for example) have no associated service order embargo. Service order embargo dates are contained on the ICONN website (database http://www.qwest.com/cgi-bin/iconn/iconnembargoreport.pl?function=14).

The IMA 9.0 edit went into effect on February 23, 2002. This edit was put into place to reject line-side orders with due dates that fall within the embargo period. A patch was put into effect on February 27, 2002 to allow LNP port-out orders to flow through.

Sincerely,

Craig Suellentrop Interconnection Planner Qwest

Cc: Joan Wells, Senior Process Analyst, Qwest Mary Retka, Director Legal Issues, Qwest

Open Product/Process CR PC013102-1 Detail

Description Of Change

Status History

Project Meetings

03/19/03 - March CMP Meeting James Kaster Qwest reported ATT gave a presentation to the Colorado PUC on March 13, 2003. This was a very forward looking presentation and the PUC is currently reviewing the information. This team will continue as an ongoing task force. Cindy Macy Qwest asked if ATT would be able to share the presentation with the Forum and also if we could close this CR since the team will be an ongoing task force. Donna –ATT agreed to check with Ervin Rea and let us know if we could close the CR and share the presentation. The suggestion was made to share the presentation at the next CLEC Forum. Donna will advise Cindy of her decision.

02/19/03 - February CMP Meeting Kaster–Qwest advised the team is targeting to present to the PUC in March. The date of the meeting was not known at this time. Sharon Van Meter – ATT asked if Ervin Rea from ATT is involved and Qwest advised yes.

01/15/03 - January CMP Meeting

Kaster-Qwest stated that AT&T will present their report to the FCC in March. The CR remains Development.

12/18/02 December CMP Monthly Meeting Qwest-Kaster and ATT-Spangler advised SME Jim W. and Rich Kaplin are finalizing the presentation. Jim W is working on obtaining the cost estimate and reviewing the data that Entrado provided. They have found some inaccuracies in the data from Entrado that need to be clarified. They have approximately 43 pages of data that needs to be paired down into a presentation. There is a 911 Task Force meeting in January and then again in March. The team would like to present at the January meeting if their data is accurate, otherwise they will continue working on the presentation and present in March. This CR will remain in Development status.

11/20/02 November CMP Monthly Meeting ATT (Spangler) advised they are continuing to work on this project. ATT will plan on presenting their process at the January Colorado PUC meeting. This project will remain in Development status.

10/16/02 October CMP Monthly Meeting ATT advised they are continuing to work on this project but do to additional investigation needed they will not be able to submit their plan as scheduled and will not be able to present at the November Colorado PUC meeting, but plan on presenting at the January meeting. This project will remain in Development status.

Subject: RE: PC013102-1 DMS 100 SR/ALI Change Request Action Item Date: Wed, 9 Oct 2002 19:03:06 -0400 From: "Spangler, Jonathan F, NCAM" To: "Martin, Rick" CC: "Boykin, Timothy (Tim), NCAM" , "Kaplan, Richard S (Rich), NLNS" , "Roth, Diane F, LGA" , "Morgenstern, Dale C, NLNS" , "Bruno, Vincent G, NLNS" , "Friesen, Letty S, LGA" , "Ann Adkisson" , "Carla Pardee" , "Donna Osborne-Miller" , "Ervin Rea" , "Esther Scherer" , "Sharon Van Meter" , "Teresa Bahner"

Per AT&T's action item for CR PC013102-1 DMS 100 SR/ALI, AT&T will not be able to provide a presentation regarding solutions to the 911 default routing in the Denver MSA. AT&T recognizes that this delay jeopardizes our plan to present our solutions to the CO 911 Task Force to be held in November.

If you have any questions, please let me know.

Jonathan Spangler Carrier Performance - Western Region AT&T Local Services & Access Management Voice: 303-298-6240 Fax: 303-298-6455 Email: jfspangler@att.com Pager: 888-858-7243 pin 106241 or jonathan.spangler@my2way.com

09/18/02 September CMP Monthly Meeting Minutes

Qwest advised that AT&T was developing a plan for the Denver area to have 9-1-1 calls default routed by CLEC. Qwest indicated that they would then review the plan and if acceptable schedule a preliminary meeting with the Colorado PUC and another CLEC (ICG). The next step would be to present the plan to the PSAPs at the PUCs formal meeting in November. Eschelon asked if the CLECs would be involved in any of the meetings and if they would have a chance to review the plan. Qwest advised that the meeting in November might be open and they would provide notification when the meeting was taking place. Qwest also indicated that they would post AT&T’s plan to this CR in the CMP Product/Process Change Request Interactive report. The CR will remain in Development.

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08/21/02 August CMP Monthly Meeting Minutes

Qwest advised that there was a meeting on July 23, 2002 with a wide range of participation including other ILECs, Nortel, NENA Working Committee Chairperson, BellSouth and Idaho PUC. The result of the meeting was that the NENA Working Committee would work towards a national standard, and for the Denver Market, AT&T would be developing a plan for default routing by CLEC. AT&T is currently working with BellSouth to put a recommendation to submit to Qwest for Qwest to pursue funding. The goal is to have everything complete by 10/15/02 for presentation to the PUC and PSAPs. AT&T advised that they concurred with Qwest’s status and appreciated everybody’s participation. They were participating in the NENA working committee and were happy with the progress. They indicated that they would be sending some minor comments to the minutes.

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CLEC Change Request Qwest & AT&T Conference Call

July 30, 2002, 8:30 am (MT) Conference Call

877-572-8687, P/C 7994817 PC013102-1, DMS100 SR/ALI

Attendees: Ric Martin, Qwest Jim Kaster, Qwest Jim Winegarden, Qwest Matt Kruzick, Qwest Jonathan Spangler, AT&T Ervin Rae, AT&T Richard Kaplan, AT&T

Introduction of Attendees Introduction of the participants on the Conference Call was made and the purpose of the meeting discussed.

Discussion Items Rich Kaplin indicated that based on 7/23/02 conference call, AT&T would like to pursue Tom Breen’s recommendation, for the Denver Market, as set forth in paragraph 2.13 of the 7/23/02 meeting minutes. The language from the meeting minutes is as follows: "Tom Breen responding as the NENA Network Technical Committee Chairperson indicated that if the need is to be able to default route at something more granular than the rate center, one would need to assume that the PSAPs play fair, and, with cooperation from Qwest, there would need to be negotiations with the PSAPs. Recommendation could be to get one default PSAP for a rate center or by carrier. Get a PSAP to volunteer to be the default PSAP for the rate center. If picked well, they would most likely be the PSAP handling most default routed calls anyway. Tom indicated that all PSAPs need to be involved in the process. Tom indicated that the long-term solution resides in NENA committees. He indicated that Tom Hinkleman could provide the pre-release final technical recommendation on rate center consolidation. It will be published by NENA shortly. Tom Breen stated that if the above could not be achieved, alternatively, all CLEC’s could ask to negotiate with Qwest for not using NPANXX based routing, however, once the TN/ESN is established (without the delete function on disconnects), the legacy record will remain and could misguide the call. This cannot be on a CLEC by CLEC basis because Number portability will mean that the NPA-NXX ranges will NOT be or will not remain unique to any given CLEC or ILEC. If the wild cards are to be removed it will require it being a switch wide process on each affected Selective Router/SR-ALI database. Tom Breen recommends trying to educate the PSAPs in the area on the technical limitations of the system, and ask them to cooperate in identifying a default PSAP per Rate Center, even if there has to be more than one to spread the load from all of the area’s carriers."

The general discussion was that we needed to look at the reduction in the number of trunks (7) going to the primary PSAPs in the Denver area. The general consensus was that there would be PSAP jurisdictional issues to overcome and we should first get the Colorado PUC buy-in and support from another CLEC. It was agreed that ICG would be an acceptable CLEC. In addition to the jurisdictional issues with the PSAP, the cost issues will need to be addressed.

It was agreed that Rich Kaplin would develop a plan with associated PSAP benefits for reducing the number of Trunks. Jim Winegarden would provide technical support to Rich. Jim Kaster would be Qwest’s point of contact for receipt of documentation of AT&T.

It was understood that the plan would look at the reduction in the number of trunks and does not change Qwest’s standard on default routing. Based on the PSAPs designated to the reduced number of trunks, Qwest will need to change their default wild card to that PSAP and update the NPA NXX, which will require a complete reload. This could be accomplished by staggered cuts.

The following plan was agreed to: - AT&T will submit a working plan by the end of September - Qwest will perform its cost evaluation by mid October - ICG support and participation will be obtained. - If Qwest agrees to move forward, Qwest will initiate a preliminary meeting with the PUC staff by the end of October. - Presentation will be made at the PUC Task Force meeting on November 14, 2002. - With support from the PUC, a presentation will be made to the PSAPs – timing to be determined.

It was agreed and recognized that participation in the NENA Default Path subcommittee was very important.

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CLEC Change Request CLEC and Industry Conference Call

July 23, 2002, 8:30 am (MT) Conference Call

877-572-8687, P/C 7994817 PC013102-1, DMS100 SR/ALI

Attendees: Ric Martin, Qwest Linda McKelvey, Qwest Jim Kaster, Qwest Jim Winegarden, Qwest Mary Wallace, Adelphia Jonathan Spangler, AT&T Vince Bruno, AT&T Dale Morgenstern, AT&T Richard Kaplan, AT&T Bernard Brabant, Bell Canada – NENA Default Path Working Group Chairperson Tom Breen, BellSouth Gretchen Leedy, Cbeyond Michael Lipread, Cbeyond Susan Bumstead-Smith, Century Tel Sheila Stewart, Century Tel John Walker, Complete Telecommunications Amanda Owens, Eschelon David Frame, Eschelon Paul Hanser, Eschelon Wayne Hart, Idaho PUC Joe Schumacher, Intrado Steve Sipple, Nortel James Baron, Talking Nets Rana Peeling, US Link Kim Sattler, US Link

Introduction of Attendees Introduction of the participants on the Conference Call was made and the purpose of the meeting discussed.

Jim Kaster provided background on the AT&T Change Request and directed participants to the CMP Web site to review the CR. Jim addressed the parties involved being the end user, independent telephone companies, CLECs, Qwest, Public Service Answering Point (PSAP) and the State. The PSAP and the State would be left to accept or reject any recommendations on Default Routing.

Discussion Items Jim Winegarden provided a brief history of 9-1-1 default routing. Jim Winegarden provided a technical explanation of Qwest’s 9-1-1 process. Jim explained that the main issue is with the period of time delay between when the end user has service and the related Service Order Input (SOI) order is entered into the Selective Router Database (SRDB). Jim also indicated that a concern with the use of 10 digit number in the SRDB is that with a disconnect, the number will always remain in the SRDB.

Rich Kaplan indicated that the basis for AT&T’s provisioning found some misroutes caused by the NPA-NXX wildcard. Their issue with Arapahoe County facilitated their issuance of the CR. Arapahoe County withdrew their request. They are still looking for a collective solution for reducing the time period for updates after SOI record submission. The TN Emergency Service Number (ESN) legacy records could still cause misroutes and would require removal. Need to address the first few hours new customers could go to any of the (40) PSAPs in Denver. Jim Kaster explained the PSAPs will transfer the call to the appropriate PSAP.

General consensus in the meeting was that the best thing that could be done is to get the most timely SOI order updates processed.

Tom Breen advised the AT&T’s situation is similar to what BellSouth did in Atlanta with their Rate Center consolidation and linking one primary default PSAP to the Rate Center. Tom indicated that the best solution is timely updates of the database, speed-up the front end processing and PSAP designation to the appropriate Rate Center.

Jim Kaster advised the he believed there was another National Emergency Number Association (NENA) Work Group addressing real time updates.

Rich Kaplan addressed their request on the removal of wild cards and route to the trunk group ESN.

Bernard Brabant indicated that if we’re talking Denver, Colorado has gone through a major rate center consolidation. Records in the Selective Router Database (SRDB) would increase, as every TN/ESN records would have to be transmitted and kept in the SRDB. One of the issue would be uploading that information, due to transport and interface limitations. Need to apply 1 rule nationally. Removal of NPA-NXX wild card would require assignment of trunk group default by Customer entity (Municipality, Region, County, State, Primary PSAP, etc.) and at a minimum by rate center. Canada has deployed a province wide 9-1-1 system arrangement where trunk group default is provided at the Customer/entity/Primary PSAP level. NENA should address the needs of the wireline, wireless and IP worlds.

Jim Winegarden indicated that a default by trunk group would only happen with an ANI failure or no record found.

Tom Breen indicated that in addition to the ALI Database Manager, it is the responsibility of all carriers to improve their service order provisioning process. This may require significant changes to exisiting Operational Support Systems.

Jim Kaster addressed the additional impacts imposed by states. Example is the State of Washington that SOI orders can’t be sent until midnight the day after cut.

Tom Breen addressed NENA future planning. Tier 1 data delivered with each 9-1-1 call would have the incoming call location coded into the call. There is a Powerpoint presentation that was presented at Indianapolis that he could share. Tom also indicated that they were looking at the ability to make the TN ESN address info on the fly and simultaneously update the SRDB (for calls made from a PBX or CTX) .

Vince Bruno suggested that there are some long term solutions, some not so long term solutions and some solutions available today. He wanted to know what solutions are available today (i.e. get SOI orders delivered more quickly, explore issue of disconnects to reduce exposure). Bernard Brabant indicated that the NENA Default Call Path Working Group was being reinstated and there would be a meeting around mid-August. The goal is to come up with a Technical Information Document (TID) on E911default routing standards. Tom Breen suggested using the data technical committee working on ALI database. With his Network Technical Committee hat on Tom Breen suggested the Denver area matter may require special arrangements to solve. His statement in no way implies any obligation on Qwest, AT&T, any other CLEC or any PSAP(s). Rich Kaplan asked if their request to remove wild cards is an option. Tom Breen indicated that the removal of wild card doesn’t correct the problem when there is old record information in the SRDB. Rich Kaplan asked if with a new customer assigned an existing TN, does the legacy record get removed with a disconnect? Jim Winegarden explained that there is no disconnect and the record will remain but the new SOI overlays the old record covering the TN.

Steve Sipple clarified that a range of TNs could not be batch and loaded into the SRDB. Each individual TN needs to be loaded. It was established that the DMS100 could not accept a single tape load of the SRDB and instead must be loaded through individual transactions. Bernard Brabant indicated that an Ethernet Interface Unit (EIU) card allows for faster transactions processing to the selective router. Bernard further indicated that Bell Canada is using an Intrado's Management System set of software applications that does process delete for those TNs that are currently in exception in the MS' SRDBQ file, by sending the deleted TN with the NPA NXX default ESN to the 9-1-1 SRDB (selective router switch) for an overwrite. Tom Breen indicated that some E911 SSPs don’t use that faster TCP/IP port yet, and it would require changes to their ALI DBMS-to-SR update processes.

Bernard Brabant cautioned that before deciding on the best way to go, we need to look at the overall impact. Bernard suggested interested parties are welcome to join his NENA working group. If interested they should send an e-mail to bernard.brabant@bell.ca.

Rich Kaplan asked if Qwest was confident that the 40 PSAPs could effectively transfer calls between PSAPs. Jim Winegarden said yes.

Rich Kaplan asked Tom Breen if he had any recommendations. Tom Breen responding as the NENA Network Technical Committee Chairperson indicated that if the need is to be able to default route at something more granular than the rate center, one would need to assume that the PSAPs play fair, and, with cooperation from Qwest, there would need to be negotiations with the PSAPs. Recommendation could be to get one default PSAP for a rate center or by carrier. Get a PSAP to volunteer to be the default PSAP for the rate center. If picked well, they would most likely be the PSAP handling most default routed calls anyway. Tom indicated that all PSAPs need to be involved in the process. Tom indicated that the long-term solution resides in NENA committees. He indicated that Tom Hinkleman could provide the pre-release final technical recommendation on rate center consolidation. It will be published by NENA shortly. Tom Breen stated that if the above could not be achieved, alternatively, all CLEC’s could ask to negotiate with Qwest for not using NPANXX based routing, however, once the TN/ESN is established (without the delete function on disconnects), the legacy record will remain and could misguide the call. This cannot be on a CLEC by CLEC basis because Number portability will mean that the NPA-NXX ranges will NOT be or will not remain uniqie to any given CLEC or ILEC. If the wild cards are to be removed it will require it being a switch wide process on each affected Selctive Router/SR-ALI database. Tom Breen recomends trying to educate the PSAPs in the area on the technical limitations of the system, and ask them to cooperate in identifying a default PSAP per Rate Center, even if there has to be more than one to spread the load from all of the area’s carriers.

Tom Breen explained that BellSouth’s plan is to move to a centralized Off-Board Selective Routing (OBR) Interface developed by Nortel (ENS00011). Initially they would default route by incoming trunk group and in the future the originating switch’s Tier 1 call data will likely contain the info to route to the correct PSAP. It is anticipated that the OBR database will NOT use wild cards.

Joe Schumacher indicates that Intrado processes SOI records three times a day: 3 AM, 11 AM, and 3 PM

It was agreed that the follow-on CLEC and Industry meeting scheduled for July 30, 2000 would be canceled. Qwest and AT&T will meet to address the discussions from today’s meeting and discuss the appropriate steps to be taken.

07/17/02 - July CMP Meeting Minutes: Qwest is moving forward with the list of attendees for meetings scheduled for July 23, 2002 and July 30, 2002. Meetings are to look at establishing an Industry recommendation on 911 Default Routing. CR status remains development.

06/18/02 Conference Call

Attendees:

Susie Bliss – Qwest Jim Kaster – Qwest Jim Winegarden – Qwest Ric Martin Qwest Jonathan Spangler – AT&T Ervin Rea – AT&T Rich Kaplan – AT&T Vince Bruno – AT&T Tim Boykin – AT&T

It was agreed that two follow-on meetings would be held.

First - July 23, 200 8:30 to 11:30 MT conference bridge 877-572-8687, ID 7994817 Second - July 30th 8:30 to 4:30, hosted by AT&T at their Denver office on Lawrence street.

06/12/02 Conference Call

Attendees:

Susie Bliss – Qwest Matt Kruzick – Qwest Jim Kaster – Qwest Jim Winegarden – Qwest Ric Martin Qwest Jonathan Spangler – AT&T Ervin Rea – AT&T Rich Kaplan – AT&T Vince Bruno – AT&T Dale Morgenstern – AT&T Tim Boykin – AT&T

Conference call was held with AT&T to address action items from the May CLEC Forum, 911 Breakout Session and to discuss disposition of the CR

Qwest advised that they had received written communication from Arapahoe County that the issue with AT&T has been put to rest. AT&T is to work with Arapahoe County on obtaining the written communication that Qwest received.

Both Parties agreed that the solution to AT&T’s Change Request should come from NENA. NENA has a subcommittee on the topic of Default Routing. In addition there is another subcommittee on the topic of Global Dynamic Updates. It was agreed that each party would review internally what each party could contribute to developing a recommendation to take to NENA.

It was agreed that there would be another conference call on Tuesday, 6/18 to review a high-level framework of what this recommendation should be to move forward. AT&T will issue a draft high-level framework document by Friday 6/14 for review on Tuesday.

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CLEC Change Request Information Exchange Meeting March 4, 2002, 10:00 (MT) Conference Call PC013102-1, DMS100 SR/ALI

Attendees: Ric Martin, Qwest Linda McKelvey, Qwest Jim Kaster, Qwest Patty Joe Ryan, Qwest Jim Winegarden, Qwest Phil Linse, Qwest Jonathan Spangler, AT&T Ervin Rea, AT&T Tim Boykin, AT&T Letty Friesen, AT&T Vince Bruno, AT&T Dale Morgenstern, AT&T Richard Kaplan, AT&T

Introduction of Attendees Introduction of the participants on the Conference Call was made and the Agenda was reviewed. Qwest explained that the purpose of the meeting was for each party to provide an exchange of technical information for each to fully understand each others respective 911 network architectures. AT&T expressed that they wanted the CR to be expedited. AT&T indicated that they also wanted as an outcome of the meeting a perspective of a path forward with Action Items. Qwest advised that they would not commit to coming up with solutions.

Discussion Items AT&T provided a power point presentation of their Architecture via e-mail to all Qwest participants. AT&T clarified that the AT&T Proprietary Statement was not applicable and AT&T would send and e-mail stating such. AT&T reviewed page 2 of their presentation and indicated that bullet number 6 is where the issue resides. Qwest provided the following comments: ? Bullet 3- ALI processed into Intrado and next day file received. ? Bullet 4 & 5 – These bullets are strictly on ANI failures and PSAPs have been aware of this since the inception of 911. ? Bullet 6 – This issue is understood due to the memory constraints and is also understood by the PSAP community. Qwest further explained that the issue in Bullet 6 can’t happen within a few days and that there are memory constraints in the in the DMS100. There was discussion on Nortel upgrades – the ENS 005 for 911 provides all the features and ENS004 would accommodate 32mm records. The original switch feature only allowed 300,000 records in the table, which set the standards for default entries on NPA-NXX. The current switch capability has 800,000 records. Qwest explained that any upgrade would be like doing an office upgrade, which is time consuming and presents an inherent risk to break existing things that are in place. This would be communities that come in on the same trunk group which are tied to different NPA NXXs. For these communities, an ANI failure would pick the larger PSAP and this would show on the screen. Qwest didn’t know if these communities fell within the Denver area. AT&T indicated that they didn’t believe Arapahoe County is aware of this and then what would the solution be. Qwest indicated that all default routing goes to 1 PSAP and a check that was made indicated that the dBase hadn’t been updated. AT&T questioned whether this was ANI failures or what. Qwest advised that this was complete defaults where no record was found and when there was a check with the dBase folks the records were not in the dBase. AT&T questioned that calls went to Arapahoe for anywhere in the Denver Rate Center because the NPA NXX was pointed to Arapahoe, but could have gone anywhere based on the assigned wild card. Qwest indicated that they could validate if the NPA NXX is correct. Qwest asked if the problem was prevalent due to AT&T’s change in testing procedure. Qwest indicated that they were aware that AT&T has multiple NPA NXXs. AT&T asked to get a listing of the Wild Cards used by Qwest. Qwest indicated that on moves with LNP there is a current record and the customer would be miss routed until the record gets updated. AT&T advised that the LERG has all of their NXX codes. Qwest clarified that change in its standard use of the wild card would use up memory, have timing constraints, be costly and would have follow-on impact with existing customers. AT&T asked how there would be a breaking and fixing of the communities that come in from one trunk. Qwest explained that when the community was added, they told us which PSAP the call would go to (i.e. 999 goes to PSAP A, 998 goes to PSAP B and 997 goes to PSAP C). This would be set in the system with its default. Any orders for selective routing are set to the 7 digit if there is a wild card with the same NXX. AT&T indicated that they would not put in any record and the new design would have separate trunk groups and not have the wild card. Qwest explained that with a default ESN to the NXX and you ripped out the NXX would act in the same manner. With a trunk in for 998 PSAP B and you pulled the wild card out the call would have gone to PSAP B. If the number borders 998 and 997, the entry would still show PSAP C. AT&T asked how the system gets built. Qwest explained that it boils down to the state and whether they build per trunk groups or number of lines. It was explained that the PSAP builds to the number of trunks and look at the concentration. In Colorado you are required to build to the number of records, which depend on the number of trunks and switch capacity. Qwest asked how AT&T builds its system. AT&T explained that they monitor to P.01 grade of service and augment/add as required. AT&T stated that Arapahoe is asking to add 6 trunk groups. AT&T feels they are asking for something that can be done in another way. Qwest explained the concentration factor as follows: With 6 communities A – F 3 trunks each for 911 going to the Selective Router would mean a total of 18 trunks. If a PSAP only has 8 trunks they would have to look at the potential volume of calls that could come in from the 18 trunks knowing they can only handle 8. AT&T asked if there were any other issue with eliminating wild cards. Qwest explained that the use of wild cards saves memory. Eliminating wild card could adversely impact others. There would be a ripple effect – Qwest would need a new contract with Intrado. AT&T indicated that the Selective Router has a data field. Qwest indicated that the Selective Router dBase is linked to Intrado. AT&T questioned if the Intrado dBase – data field could look for the information. Qwest advised that if the wild cards are removed, Intrado would have to put it in the table. Intrado would have to do a reload with the entry for the wild card. Denver has approximately 3 mm customers that would have to be reloaded – this would mean down time. Further the switch is in a tandem arrangement which duplicates the effort. AT&T asked if there was any way of arriving at what the situation would be for doing Cap Hill and Broomfield. Qwest indicated that it would come down to time, money and risk. Risk would be the human factor, we really don’t know what they are receiving on a trunk group, etc. Qwest explained that Cap Hill was initially 20 tapes and 10 days brand new. We now have 2 switches. Qwest explained that the dual tandem switch was installed for disaster recover purposes. The tandem switch could not be used as a back-up and both switches would need to be done in parallel. AT&T asked if Qwest could quantify the effort. Qwest identified they would have their costs, Nortel costs and Intrado costs. Qwest couldn’t commit to having quantifiable costs. Qwest asked if AT&T’s dBase has been updated. AT&T indicated that they had an updated report. Qwest advised that they would evaluate the options.

Action Items AT&T is to provide Qwest with their NXXs. Qwest to provide AT&T a list of their wild cards. Qwest to report back to AT&T with a preliminary plan for responding. Qwest will obtain information on how many misrouted calls have been reported by the PSAP, Arapahoe County.

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1:30 p.m. (MDT) / Tuesday 05th February 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC013102-1 "DMS100 SR/ALI"

Ervin Rea, AT&T Donna Osborn-Miller, AT&T Jonathan Spangler, AT&T Jim Kaster, Qwest Phil Linse, Qwest Christine Quinn-Struck, 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} Description: AT&T has been officially served by Arapahoe County Colorado that current 911 default routing is inadequate. Current 911 call routing for some jurisdictions that define designated serving areas for service providers, is not routed using the ALI database, but is routed via selective router in the DMS 100 switches. If no number is found, then routing should be done by utilizing information associated with the incoming trunk group of the service provider. Current routing methods can, in some cases, route calls to the wrong PSAP, requiring the call to be re-routed to the correct PSAP, resulting in a loss of time in a possible life threatening situation. This issue impacts all CLEC's providing business or residential service.

Expected Deliverables: DMS100 switches to be modified to ensure that the switch is routing calls according to the ALI database and not the selective router. Should a number not be located in the ALI database the routing should utilize information associated with incoming trunks.

1) Urban Ray reviewed the CR. Requested that "modified" be changed to "programmed" in the "Expected Deliverables" text. Basically, AT&T indicated that outside county "911" calls are being misdirected to Arapahoe County, CO. AT&T’s position is that programming of the router (Nortel DMS100) is required to correctly route using the Automatic Line Identification (ALI) database to the appropriate Public Service Access Provider (PSAP) (i.e., Arapahoe County). 2) Previous AT&T communications with Qwest were identified. Urban Ray, AT&T agreed to forward correspondences to the CRPM. 3) Qwest asked for a listing of any phone numbers that were misdirected to the Arapahoe County PSAP, if available, for Qwest investigation. Urban Ray, AT&T indicated he may speak with Arapahoe County in the near future and will request the listing. 4) Jonathan Spangler, AT&T asked if Qwest could respond to the CR in the February 20, 2002 Monthly Product & Process CMP Meeting. The CRPM indicated that due to the short timeframe, Qwest could give a status update & review the CR with the CLEC community.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} Confirmed.

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 & AT&T 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 February 2002 Monthly P&P CMP Meeting, Qwest will solicit input from CLEC community.

CenturyLink Response

Donna Osborne-Miller and Ervin Rea LSAM Managers AT&T

SUBJECT: Qwest’s Change Request Response - CR #PC013102-1 DMS100 SR/ALI

This letter is in response to AT&T’s Change Request PC013102-1 requesting Qwest to modify its DMS100 switches to ensure that the switch is routing calls according to the ALI database and not the selective router. Further, if a number cannot be located in the ALI database, AT&T is requesting that the routing utilize information associated with incoming trunks, as one possible solution supported by the manufacturer.

On March 21, 2002, Qwest and AT&T held a meeting with the Colorado Public Utilities Commission (PUC) Staff. In the meeting, the issue of timely ALI database updates was discussed and it was agreed that timely updates would reduce default routing occurrences. It was agreed that the parties would hold off on pursuing default routing by trunk group ESN until a meeting could be held with the PUC and other industry stakeholders. The parties also agreed to participate in the appropriate Industry Forum on Global Dynamic Updates. In addition a meeting is to be scheduled by the PUC Staff with Arapahoe PSAP, Qwest and AT&T to review specific issues and discuss how the parties can address the Arapahoe PSAP’s concerns.

After the meeting Qwest and AT&T agreed that the CR should be placed in a hold status while the aforementioned issues are addressed.

At April 17, 2002 CMP Monthly Meeting it was agreed that the CR would be status as Development until further direction is agreed to.

Sincerely,

Richard H Martin Change Request Project Manager

Open Product/Process CR PC020802-1 Detail

Description Of Change

Modification:

Revised Category reference from "013" to "011"

Status History

Project Meetings

AT&T agreed to close this Change Request

Subject: Clarification Response to Questions from 4/26/02 CLEC Conference Call Date: Tue, 25 Jun 2002 09:06:57 -0600 From: Richard Martin Organization: Qwest Communications International, Inc. To: Kathy Stichter , wdmarkert CC: Alan Zimmerman , "Pardee, Carla"

Kathy/Bill,

Based on our conference call, Monday June 17, 2002, the following clarifications were made to the previous questions asked and anwered from our 4/26/02 CLEC Conference Call to review System Fixes Implemented Pursuant to Third Party Tests on DUF Transmission:

Meeting Minute item 3.2 - The original question had to do with why access records appear on the DUF with zero's in the CIC. The original answer discussed Feature Group A usage. There is one more circumstance when an access record would show a CIC of zero's. That has to do with 110125 records in the Central region when Qwest is the underlying provider of the 8XX service.

Those records currently go out with a zero CIC as well.

Meeting Minute item 3.3 - It was confirmed that Eschelon will be getting two separate files for Meet Point Billing and DUF. The type of file and mehtod of transmission will depend on the agreements made between Eschelon and Qwest.

To: wdmarkert@eschelon.com, Richard H Martin/Mass/USWEST/US@USWEST cc:

Subject: 0000's in the CIC

Hello; Yesterday I mentioned that I thought that the issue of CICs being 0000 in the 110125 access records was limited to the Central region. I have since confirmed that this is correct. Central is the only region where this occurs. As discussed in our call yesterday, this is usage that was carried by Qwest, so we would be the billable carrier. This should be the only FG-D usage you see with 0000 in the CIC field.

Have a good day!

Alan Zimmerman Qwest Wholesale Billing Manager (303)896-8346

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CLEC Conference Call

April 26, 2002 10:00 am (MDT) Conference Call TEL: 877-564-8688 CODE: 8973036 System Fixes Implemented Pursuant to Third Party Tests on DUF Transmission (Product/Process CR PC020802-1)

Attendees: Ric Martin, Qwest Wendy Thurnau, Qwest Brad Wickes, Qwest Alan Zimmerman, Qwest Carla Pardee, AT&T Jonathan Spangler, AT&T Kathy Stichter, Eschelon Bill Markert, Eschelon Jack Mungia, Eschelon Deb Hoffman, US Link

Introduction of Attendees Introduction of the participants on the Conference Call was made. Ric Martin explained that the call was a result of an Action Item from March’s CMP Monthly Meeting under Change Request PC020802-1. Details on the CR can be viewed in the CLEC Change Request – Product/Process Interactive Report located at the following URL: http://www.qwest.com/wholesale/cmp/changerequest.html This call will discuss the system fixes that were implemented by Qwest to become compliant with third party tests on the transmission of DUF Records and provide an update on the Central Regions compliance. Ric Martin requested that all CLEC participants send their e-mail address for receipt of meeting minutes.

Review of System Fixes Alan Zimmerman explained the 3rd Party Testing of the DUF conducted by KPMG Consulting and Cap Gemini, Ernst & Young (CGE&Y). The tests involved thousands of calls, and about 43 different call types. Both KPMG and CGE&Y have now concluded that Qwest’s DUF does adequately reflect usage made from Resale and UNE lines. To get to this successful conclusion, Qwest had to make several system changes, as detailed in KPMG’s Exceptions 3036, 3037, 3113 and 3098, as well as CGE&Y IWO 2129. Alan explained that these system changes are generally grouped into two categories: Pending Order File implementations and specific Local Measured Service issues, with a few additional fixes for specific other circumstances. Alan described the fixes and fix dates from those KPMG Exceptions, and answered questions from Eschelon and AT&T. The major fixes discussed included: Pending Order File Process --The pending order file (POF) Process was installed September 13th to more precisely handle usage made within a few days of customer conversion between local service providers. --The Western region had some inconsistencies in the way local measured service usage made on conversion day was handled. This was fixed Nov. 22. --8XX usage did not go to POF process in Western region until Nov 12. Central region had some specific circumstances where 8XX usage delayed in the POF process could be dropped. These circumstances were fixed November 20. --There were timing issues with POF processing in Central such that conversions done via a C order posted on a Thursday or Friday could have some of the usage released from POF for processing before all toll guides and databases were updated. This was fixed Feb. 7th. Local Measured Service (LMS) Records --Central & Eastern had problems that caused a very small percent of Local Measured Svc usage to error. These were fixed in December 2001. --Sent Paid LMS calls that were operator assisted were not properly sent on the DUF in the Western region. This was fixed Nov 22. --Central region LMS calls that originated from a UNE and billed to a resold line did not get a DUF record passed to the reseller until Dec 17. Additional Fixes --WATS attempts that originated from UNEs and did not complete did not have a DUF record generated for the Central region until Feb 18th. --Toll calls that intraLATA calls originated from a coin phone, were sent paid (not alternately billed), were carried by Qwest, and terminated to a UNE account did not have access records generated on the DUF until March 28th. --The Eastern region had a problem that resulted in duplicate records being generated to the DUF when an operator handled LMS call was made. This duplicate record condition was fixed 2/04.

Questions Raised During Discussion AT&T asked what products were covered and Qwest confirmed UNE-P and Resale. Eschelon asked what 0 meant and Qwest replied that if it comes from Qwest and it is a 0, bill Qwest. Qwest was requested to advise what condition access calls show up with a kick of 5123 versus 0 in all 3 regions. Eschelon asked what the meet point billing is on the same DUF. Qwest to provide response.

Closing Ric Martin advised that meeting minutes would be issued to the CLEC participants for review before posting to the CLEC community. Also responses to the Qwest action items would be issued to the all CLEC participants.

Subject: FW: CR PC020802-1 - Clarification Date: Thu, 14 Mar 2002 12:00:18 -0500 From: "Pardee, Carla D, NCAM" To: CC: "Hayes, Robert W (Bob), NCAM"

Ric:

AT&T has been discussing this CR (asking for correct and accurate transmission of DUF records) internally. AT&T would like to know the scope of the problem that was fixed. Did this fix correct only billing systems for UNE-P, or did this DUf transmission problem extend to meet point billing records as well? Does this fix have anything to do with the recent notification about the UNE-P records credits? We would like to set up another meeting to discuss this, or, if it is appropriate to discuss it in the CMP meeting next week, we are amenable to that as well. Let me know what works best for you. Thank you.

ps - I don't have Allan Zimmerman's correct e-mail address, if you wouldn't mind forwarding this to him also. Thank you.

Carla Dickinson Pardee Manager - LSAM (303) 298-6101

Revised (2/24/02) CLEC Change Request Clarification Meeting

2:30 p.m. (MDT) / Friday February 15, 2002 Conference Call TEL: 877-564-8688 CODE: 8973036 PC020802-1, Correct and Accurate Transmission of ADUF, DUF Records

Attendees: Carla Pardee, AT&T Richard Martin, Qwest Lynn Stecklein, Qwest Peggy Esquibel-Reed, Qwest Alan Zimmerman, Qwest Mark Pomeroy, Qwest Doug Warren, Qwest

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 Carla advised that the 013 DUF was to transmit Access records. She indicated that the ADUF records were not being transmitted correctly for UNE-P. She indicated that AT&T didn’t believe they were getting all DUF records and subsequently couldn’t bill their IXCs. Carla indicated that she thought that this was something the ROC was monitoring. Alan advised that the test were in the 3036 ROC Test. Alan further stated that the tests indicated that the Eastern and Western regions were 100% compliant. He indicated that the Central region is having issues with access of records received within a couple of days from a Change Order. Carla asked if there was any documentation on this. Alan advised that the documentation is on the WEB under Exception 3036. Alan explained that there is no Category 013, it is 011 for UNEs. Ric explained that there was a Systems Change to split the ADUF and ODUF records

Confirm Areas & Products Impacted It was confirmed that AT&T was interested in the product covered under Cat 011, which is Switched Access. . Confirm Right Personnel Involved It was confirmed that this is a Product/Process CR and Alan Zimmerman is the appropriate SME.

Identify/Confirm CLEC’s Expectation It was confirmed that AT&T wants confirmation that the Central Region is in compliance with providing 100% of the records.

Identify any Dependent Systems Change Requests It was confirmed that there is a System CR to break out Category 010 from 011.

Establish Action Plan (Resolution Time Frame) Qwest will report back on Central compliance progress by March’s CMP meeting

CenturyLink Response

Carla Pardee LSAM Manager AT&T

SUBJECT: Qwest’s Change Request Response - CR #PC020802-1 Correct and Accurate Transmission of ADUF or Category 011 DUF Records

This letter is in response to AT&T’s Change Request PC020802-1 requesting accurate and correct transmission of access DUF records (category 011 or ADUF).

During the February 15, 2002 Clarification Meeting, Qwest advised that the 3036 ROC Tests indicated Qwest’s Western and Eastern Regions were 100% compliant with issuance of DUF records. Qwest’s Central Region was still under testing by KPMG.

On Wednesday, KPMG officially closed the last issues associated with the DUF test for the 13 state ROC test area. These last issues had to do with correct population of Indicator 4 and the matches of calls made to DUF records passed in the Central region. KPMG found no records with incorrect Indicator 4 values, and found about 96% of the calls expected on the DUF. KPMG has now sent us the calls that comprise the four- percent of expected calls that KPMG did not find. Qwest will investigate these messages to see if any problems are found. Historically, however, there have been several percent of KPMG's expected calls that did not generate AMA records, did not complete a billable call, did not in fact belong to a wholesale account, or were passed on the DUF but were missed by KPMG. So Qwest expects to be able to explain essentially all the KPMG calls with these valid reasons. That analysis has just begun.

Qwest will provide the results of the analysis when they become available.

Sincerely,

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

Cc: Susan Burson

Open Product/Process CR PC030802-1 Detail

Description Of Change

- Caller must be a Qwest retail customer

- Customer must call business office and say they wish to "remove the freeze off of their local service"

- Do not instruct the customer to use the word "PIC". This is used for inter and intra lata services and causes confusion which can delay removing the LEFV

- CLEC can be a third party on the call to Qwest by the local customer

- Customer can call up to 7pm in his local service area to remove the freeze

- The LEFV resides in a repository that is worked overnight which means it will be removed off the customer's account that night and the LSR can be sent the next day without rejection

- Although updates to a CSR can take up 3-5 days, the removal of the freeze is not dependent on that CSR being updated.

- Qwest does not charge $5 to remove the freeze

- A Communicator will be sent to the CLEC community when the PCAT is updated

The last 2 bullet points can be removed from the CR as per clarification call 03/18/02

Scope expanded to include business accounts as well (per CLEC request 03/20/20)

Status History

Project Meetings

Documentation and disposition of AT&T CR PC 03802-1 – Local Service Freeze

As you know, I submitted this CR and requested application of the CMP “Exception Process”. I then escalated the issue based on discussions with Qwest. It’s a strange dichotomy for Qwest to state at the CMP Product and Process meeting that AT&T had five business days to respond to Qwest’s binding response to AT&T’s escalation of PC 030802-1 and then infer it was at Qwest’s own discretion whether to even document AT&T’s comments let alone where. At a minimum, the correspondence generated as part of the escalation should be included with the documentation of the CR, just as all other correspondence and minutes relating to CRs are documented. Since Qwest indicated in its binding response to AT&T’s escalation that Qwest would continue “to do problem solving working sessions with AT&T”, I don’t understand why my request to move the escalated change request to a ”Development” status was denied. AT&T understood the main purpose of escalating a change request was to ensure it received top priority based on business needs, not to house it in the dead-end file once Qwest provides its binding response. Qwest was clearly not prepared to present the binding response at the CMP meeting. No copies were provided to the CLEC community at the meeting and Sue Burson appeared unsettled by the request to present the binding response and respond to questions. While I have provided detailed written comments on Qwest’s binding response, AT&T has not rejected it. The areas addressed by Qwest’s response may satisfy most of AT&T’s needs, however, it is not clear from Qwest’s response that the problems AT&T has been experiencing have actually been resolved. AT&T expects that Qwest will work collaboratively with AT&T to resolve these issues. We are extremely disappointed that Qwest chose to then send out the local service freeze notice as a Level 1 notification (Announcement Date: April 18, 200; Document Number: PROS.04.18.02.F.00426.LocalServFreeze) . Judy, you had articulately explained the five levels of Qwest-initiated product/process changes in the morning portion of the April 17th meeting. Yet, the notice was sent on April 18th as a Level 1 instead of the Level 3 AT&T had strongly recommended in our written and oral responses on April 17th. We have repeatedly indicated to Qwest the local service freeze has had a daily negative impact on our ability to meet the end customers’ requests for a change in local service provider. For Qwest to indicate at this juncture of the change request that no comment cycle is available to the CLEC community shows a true disregard for the redesigned CMP, to the commitment made by the entire CMP re-design team since its work began in July 2001 and to Qwest’s commitment in its binding response “to do problem solving working sessions with AT&T.”

04/10/02 - AT&T comments on Qwest's draft response

1. Caller must be a Qwest retail customer This is a true statement. The Qwest Retail end user may contact their Qwest Retail business office to have their local service freeze removed. Their new CLEC may be on the phone with them at the same time (Three-way call).

AT&T - AT&T should be able to call the retail office without having the customer on line, this would eliminate the unnecessary time it takes to reach the customer. (Portland Metro Market – AT&T Broadband)

2. Customer must call business office and say they wish to "remove the freeze off of their local service" This is a true statement. When the end user customer contacts the Qwest Retail business office, they should ask to have their local service freeze removed. If the end user customer simply states that they are moving to AT&T, there may be some confusion as to whether this is a PIC change or the customer is moving their local service to AT&T.

AT&T - Does the retail office see the pending order to port to the CLEC? End users are being told their Qwest number(s) are disconnected and therefore Qwest cannot remove the LEFV. Perhaps they are confusing the "pending" disconnect. Notation on the Qwest side is very poor. Customers are given information such as their number is disconnected, but when they call back again, there is no note of the information they were given or even that they called in earlier. (Denver Metro Market - AT&T Broadband) AT&T believes the Qwest Retail business office is not the best arm of Qwest to be responsible for removing the LEFV. Sales’ organizations are based on revenue generating actions. They should not be responsible for lifting the LEFV when this clearly indicates a loss of revenue when the end customer moves to another competing CLEC for their local service. We believe this accounts for the lack of notations on the customer’s account after he has called nine times to remove the LEFV. (Terry Bahner - LSAM)

3. Do not instruct the customer to use the word "PIC". This is used for inter and intraLATA services and causes confusion which can delay removing the LEFV This is true. It is helpful in guiding the end user customer through the process since they may have a PIC, LPIC, and Local Service Freeze. The Sales Consultants have been provided training and job aids to help determine the customer’s need.

AT&T - Again, Qwest’s notation is very poor. The notes need to indicate what "type" of freeze the customer wishes to remove. The customer will use the word "LOCAL" and the Qwest notes will indicate "PIC". This is still a training issue on the Qwest side. The "R" order number should be noted so both sides of Qwest’s offices have access to this information. (Denver Metro Market - AT&T Broadband) AT&T believes the lack of notation or the wrong notation on the customer’s account and the multiple times the end customer has to call Qwest to lift the LEFV is indicative of a failed process and a serious training deficit. (Terry Bahner - LSAM)

4. CLEC can be a third party on the call to Qwest by the local customer See question #1

AT&T - AT&T believes Qwest needs to send out additional internal memos to drive home this statement. (Terry Bahner - LSAM)

5. Customer can call up to 7pm in his local service area to remove the freeze Qwest has customers across three different time zones. The Residence end user customer may call their Qwest Retail business office until the close of business in the Pacific time zone. - Central time zone until 9:00 PM (they will be routed to a center in the Mountain or Pacific time zones after 7:00 PM local time) - Mountain time zone until 8:00 PM (they will be routed to a center in the Pacific time zone after 7:00 PM local time) - Pacific time zone until 7:00 PM The hours for the Business, Federal Government, Education, Public Access Lines business offices are listed in the April 3, 2002 update to the PCAT.

AT&T - The window of opportunity to reach the retail office should be extended to include Saturdays. (Portland Metro Market - AT&T Broadband) Prime selling hours are until 9pm. The 7pm time could prevent us from closing the sale if the customer has a freeze on. It is not enough to rationalize that the customer can always call back later to remove the freeze. Sales organizations know that any obstacle thrown in the way of completing the sale at the time of offering the sale diminishes the chances of completing the sale. This places Qwest at an unfair competitive advantage. (Salt Lake Metro Market - AT&T Broadband) AT&T requests expanded hours to include Saturdays. (Denver Metro Market - AT&T Broadband) AT&T believes that Qwest for the time being should at least match their hours of removing the LEFV to the Monday-Saturday schedule already in existence. A second option would be for the CSIE to field the calls and note the customer’s account. (Terry Bahner - LSAM)

6. The LEFV resides in a repository that is worked overnight which means it will be removed off the customer service record. Qwest has a Local Freeze Repository where all frozen phone numbers are stored. That repository is updated on a daily basis as orders are issued to add or remove local freeze. When an order is issued to remove the freeze, the telephone number is removed from the Repository that night. The LEFV will not be removed from the CSR for 3-5 days. See further explanation in response to question 7.

AT&T - If the "R" order number is supplied in the remarks field...why cannot this be done manually and resubmitted the same day? See # 7’s explanation that SDC’s are already checking for system notations and if there is a notation, they will process the LSR. If Qwest does include Saturday hours but not same day supps, what day would the number update in the repository? (Denver Metro Market - AT&T Broadband)

7. Although updates to a CSR can take up 3-5 days, the removal of the freeze is not dependent on the CSR being updated. The Customer Service Record does not update for 3-5 days after the R order is issued to add or remove the Local Service Freeze. When a LSR is issued and there is LEFV on the CSR, the Wholesale Service Delivery Coordinators are checking system notations to determine if an order has been issued to remove the local service freeze. If there is a notation, they will process the LSR. In addition, if the LSR contains the R order number (of the freeze removal) the SDC will allow the order to be processed.

AT&T - The centers should be able to send the LSR immediately after calling the retail office to remove the freeze. Waiting 24hrs to submit is unacceptable unless Qwest is willing to reduce the 3-business day port rule. (This point was made my Jonathan Wolf on last week’s call. (Portland Metro Market - AT&T Broadband) However, the LSR will be rejected if submitted the same day as the LEFV removal request. This adds an additional day to the installation process. This may also require AT&T to contact the customer again to reschedule the originally promised installation date. This, in turn, could cause the original install to be missed if the customer cannot be contacted again in enough time to meet the due date. (Salt Lake Metro Market - AT&T Broadband)

The following questions were submitted by AT&T in a letter to Qwest dated 03/19/02

8. Customer required to call Qwest multiple times to remove LEFV The customer should be able to accomplish removal of the local service freeze in one call to Qwest.

AT&T - Simply remove the freeze with one call. (Portland Metro Market - AT&T Broadband) Should be able to and can are two different things. (Salt Lake Metro Market - AT&T Broadband) AT&T has provided examples where this demonstrates that it does not occur. As stated in earlier meetings with Qwest, this is one of the three process requirements that must be addressed to move the CR towards a workable process. (Terry Bahner - LSAM)

9. No established process to remove the LEFV at the Qwest retail offices Qwest has had established processes in place for local service freeze removal since March 10, 2001 when Local Service Freeze was first implemented.

AT&T - There are no established process by Qwest, until a workable process is in place a all frozen accounts should be lifted per Mike Mason’s request on the last two calls. (Portland Metro Market - AT&T Broadband) It’s apparent these "established processes" are broken. (Denver Metro Market - AT&T Broadband) AT&T has repeatedly indicated the process is not consistent. This has been demonstrated to Qwest by examples that range from Qwest refusing to help the end customer when AT&T Broadband is on the call to actually adding the LEFV and issuing a "D" order to disconnect the customers service instead of the "R" order. (Terry Bahner - LSAM)

10. No consistent confirmation number provided by the Qwest retail offices to note customer account Qwest Sales Consultants are currently providing the R order number to any end user customer or CLEC (on 3-way call) who requests it. We have determined that a specific work group has been providing "confirmation numbers" instead of the R order numbers. That situation has been corrected by the issuance of internal memo (MCC) and managing the performances of the involved individuals. Do not hesitate to request the R order that is being issued to remove the freeze.

AT&T - AT&T believes Qwest needs to continue to monitor how the LEFV is noted on the customer’s account by the Qwest representative. Although AT&T acknowledges and appreciates Qwest identifying a specific work group who was incorrectly providing a "good" confirmation number, a problem still surfaced after the MCC was sent. Once again we reference when Qwest issued either a "D" order or a "C" order for removing the LEFV. (Terry Bahner - LSAM)

11. Inconsistent information between the account team and the PCAT pertaining to submission of the LSR The PCAT is the Qwest official source for CLEC information.

AT&T - AT&T believes Qwest subject matter experts did provide inconsistent information to the service managers. It placed them in a precarious position by having to always "go to the SPOC" for every issue concerning the LEFV. This caused delays in developing a working process and delays in the status of the examples provided. It created a unnecessary extra layer in resolving outstanding LEFV issues. (Terry Bahner - LSAM)

12. Inconsistent Quality Check process at the Sierra Vista Center Calls and orders are monitored on a regular basis to ensure quality.

AT&T - Improved communication between the retail office and Sierra Vista (Portland Metro Market - AT&T Broadband) Inconsistencies still exist. (Denver Metro Market - AT&T Broadband) If this is true, why is Qwest saying they can cancel an LSR related to an LEFV issue? If this is true, why are some orders rejected and others are issued a jeopardy condition after the FOC? (Terry Bahner - LSAM)

13. Inconsistent escalation process at the Denver CSIE once confirmation has been received There are several determining factors as to how the escalation is handled. Each escalation is reacted to on an individual case basis.

AT&T - A single point of contact for escalations. (Portland Metro Market - AT&T Broadband) AT&T believes this does not meet our business requirements. Our third standing request is for Qwest to provide an escalation process that addresses LEFV issues that occur out of process. AT&T should not be penalized and lose their requested due date when Qwest fails to remove the LEFV. Our customer should never be placed in jeopardy when he wishes to have another CLECS’ local service because a Qwest system or agent failed to respond properly to a LSR issue regarding LEFV. (Terry Bahner - LSAM)

14. IMA 9.0 edit pulled and no notice sent to the CLEC Qwest did not remove any IMA 9.0 edits; therefore, notification to the CLECs was not necessary. There was a non-IMA edit in place that was checking the CSRs for LEFV which was relaxed so LSRs could flow through and allow the Service Order Processors to check the Freeze Repository and edit for a freeze at that point in the process.

AT&T - Qwest has stated on numerous occasions that back end systems are not considered CLEC impacting. Therefore, these back end system edits are neither subject to a CLEC review nor a CLEC upgrade notification. AT&T believes these edits did affect our orders. We believe they changed whether a LSR was rejected up front or issued a jeopardy condition after the FOC. This alters how a CLEC responds to an LSR. AT&T has repeatedly asked how these non-IMA edits affect our orders. Qwest has not provided an answer. AT&T has reconfirmed the information provided on March 15th by the Qwest service managers that an edit did occur on March 14th, 2002. If we cannot question Qwest’s backend systems, then we will refer to it as an IMA change when we believe our orders have been impacted. (Terry Bahner - LSAM)

15. IMA 9.0 edit to be implemented at a future date without CLEC notice All planned CLEC Impacting changes to IMA are currently being presented to the CLECs for prioritization. There are no plans to implement a 9.0 edit pertaining to Local Service Freeze.

AT&T - AT&T wants Qwest to not implement any edits in any systems (IMA, non-IMA) until a workable process to remove the LEFV has been agreed upon by AT&T and the CLEC community. (Terry Bahner - LSAM)

16. Jeopardy condition codes issued after the FOC affecting CLEC due date Qwest has listened to the concerns raised by AT&T on this issue and has taken steps to fortify existing processes to alleviate this problem.

AT&T - However, since we have to wait to supp the Pon AFTER the freeze is removed, this still results in a due date push out/reschedule for the customer. (Denver Metro Market - AT&T Broadband) AT&T wants to know what these steps are. The action of issuing a jeopardy condition after the FOC drastically affects our due date. If this jeopardy condition is a result of Qwest’s inability to successfully lift the LEFV, we believe we should not lose our due date under any circumstances. (Terry Bahner - LSAM)

17. Inconsistent Qwest retail process where CLEC can be a third party on the call with end customer See question #1

18. Inconsistent process between removing the LEFV and the updating of the CSR See question #6

19. Confusing reject /jeopardy condition message issued by Qwest The reject/jeopardy message currently being used is the only existing message that fits the local service freeze situation. Requests for new reject messages go through the CMP CR process. LSRs received to change lines/accounts with a local service freeze are rejected with the error message "Features on account are not compatible with requested features". In the Customer Comments section of the Reject Notice Qwest will include the following: "Please have end user contact current local service provider to have local service freeze removed."

AT&T - According to an earlier Qwest communication, Qwest stated the error message would read "Change activity not allowed, CLEC does not own account". Is this the message if the reject is caught up front (fatal reject) as opposed to the message for a jeopardy reject after the FOC? Or has this been changed altogether? (Denver Metro Market - AT&T Broadband) AT&T believes Qwest has not adequately addressed this issue. AT&T has requested LEFV be listed as a reason for a reject/jeopardy message in the PCAT. The jeopardy matrix needs to address LEFV. (Terry Bahner - LSAM)

20. AT&T reiterated they would like all of the above bullet points validated by Qwest and the process clearly documented in the PCAT The PCAT will be updated April 3, 2002.

AT&T - Under the current circumstances, Qwest needs to provide a collaborative atmosphere in resolving LEFV issues before any future PCAT documentation takes place. (Terry Bahner - LSAM)

21. What kind of questions does Qwest ask a Retail end user customer before adding a local service freeze? Upon initial contact with the end user customer, the Qwest Sales Consultant informs the customer of the availability of the freeze as follows: "We offer free protection to ensure that your provider of local service, long distance service, and local long distance service cannot be changed unless you contact us directly. You may remove this protection from your account at any time by contacting Qwest directly with a verbal, written, or electronically signed authorization. Would you be interested in setting that up now?" If the end user customer indicates they would like a freeze established, they are transferred to a Third Party Verifier (TPV) who asks the customer for the Billing Name on the account, Billing Address, the last four digits of their Social Security Number, and their date of birth. In addition, they ask if the caller is over 18 years old and is responsible for the account, and if they have permission to place the local service freeze on each specific line of the account.

AT&T - AT&T believes Qwest needs to go beyond the statement provided. It’s apparent the end customer is unaware of the cumbersome process to remove the LEFV when he wishes to obtain local service from a different company. (Terry Bahner - LSAM)

22. What changes have been made in the Local Service Freeze Removal process since 02/18/02? The process was working well before that date. Qwest has had established processes in place for local service freeze since March 10, 2001 when Local Service Freeze was first implemented. The only changes made to the process have been made within the past two weeks as a result of this CR.

AT&T - It is very clear to AT&T that Qwest did not have a working process in place on March 10, 2001. If Qwest had a good process in place that didn’t harm both the end customer and the CLEC, this CR would have never been submitted. (Terry Bahner - LSAM)

As a general proposition, Qwest has responded in the theoretical realm to many of the questions versus saying what the actual situation is (like in #8 above, but there are many other examples in their responses). It's easy to set up a theoretical process, but that is meaningless if the practical implementation is not being accomplished effectively. (Salt Lake Metro Market - AT&T Broadband)

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04/08/02 - Draft follow-up meeting minutes sent to participating CLECs via e-mail

CLEC Change Request Follow-up Meeting 11:30 a.m. (MDT) / Thursday 4th April 2002 1-877-564-8688 ID 626-5401 # PC030802-1 Local Service Freeze - Process to remove LEFV from Qwest residential accounts

Attendees: Terry Bahner / AT&T Sharon Van Meter / AT&T Lindel Watkis / AT&T Mike Mason / AT&T Cynthia Linenberger / AT&T Rick Wolters / AT&T Johnthon Wolf / AT&T Joan Russell / AT&T Mitchell Menezes / AT&T Bonnie Johnson / Eschelon Karen Clauson / Eschelon Terry Wicks / Allegiance Leilani Hines / Worldcom Susan Travis / Worldcom Monica Avila / VarTec Telecom, Inc. Judy Schultz / Qwest Todd Mead / Qwest Harriett Berry / Qwest Pam DeLaittre / Qwest Scott Riley / Qwest Pete Budner / Qwest Carylon Brown / Qwest Sue Burson / Qwest

Introduction: - Qwest presented a brief history of the CR, (submitted 03/08/02, clarification call 03/18/02, AT&T expedite letter 03/19/02, AT&T walked-on @ CMP 03/20/02, general clarification call 03/26/02, Qwest draft response issued 04/02/02). The purpose of this call is to review Qwest’s draft response dated 04/02/02 - Note: Notification CMPR.04.01.02.F.01248.CRMeeting issued to CLECs on the 1st of April, informing them of a call on 04/04/02 for a follow up discussion on this issue. Standard P&P Redline guidelines of 5 business days for notifications to CLECs not followed due to expedited status of this CR.

Review Qwest Draft Response - Harriett Berry reviewed Qwest’s draft response dated April 2, 2002 - AT&T commented that using Aegis is currently their only option, as when they call the Qwest Business Offices they be on hold for long periods and the staff do not appear to be familiar with this process. AT&T asked that the 866-311-0222 number remain in effect. Qwest agreed that the Aegis number will remain in effect until this issue is resolved. - AT&T stated that the Qwest web site states the Local Service Freeze can be removed immediately, which has not been their experience. Qwest reiterated that it is effective the same day, but the LSR has to be submitted the next day. AT&T then asked Qwest to reduce the process time by one business day. Qwest took an action to reply to this. - AT&T stated that their desire is for Qwest to lift the Local Service Freeze so the LSR can be submitted the same day - see 2.10 - Eschelon asked if the LSR can be submitted using the R-Order number in the PON field? Qwest believed this would work. Qwest will investigate and report back. - AT&T reiterated they believe something changed on February 18th. They believe this process is broken and asked Qwest to lift the Freeze to before February 18th conditions - see 2.10 - Eschelon stated that Qwest could go to the State Commissions and seek a waiver on the Local Service Freeze. Eschelon also asked about a written process to remove the Freeze. Besides the presence of a form, Eschelon wanted to know whether there was a back end process in place to deal with this and what had been communicated to the CLECs? Qwest took an action to respond to this. - AT&T reiterated they are seeking: 1. To only have to make one call 2. To send in their LSR without rejection 3. A clear and concise escalation process 4. Have the AGIS number available on Saturday’s - AT&T also stated they continue to see large numbers of customers with the Freeze implemented, who believe they have never asked for it on their account. Qwest replied that they are continuing to investigate the AT&T examples and have already found most of the TPV’s for the AT&T examples. AT&T replied they have heard this before but have yet to receive any validation from Qwest. AT&T stated the implementation of a freeze is not clear as too many customers are not aware of this action on their account. Qwest will provide validation to Terry Bahner (AT&T) - AT&T stated they were going to escalate this CR as they expected resolution today, but believed this call had failed in its intent. AT&T want the freeze lifted and want an official response on this from Qwest in 24 hours. AT&T also offered to support an application by Qwest to the commission to get a waiver on Local Service Freeze until this issue is resolved. - AT&T also stated they believe the interim exception process has not worked for them as they had expected a response to this CR immediately.

Establish Action Plan - Qwest will respond to the above actions as soon as possible. - Qwest will either respond or provide a status update on lifting the freeze within 24 hours

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04/05/02 - Status update from Qwest on AT&T's request to immediately lift the freeze

Status Update: Per action from April 4th CLEC Meeting

All, Qwest continues to review and analyze AT&T's request made yesterday to lift the Local Service Freeze. Qwest has not arrived at its final position at this time, however executive management is deeply engaged. We will follow up with another status update prior to close of business Monday April 8th 2002.

CR details can be found in the Product & Process Interactive report. The Product & Process Interactive report can be found at: http://qwest.com/wholesale/cmp/changerequest.html

Thanks Todd Mead

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04/05/02 - Letter from AT&T expressing their disappointment with Qwest's response presented in the follow-up meeting on 04/04/02

1875 Lawrence St. Denver, CO 80202-1847

April 5, 2002

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

RE: Change Request PC 030802-1

Dear Todd:

This reconfirms AT&T’s repeated request that Qwest suspend the local service freeze until a collaborative Qwest-CLEC process can ensure an effective, efficient and prompt way to remove the LEFV with no impact to the end customer. AT&T does not believe Qwest’s draft response presented at the April 4th conference call meets our company’s immediate needs.

AT&T is disappointed that Qwest cannot recognize the impact the LEFV has on our daily LNP operations. It is very disturbing when Qwest continues to fail to bring to the table a workable solution. It is discouraging when Qwest continues to ignore our requests to engage the appropriate Qwest subject matter experts to participate in discussions with AT&T to help resolve this issue quickly. Had the appropriate operational SMEs from Qwest participated on the call yesterday, we might have made progress resolving these issues. Unfortunately, once again such individuals were absent.

AT&T’s expectations of the LEFV process is really quite simple. The end customer should be able to remove the LEFV with one call. AT&T Broadband should then be able to submit the LSR to port the customer immediately after the customer has taken the appropriate step to remove the LEFV without fear of an order rejection or a jeopardy condition being issued after the FOC. And last, if the process fails, there is a working escalation process to effectively handle the issue quickly.

Up to this point, Qwest has made minimal effort to work with AT&T to hammer out a workable solution. We view this as a dismal Qwest failure. First, it demonstrates Qwest’s inability to perform a normal function adequately. Second, it clearly shows Qwest does not acknowledge nor recognize the urgency related to the CMP exception process. Third, it demonstrates Qwest’s inability to effectively manage changes to its processes when they adversely impact CLECs.

AT&T will send to Qwest written comments embedded in Qwest’s April 2, 2002, rough draft response to change request PC 030802-1. It will also include AT&T’s proposed resolutions. In the meantime, AT&T will continue to direct the end customer to call AEGIS directly to remove the LEFV from his account. We are expecting at least a verbal response from Sue Burson by close of business today regarding AT&T’s request to suspend LEFV until a workable process can be implemented. AT&T would expect Sue to then send a written response to AT&T. Please insure the minutes from the April 4th conference call reflect AT&T has officially escalated this to Sue Burson.

Sincerely,

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

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller Judy Schultz Mike Mason

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04/02/02 - Notification PROS.04.02.02.F.00414.LocalServiceFreeze issued informing CLECs of PCAT update

Announcement Date: April 2, 2002 Effective Date: April 3, 2002 Document Number: PROS.04.02.02.F.00414.LocalServiceFreeze Notification Category: Process Notification Target Audience: CLECs, Resellers Subject: Options to Remove Local Service Freeze

Beginning April 4, 2002, Qwest will issue updates to its Wholesale Product Catalog that includes new/revised documentation for Local Service Freeze.

The Local Service Freeze PCAT will be updated to outline the options of requesting the removal of the Local Service Freeze. The PCAT also lists the information the retail end-user needs to provide to have the Local Service Freeze removed.

You will find a summary of these updates on the attached Web Change Notification Form. Actual updates are found on the Qwest Wholesale Web site at this URL: http://www.qwest.com/wholesale/clecs/lsfreeze.html

You are encouraged to provide feedback to this notice through our web site. We provide an easy to use feedback form at http://www.qwest.com/wholesale/feedback.html. A Qwest representative will contact you shortly to discuss your suggestion.

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03/28/02 - Letter from AT&T expressing their disappointment with the general clarification call held on 03/26/02

1875 Lawrence St. Denver, CO 80202-1847

March 28, 2002

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

RE: Change Request PC 030802-1

Dear Todd:

AT&T is greatly disappointed with the conference call Qwest facilitated March 26, 2002 to discuss the expedited CR PC 030802-1. Qwest stated at the March 20, 2002 Product and Process CMP monthly meeting they understood the urgency of this change request regarding the local service freeze (LEFV). There was no need for a second clarification call. A clarification call had already been held on March 18, 2002.

We believed Qwest was willing to resolve the issue expediently, Todd, when you indicated you would have your subject matter experts available on the March 26th call. I then indicated to you that I was expecting my AT&T Broadband subject matter experts to also be available to help resolve the issue in the e-mail I sent March 22, 2002 (RE: CR # 5582295 - Updated Matrix). I suggested, in order getting to immediate resolution, that you include operational subject matter experts. I was very clear about AT&T’s expectations for the March 26th conference call.

AT&T also believes Qwest implied a resolution would be forthcoming by indicating the temporary 800 telephone number was directly dependent on the outcome of the March 26th meeting. If Qwest was not ready to problem solve the issue then there should never have been a question about keeping the 800 number available. While AT&T appreciates Qwest extending the use of the 800 telephone to help ease the burden of this issue, we should not have had to explain why we needed the extended use of it.

AT&T once again reminds Qwest of the negative impact the LEFV has imposed on our ability to port a customer. It continues to affect our daily ability to port a customer who wants our local service. This truly is unacceptable to us. AT&T has identified and shared with Qwest some of the most basic obstacles in a letter sent March 18, 2002 (RE: Change Request PC 030802-1).

Since Qwest has indicated a formal response will be issued to the CLEC community on April 3rd without a collaborative effort between Qwest and the CLEC community, AT&T clearly expects Qwest to be open to additional suggestions on the follow up conference call scheduled April 4th. AT&T expects that conference call to resolve outstanding issues and the appropriate decision-making individuals from Qwest will attend.

We believe going forward explicit timelines should be provided and adhered to by Qwest for an expedited CR. It should mirror the expedited CR Qwest presented as a walk on at the same March 20 meeting. Qwest clearly defined the timeframe and expectations of the CLEC community during that presentation. It should not be any different for an expedited CLEC CR.

AT&T looks forward to partnering with Qwest and the CLEC community to enhance the Interim Exceptions Process for OSS interfaces, Product and Process Changes (RE: Qwest Re-Design Web site) in future re-design CMP sessions. We believe use of the process, as it now stands for this specific change request, clearly indicates its’ lack of substance.

Sincerely,

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

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller Judy Schultz Mike Mason

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03/27/02 - Draft general clarification meeting minutes sent to participating CLECs via e-mail

General Clarification Meeting

3:00 p.m. (MDT) / Tuesday 26th March 2002

1-877-564-8688 ID 626-5401 # PC030802-1 Local Service Freeze - Process to remove LEFV from Qwest residential accounts

Attendees: Terry Bahner / AT&T Carla Dickinson-Pardee / AT&T Sharon Van Meter / AT&T Lindel Watkis / AT&T Mike Mason / AT&T Cynthia Linenberger / AT&T Noriko Wilson / AT&T Anthony Robert / AT&T Leilani Hines / Worldcom Susan Travis / Worldcom Monica Avila / VarTec Telecom, Inc. Judy Schultz / Qwest Todd Mead / Qwest Harriett Berry / Qwest Pam DeLaittre / Qwest Gay Abrahamson / Qwest Joan Smith / Qwest Connie Winston / Qwest

Introduction: Qwest presented a brief history of the CR, (submitted 03/08/02, clarification call 03/18/02, AT&T expedite letter 03/19/02, AT&T walked-on @ CMP 03/20/02 and general notification to all CLECs advising them of this meeting 03/21/02) Note: Notification CMPR.03.21.02.F.01239.CRMeeting issued on 03/21/02 to CLECs informing them of a call on 03/26/02 to discuss this issue. Standard P&P Redline guidelines of 5 business days for notifications to CLECs not followed due to expedited status of this CR.

Review Description of Change: Terry Bahner read out the following from Change Request PC030802-1: VALIDATE THESE FOLLOWING BULLET ITEMS AS PART OF THE PROCESS: - Caller must be a Qwest retail customer - Customer must call business office and say they wish to "remove the freeze off of their local service" - Do not instruct the customer to use the word "PIC". This is used for inter and intra lata services and causes confusion which can delay removing the LEFV - CLEC can be a third party on the call to Qwest by the local customer - Customer can call up to 7pm in his local service area to remove the freeze - The LEFV resides in a repository that is worked overnight which means it will be removed off the customer's account that night and the LSR can be sent the next day without rejection - Although updates to a CSR can take up 3-5 days, the removal of the freeze is not dependent on that CSR being updated. - Qwest does not charge $5 to remove the freeze * - A Communicator will be sent to the CLEC community when the PCAT is updated * *Removed as per clarification meeting 03/18/02 Terry also read out additional scope as per AT&T’s expedite request (AT&T letter dated 3/19/02) - Customer required to call Qwest multiple times to remove LEFV - No established process to remove the LEFV at the Qwest retail offices - No consistent confirmation number provided by the Qwest retail offices to note customer account - Inconsistent information between the account team and the PCAT pertaining to submission of the LSR - Inconsistent Quality Check process at the Sierra Vista Center - Inconsistent escalation process at the Denver CSIE once confirmation has been received - Qwest retail office confusing end customers by referring to the LEFV as a PIC freeze (Repeated above 3rd bullet) - IMA 9.0 edit pulled and no notice sent to the CLEC - IMA 9.0 edit to be implemented at a future date without CLEC notice - Jeopardy condition codes issued after the FOC affecting CLEC due date - Inconsistent Qwest retail process where CLEC can be a third party on the call with end customer - Inconsistent process between removing the LEFV and the updating of the CSR - Confusing reject /jeopardy condition message issued by Qwest

- AT&T reiterated they would like all of the above bullet points validated by Qwest and the process clearly documented in the PCAT - AT&T confirmed they would like the CR scope expanded to include Business Accounts as per CLEC request at the March CMP meeting. Todd will adjust CR documentation. - AT&T stated that 68% of all orders for removing LEFV in the Portland region had to be rescheduled last month. AT&T are seeking clarification on what exactly is the process for removing LEFV. AT&T also asked for an extension on the 800 number until the LEFV process is clarified and documented. - Qwest reiterated that they are working as expeditiously as possible to resolve this issue, and they aim to present a written draft response to the CLECs next week. - AT&T said they are willing to wait for the written response next week but need immediate ‘relief’ now. Immediate ‘relief’ was defined by AT&T as: - Keeping the 800 number live until next week (and include Saturday availability) - Someone in CSIE to take the lead on this issue and be nominated as the Single Point of Contact (SPOC) - Qwest would confirm later in the day on the status of this request. - AT&T also stated that they believe 100% of customers they talk too, insist they never asked for the freeze to be installed. AT&T would like to know what type of validation/questions Qwest ask to believe the customer has requested this product. - AT&T also asked for clarification on the R-Number and whether the order number is sufficient as some LSRs are currently being rejected with this information. - Worldcom and VarTec Telecom expressed their continued interest in this issue. - Qwest restated that they are currently not aware of anything that was ‘backed out’ of IMA 9.0 and also reiterated that the only work currently pending for IMA is in the prioritization list for all CLECs to vote on. - AT&T stated that since February 18th 2002, this process has not been working. They requested that in light of Qwest’s inability to support the process and the fact that the freeze placed on accounts were questionable as far as customer approval to begin with. That the best and quickest way to fix this matter was to lift the freeze and go back to the way we were prior to February 18th and not go back until all the issues were properly addressed and good process was actually in place. Qwest stated that a number of States were ‘turned-up’ on Feb 18th so this may be a volume issue. AT&T believe their volume did not change on Feb 18th and asked for the freeze to be lifted until a working process is put in place by Qwest. Qwest replied they understood AT&T’s concern and reiterated they are working as fast as possible on getting an accurate and workable solution for all CLECs.

Establish Action Plan: Next Meeting: Thursday 4th April @ 11:30 am (MDT) - same bridge number as this call. Qwest will present written response. Qwest will investigate and report back to AT&T this afternoon on providing ongoing ‘relief’

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03/21/02 - Notification CMPR.03.21.02.F.01239.CRMeeting issued to CLECs informing them of a call on 03/26/02 to discuss this issue

Qwest will host a general clarification meeting on CLEC Change Request (CR) PC030802-1 (Process to remove LEFV from Qwest residential accounts) on Tuesday March 26, 2002.

Date: Tuesday, March 26, 2002 Time: 3:00 p.m. MST Conference Line: 1-877-564-8688 Passcode 626-5401 #

Details of the CR can be found in the Product/Process Interactive report at: http://qwest.com/wholesale/cmp/changerequest.html Sincerely,

Todd Mead

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03/19/02 AT&T advised Qwest they would like this CR expedited

1875 Lawrence St. Denver, CO 80202-1847

March 18, 2002

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

RE: Change Request PC 030802-1

Dear Todd:

AT&T is requesting Qwest to officially expedite PC 030802-1. The local service freeze (LEFV) is critically affecting AT&T Broadband’s ability to port customers. This LEFV has presented multiple obstacles. We are requesting to have an immediate discussion between Qwest and AT&T Broadband subject matter experts to discuss the many problems associated with LEFV. What have been identified to date are the following:

- Customer required to call Qwest multiple times to remove LEFV - No established process to remove the LEFV at the Qwest retail offices - No consistent confirmation number provided by the Qwest retail offices to note customer account - Inconsistent information between the account team and the PCAT pertaining to submission of the LSR - Inconsistent Quality Check process at the Sierra Vista Center - Inconsistent escalation process at the Denver CSIE once confirmation has been received - Qwest retail office confusing end customers by referring to the LEFV as a PIC freeze - IMA 9.0 edit pulled and no notice sent to the CLEC - IMA 9.0 edit to be implemented at a future date without CLEC notice - Jeopardy condition codes issued after the FOC affecting CLEC due date - Inconsistent Qwest retail process where CLEC can be a third party on the call with end customer - Inconsistent process between removing the LEFV and the updating of the CSR - Confusing reject /jeopardy condition message issued by Qwest

It is critical Qwest establish a team to address the customer impact and at the same time improve the processes. As I have indicated both in e-mail and on the clarification call to Qwest, this is now a high profile issue between both companies. Mike Mason, Vice-President AT&T Broadband, has escalated this to Scott Shipper, Vice-President Qwest.

AT&T’s account team has declined to work directly with AT&T to resolve this issue and has instructed AT&T to move all discussion to CMP. In addition Todd, you stated on the clarification call held March 18, 2002, Qwest would not provide a resolution to this CR until the monthly CMP forum in May. This is unacceptable to AT&T.

AT&T requests Qwest to expedite PC 030802-1 immediately. AT&T will present this CR as a "walk on". Please inform Jim Beers. Under the Interim Exception Process for OSS Interfaces, Product and Process Changes (RE: Qwest Re-Design Web site) this can be addressed at Wednesday’s monthly CMP meeting and voted on as an expedited issue by the CLEC community.

Sincerely,

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

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller Judy Schultz

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Clarification Meeting

11:00 a.m. (MDT) / Monday 18th March 2002 1-877-564-8688 ID 626-5401 # PC030802-1 Local Service Freeze – Process to remove LEFV from Qwest residential accounts

Attendees: Terry Bahner / AT&T Donna Osborne-Miller / AT&T Cynthia Linenberger / AT&T Lindel Watkis / AT&T Mike Harggert / AT&T Harriett Berry / Qwest Chris Quinn-Struck / Qwest Pete Budner / Qwest Todd Mead / Qwest

Review Requested (Description of) Change: Terry read out the change request: VALIDATE THESE FOLLOWING BULLET ITEMS AS PART OF THE PROCESS: * Caller must be a Qwest retail customer * Customer must call business office and say they wish to "remove the freeze off of their local service" * Do not instruct the customer to use the word "PIC". This is used for inter and intra lata services and causes confusion which can delay removing the LEFV * CLEC can be a third party on the call to Qwest by the local customer * Customer can call up to 7pm in his local service area to remove the freeze * The LEFV resides in a repository that is worked overnight which means it will be removed off the customer's account that night and the LSR can be sent the next day without rejection * Although updates to a CSR can take up 3-5 days, the removal of the freeze is not dependent on that CSR being updated. * Qwest does not charge $5 to remove the freeze * A Communicator will be sent to the CLEC community when the PCAT is updated

- AT&T asked for more clarification around the 6th Bullet as the updated PCAT indicated the LSR can be submitted immediately after the LEFV is removed (not the next business day). - The last two bullet points can be removed from the original CR. Todd will adjust the CR documentation. - AT&T asked for clarification around the edit that is going into IMA - AT&T asked for Qwest to explain the role and also train the duty pager on the Local Service Freeze process. AT&T have experienced significant problems with issues they have escalated to the duty pager - AT&T also asked Qwest to provide clarification on what remarks to expect in the remarks section of the jep notification re: Joan Wells

Confirm Areas & Products Impacted: Products: LNP, Private Line, Unbundled Loop & UNE Areas: Pre-ordering, Ordering & Provisioning - Billing was added

Confirm Right Personnel Involved: Harriett confirmed she is the correct person to be the Qwest SME in relation to this CR.

Identify/Confirm CLEC’s Expectation: AT&T want to see a clear and concise process around removing the Local Service Freeze, verified and documented in PCAT.

Establish Action Plan (Resolution Time Frame): General clarification – April CMP meeting. Qwest’s initial response presented at May CMP meeting. AT&T will send Change Management a letter this afternoon requesting Qwest expedite this CR. AT&T will ‘walk-on’ this CR at Wednesday’s CMP meeting.

CenturyLink Response

April 2, 2002

Terry Bahner Supervisor AT&T Local Services Access Management 1875 Lawrence St. Denver, CO 80202-1847

SUBJECT: Qwest’s Change Request Response - CR # PC 030802-1 "Local Service Freeze Removal for Residence and Business Customers"

Following are responses to your list of issues and questions from CR #PC030802-1, your additional list of issues dated March 19, as well as questions from our March 26, 2002 conference call.

1. Caller must be a Qwest retail customer This is a true statement. The Qwest Retail end user may contact their Qwest Retail business office to have their local service freeze removed. Their new CLEC may be on the phone with them at the same time (Three-way call).

2. Customer must call business office and say they wish to "remove the freeze off of their local service" This is a true statement. When the end user customer contacts the Qwest Retail business office, they should ask to have their local service freeze removed. If the end user customer simply states that they are moving to AT&T, there may be some confusion as to whether this is a PIC change or the customer is moving their local service to AT&T.

3. Do not instruct the customer to use the word "PIC". This is used for inter and intraLATA services and causes confusion which can delay removing the LEFV This is true. It is helpful in guiding the end user customer through the process since they may have a PIC, LPIC, and Local Service Freeze. The Sales Consultants have been provided training and job aids to help determine the customer’s need.

4. CLEC can be a third party on the call to Qwest by the local customer See question #1

5. Customer can call up to 7pm in his local service area to remove the freeze Qwest has customers across three different time zones.

The Residence end user customer may call their Qwest Retail business office until the close of business in the Pacific time zone.

- Central time zone until 9:00 PM (they will be routed to a center in the Mountain or Pacific time zones after 7:00 PM local time) - Mountain time zone until 8:00 PM (they will be routed to a center in the Pacific time zone after 7:00 PM local time) - Pacific time zone until 7:00 PM

The hours for the Business, Federal Government, Education, Public Access Lines business offices are listed in the April 3, 2002 update to the PCAT.

6. The LEFV resides in a repository that is worked overnight which means it will be removed off the customer service record. Qwest has a Local Freeze Repository where all frozen phone numbers are stored. That repository is updated on a daily basis as orders are issued to add or remove local freeze. When an order is issued to remove the freeze, the telephone number is removed from the Repository that night. The LEFV will not be removed from the CSR for 3-5 days.

See further explanation in response to question 7.

7. Although updates to a CSR can take up 3-5 days, the removal of the freeze is not dependent on the CSR being updated. The Customer Service Record does not update for 3-5 days after the R order is issued to add or remove the Local Service Freeze.

When a LSR is issued and there is LEFV on the CSR, the Wholesale Service Delivery Coordinators are checking system notations to determine if an order has been issued to remove the local service freeze. If there is a notation, they will process the LSR. In addition, if the LSR contains the R order number (of the freeze removal) the SDC will allow the order to be processed.

The following questions were submitted by AT&T in a letter to Qwest dated 03/19/02

8. Customer required to call Qwest multiple times to remove LEFV The customer should be able to accomplish removal of the local service freeze in one call to Qwest.

9. No established process to remove the LEFV at the Qwest retail offices Qwest has had established processes in place for local service freeze removal since March 10, 2001 when Local Service Freeze was first implemented.

10. No consistent confirmation number provided by the Qwest retail offices to note customer account Qwest Sales Consultants are currently providing the R order number to any end user customer or CLEC (on 3-way call) who requests it. We have determined that a specific work group has been providing 'confirmation numbers' instead of the R order numbers. That situation has been corrected by the issuance of internal memo (MCC) and managing the performances of the involved individuals. Do not hesitate to request the R order that is being issued to remove the freeze. 11. Inconsistent information between the account team and the PCAT pertaining to submission of the LSR The PCAT is the Qwest official source for CLEC information.

12. Inconsistent Quality Check process at the Sierra Vista Center Calls and orders are monitored on a regular basis to ensure quality.

13. Inconsistent escalation process at the Denver CSIE once confirmation has been received There are several determining factors as to how the escalation is handled. Each escalation is reacted to on an individual case basis.

14. IMA 9.0 edit pulled and no notice sent to the CLEC Qwest did not remove any IMA 9.0 edits; therefore, notification to the CLECs was not necessary. There was a non-IMA edit in place that was checking the CSRs for LEFV which was relaxed so LSRs could flow through and allow the Service Order Processors to check the Freeze Repository and edit for a freeze at that point in the process.

15. IMA 9.0 edit to be implemented at a future date without CLEC notice All planned CLEC Impacting changes to IMA are currently being presented to the CLECs for prioritization. There are no plans to implement a 9.0 edit pertaining to Local Service Freeze.

16. Jeopardy condition codes issued after the FOC affecting CLEC due date Qwest has listened to the concerns raised by AT&T on this issue and has taken steps to fortify existing processes to alleviate this problem.

17. Inconsistent Qwest retail process where CLEC can be a third party on the call with end customer See question #1

18. Inconsistent process between removing the LEFV and the updating of the CSR See question #6

19. Confusing reject /jeopardy condition message issued by Qwest The reject/jeopardy message currently being used is the only existing message that fits the local service freeze situation. Requests for new reject messages go through the CMP CR process.

LSRs received to change lines/accounts with a local service freeze are rejected with the error message "Features on account are not compatible with requested features." In the Customer Comments section of the Reject Notice Qwest will include the following: "Please have end user contact current local service provider to have local service freeze removed."

20. AT&T reiterated they would like all of the above bullet points validated by Qwest and the process clearly documented in the PCAT. The PCAT will be updated April 3, 2002. 21. What kind of questions does Qwest ask a Retail end user customer before adding a local service freeze? Upon initial contact with the end user customer, the Qwest Sales Consultant informs the customer of the availability of the freeze as follows: "We offer free protection to ensure that your provider of local service, long distance service, and local long distance service cannot be changed unless you contact us directly. You may remove this protection from your account at any time by contacting Qwest directly with a verbal, written, or electronically signed authorization. Would you be interested in setting that up now?"

If the end user customer indicates they would like a freeze established, they are transferred to a Third Party Verifier (TPV) who asks the customer for the Billing Name on the account, Billing Address, the last four digits of their Social Security Number, and their date of birth. In addition, they ask if the caller is over 18 years old and is responsible for the account, and if they have permission to place the local service freeze on each specific line of the account.

22. What changes have been made in the Local Service Freeze Removal process since 02/18/02? The process was working well before that date. Qwest has had established processes in place for local service freeze since March 10, 2001 when Local Service Freeze was first implemented. The only changes made to the process have been made within the past two weeks as a result of this CR.

Sincerely,

Harriett Berry Senior Process Analyst Qwest

Cc: Sue Burson, Director Process Management, Qwest

Open Product/Process CR PC010702-1 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

January 24, 2002

Roy Harsila Carrier Relations Manager Comm South Companies, Inc.

CC: Bill Campbell

This letter is in response to your CLEC Change Request Form, number PC010702-1 – For Qwest to develop appropriate blocking for Directory Assistance and National Directory Assistance for Resellers.

REQUEST: At this time, Comm South Companies, Inc. uses the appropriate toll restriction USOC for our blocking; however, the toll restriction does not block any types of Directory Assistance calling. Qwest provides to their customer's the product of Dial Lock, which is USOC: OC4 that blocks Directory Assistance. Qwest has stated that this product was not developed to be used by Resellers. Other RBOC's include this type of blocking in the toll restriction option. I would like to see Qwest add the Directory Assistance blocking feature in the toll restriction. At this time, Comm South Companies, Inc. is being billed thousands of dollars for Directory Assistance and then we have to bill our end users, if Qwest would add this Directory Assistance blocking functionality in their toll restriction product it would help reduce these charges.

RESPONSE: Qwest understand the problem Comm South is facing with unapproved charges being made against its network. Qwest has a product called CustomNET that will provide the National and International Directory Blocking product for Comm South. Details about this product can be found at:

http://www.qwest.com/wholesale/clecs/features/customnet.html#prod

If you have any questions or would like to purchase this product, please contact your Service Manager.

Sincerely,

Janean Van Dusen Product Manager

Open Product/Process CR PC011502-1 Detail

Description Of Change

Additional Information: Covad has experienced a significant number of cable augments with electrical faults, requiring a technician dispatch to the central office.

Status History

Project Meetings

06/18/03 June CMP Meeting Minutes Steve Nelson – Qwest reported the Dry Creek test is still pending. Qwest and Covad completed the test in Washington. They tested 200 cables, all were good, and we found 2 splitter card problems that we resolved. The joint test took 1 hour to do the test, and 1-hour travel time each way. Qwest will reduce the interval to 1 hour. Mike Zulevic-Covad advised we need to work on sharing and recording test results. Covad requested to leave in CLEC Test one more month.

05/21/03 May CMP Meeting Minutes Steve Nelson – Qwest reported he is monitoring two RFS; one for Covad and one for Cyber Mesa. There is a call scheduled today which will set up the time for the Joint Test to occur. Steve and Mike will try to attend the Joint test. Steve will advise Cindy Macy when the joint test is scheduled and completed. This CR will remain in CLEC Test.

04/16/03 April CMP Meeting PC011502-1: Joint Testing of Qwest Installed Transmission Cables

Steve Nelson – Qwest reported a total of 13 joint test results have been submitted and are pending from 3 different CLECs. None are completed as of yet so we are unable to report on the test results until they go through that phase. These requests came in with Augment orders. Steve advised Qwest will be updating the document to include improvements on the process. Steve is working with the CPMC and will get the RFS dates and call Mike Zulevic. Mike advised he would like to keep this CR open until an order has gone through the entire process. This CR will remain in CLEC Test status.

03/19/03 March CMP Meeting Steve Nelson – Qwest reported Covad has issued orders and Qwest is waiting for Covad to accept the quote. After Covad accepts the quote Steve Nelson will monitor the process to make sure the joint test goes okay. Mike Zulevic agreed to check and see why Covad has not accepted the quote as of yet. Steve Nelson agreed to call Mike with BAN numbers.

02/19/03 Steve Nelson-Qwest and Mike Zulevic-Covad advised they have updated the Interconnection Agreement and Covad has placed augment orders. We are now waiting for the orders to go through the entire process which normally has a 45-60 day interval to complete. After the orders go through the entire process we will determine a close date.

01/15/03 January CMP Meeting

White-Qwest described the CR. Zulevic-Covad stated that Qwest and Covad were in the process of amending Covad’s interconnection agreement and that when that was complete Covad would begin placing orders. This CR remains in CLEC Test.

12/18/02 December CMP Monthly Meeting Minutes Qwest - Nelson advised the PCAT was published and no comments were received. Nelson reported he is working with Covad to clarify how to order the product. Section M of the Collocation Order Form and the Joint Testing at ICDF Form is used for ordering. Covad advised an amendment to their Interconnect Agreement will be issued to modify the increments. The team agreed another CR would need to be issued and handled as a Level 2. This CR will be left in CLEC Test until an order is placed for the product or until the team determines otherwise.

11/20/02 November CMP Monthly Meeting Minutes Qwest (Steve Nelson) reported the PCAT was updated and posted for review with the comment cycle ending 11-21. It was agred to move this CR to CLEC Test.

10/18/02 October CMP Monthly Meeting Minutes Qwest reported the process document for the Test Access Points is under review and anticipated to be available for review effective October 18, 2002. The Qwest documentation review team surfaced an issue after the CMP meeting that is currently under investigation. This issue will impact the October 18 availability date. The document will remain in review and this project will remain in Development status.

09/18/02 September CMP Monthly Meeting Minutes

Qwest advised that documentation on the Joint Test Process should be published by the end of next week. Comments from the last collaborative review meeting are being incorporated into the document and the Collo Application form is being updated. The CR will remain in Development

-

08/21/02 August CMP Monthly Meeting Minutes

Qwest provided a status update on issuance of the Initial Notification. They indicated that the process with being revised to incorporate the CLECs request to have Qwest contact the CLEC to notify when they are ready and that there would be no additional QPF. Covad advised that they had a conversation with the Collocation Product Manager and he provided the same update.

-

07/17/02 - July CMP Meeting Minutes: Qwest stated a meeting was held July 11, 2002 to discuss the proposed product offering. Qwest stated another meeting is planned for the first week of August with the CLECs to discuss proposed resolutions to the questions raised during the July 11 meeting. Qwest will issue a notice to the CLEC community containing proposed dates for the meeting.

CLEC conference call held to review the ICDF Joint Testing product offering and the Test Access Points document

10:00 a.m. (CST) / Thursday, July 11, 2002 Conference Call TEL: 877.521.8687 CODE: 5699655 PC011502-1 Joint testing of Qwest installed transmission cables

Attendees Brent Debrock Cbeyond Communications Al Villiam Allegiance Steve Marks Allegiance David Stauter Allegiance Mike Zoulvik Covad Beckey Neesen Covad Byron Dowing Alltel Laurel Burke Qwest Jerry Bocke Eschelon Lana Messenger FreeTel Communication Mike Keegan Qwest Benjamin Campbell Qwest Johnathan Spangler AT&T

Introduction of the participants on the Conference Call was made. Qwest explained that the purpose of the call was to review the IDCF Joint Testing product offering and the Test Access Points document.

Qwest discussed the new process offering of Joint Testing, and the Test Access Points Document. The CLEC community expressed that they want: 1) Qwest to take an active role in the test process during Joint Test 2) CLECs do not want to pay for the Joint Test if there are errors found in the Qwest installed Cable.

Qwest stated it would explore these two requests to see if they can be incorporated into the new product offering. Based upon this new feedback, Qwest will delay delivery of the Joint Test Process until resolution on these additions have been resolved. Qwest stated that it would set up another meeting to review the Joint Test Process once a decision is made on their request.

Qwest asked Eschelon if the Test Access Points Document provided the detail requested by Eschelon at the June 19, 2002 CMP meeting (reference Action Item AI041702-1 "Prepare high level documented process of what CLECs are allowed to do in Qwest Central Offices". Eschelon replied the document has not yet been reviewed.

CLEC Change Request Clarification Meeting

12:30 p.m. (MDT) / Wednesday 23 January 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC011502-1 “Joint Testing of Qwest Installed Transmission Cables”

Attendees: Michael Zulevic, Covad Jeffery B. Cook, Qwest Richard Martin, Qwest Peter Wirth, Qwest

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 Mike indicated that he recognized that at the time the tie cables are placed, they do not do an actual test when the tie cables are terminated to the equipment. They were looking to be able to do continuity tests, etc before they terminated to the equipment and wanted a period of time for them to do their test and acceptance. Jeff asked why Covad wanted to test DS1 & 3 cables. Mike advised that they wanted to ensure that installation was correct. It was agreed that Covad didn’t want to limit the scope to the cables at the colo splitter arrangement and wanted to cover actual installation(s) at their colo location. Mike confirmed that they were looking for a formal test and turnover process and wanted an acceptance period after actual installation of the facility took place. This would be a joint testing process. Mike indicated that he would be willing to have discussion on the interval time of 60 days. Covad is limited to the number of techs that cover various states and a reasonable time would be required for their techs to get from place to place.

Confirm Areas & Products Impacted It was confirmed that Covad would like any products covered to be included in the process. . Confirm Right Personnel Involved Jeff indicated that Laurel Burke would probably take ownership of the CR and he would help facilitate.

Identify/Confirm CLEC’s Expectation It was confirmed that Covad is looking for a process for Test and Turnover of facility installations to their collocations.

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

Establish Action Plan (Resolution Time Frame) Ric advised that the CR would be clarified with the CLEC Community at the next CMP Meeting and Qwest will verbally present potential solutions.

CenturyLink Response

Michael Zulevic Director Technical Regulatory Support Covad Communications

SUBJECT: Qwest’s Change Request Response - CR # PC011502-1 Joint Testing of Qwest Installed Transmission Cables

This letter is in response to your Change Request PC011502-1 requesting a formal test and turn up process and an acceptance period after the collocation installation work completes – after Ready For Service (RFS). Covad envisions this process as joint testing at no additional cost to take place within 60 days of the RFS that allows for scheduling of their technicians.

Qwest is committed to providing quality facilities installations by the RFS date and Qwest’s warranty obligations will be enforced. Qwest installation forces perform continuity testing where appropriate when the collocation is turned over to Covad for acceptance. We perform quality audits on a random basis to check the quality of our work on the collocation CLEC cable installations. Streaker tests are performed on Line Sharing installations.

Recent results of Qwest internal quality audits have identified the following as it relates to the line sharing installations performed as a project in the summer of 2000: ? Of 249 jobs checked, 25.7% had some percentage of defects. ? One way to describe it is in # of pairs provisioned - (1 pair/job w/problem) x (25.7% of jobs w/connection problems)/300 pairs/job = 0.086% of all terminations wired had problems open/cross/reversal problems. ? This type of error is not common, but not unheard of in Telecommunications Installation. ? 7 jobs (3%) had the cards not seated in the splitter. Normally, Central Office Equipment installation hands off cards to the CO Operations for final test/turn-up. Line Sharing differed from this ingrained work-norm, and thus resulted in 2% of those jobs exhibiting this problem. ? 3 (1%) of the jobs had items that were found to be attributed to CLEC-issues (e.g. telling Qwest to cannibalize circuits that already had jumpers run for CLEC-customers, and 1 item that was traced back to the Customer Premise - end user equipment). ? 5 jobs had a combination of the above issues.

Given the newness of the product and associated processes and technologies, this project proved more challenging than any standard collocation build. Thus, the quality of those standard builds are even better than the Line Sharing results.

After the facility installation has been turned-over and the CLEC has had the opportunity to terminate their bulk end of the cable, full testing of the terminations between their collocation space and the vertical side of the ICDF can be done by the CLEC. In the case that these CLEC test indicate Qwest-defects, Qwest is willing to revisit the site and resolve any such defects for no additional charge should they exceed a 2% threshold. The attached diagram captures the existing test points as they are defined today in the Unbundled Loop process and collocation test access.

The piece of cable between the CLEC’s collocation space and the vertical side of the ICDF (commonly referred to as CLEC cabling) is the responsibility of CLEC and is paid for by the CLEC, as part of the collocation build out. With that stated, the CLEC is responsible for the testing, maintenance and subsequent repair if they were to find trouble in this cable “piece” after any acceptance or continuity test on their part requiring Qwest installation revisit initially.

Qwest evaluated the possibility of having a coordinated Joint Test on a regularly scheduled basis, but determined quality results indicate it would not be productive to do so and would indeed be costly. Nevertheless, we are willing to Joint Test should a CLEC still feel the need for such a service and agree to do so under our Special Request process and price the service accordingly.

We are committed to define the Joint Test process over the next few months.

Sincerely,

Steve Nelson Group Product Manager-Collocation

Cc: Laurel Burke Mary Retka William Campbell

(See end of this CR Detail Report for Attachment)

Open Product/Process CR PC011502-2 Detail

Description Of Change

Additional Information: Covad has experienced a significant number of incorrectly wired customer circuits. These include incorrectly wired DS0 UNE and Line Shared services and also DS1/3 services which have been delivered with the transmit and receive conductors reversed, requiring a technician dispatch to the central office.

Status History

Project Meetings

07/17/02 - July CMP Meeting Minutes: Qwest stated all collocation point of demarcation cross-connect wiring documentation had been placed in the central offices. Covad agreed to change status to closed.

9:00 a.m. (MDT) / Monday 18th February 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC011502-2 "Collocation Point of Demarcation cross-connect wiring diagram" [Follow-up Meeting]

Michael Zulevic, Covad Laurel Burke, Qwest Steven Hilleary, Qwest Michael Lanoue, 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} Description: Provide documentation at every Point of Demarcation cross-connect point, clearly available to both Qwest and CLEC technicians, which clearly describes the appropriate method of making cross-connects, in order to eliminate reversed circuits and/or incorrectly wired circuits. This documentation will provide a consistent product for CLECs and establish a common understanding between the CLEC and Qwest technicians as to the proper wiring of DS0 (UNE and Line Shared), DS1 and DS3 circuits, eliminating unnecessary trouble reports and costly dispatches. Additional Information: Covad has experienced a significant number of incorrectly wired customer circuits. These include incorrectly wired DS0 UNE and Line Shared services and also DS1/3 services which have been delivered with the transmit and receive conductors reversed, requiring a technician dispatch to the central office.

Additional discussion occurred regarding specifics of the request. Covad indicated that it would like to have wiring diagrams in the collocation areas for the cross connects for DS0/DS!/DS3 circuits. Steve Hilleary & Michael Lanoue, Qwest indicated that current test procedures should identify polarity (transmit/receive) reversals, unless "loop backs" are utilized during testing. Qwest will review procedures and determine if "loop backs" are allowable. Laurel Burke, Qwest requested more recent specific examples dealing with the CR from Covad. Qwest will conduct the CLEC community clarification in the 20-Feb-02 meeting, to solicit any additional input.

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 & Covad 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)"} Covad is requesting Qwest to provide process/documentation available to both Qwest and CLEC at the ICDF detailing the correct cabling (& terminations) for a cross-connection.. Qwest to evaluate CR. During the February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR.

--

10:00 a.m. (MDT) / Monday 21th January 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC011502-2 "Collocation Point of Demarcation cross-connect wiring diagram"

Michael Zulevic, Covad Shirley Tallman, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change: Description: Provide documentation at every Point of Demarcation cross-connect point, clearly available to both Qwest and CLEC technicians, which clearly describes the appropriate method of making cross-connects, in order to eliminate reversed circuits and/or incorrectly wired circuits. This documentation will provide a consistent product for CLECs and establish a common understanding between the CLEC and Qwest technicians as to the proper wiring of DS0 (UNE and Line Shared), DS1 and DS3 circuits, eliminating unnecessary trouble reports and costly dispatches. Additional Information: Covad has experienced a significant number of incorrectly wired customer circuits. These include incorrectly wired DS0 UNE and Line Shared services and also DS1/3 services which have been delivered with the transmit and receive conductors reversed, requiring a technician dispatch to the central office.

Michael Zulevic, Covad reviewed CR stressing the following: 1) focus primarily on DS1 and DS3 cross-connects utilizing ICDF’s; 2) polarity (Transmit/Receive) of connections incorrectly wired; and 3) need process/documentation for access by both Qwest & CLEC to completed connection correctly, thus avoiding cross-connection re-work. Examples were cited in the Seattle, WA and Minneapolis, MN CO’s. Covad indicated that Susan Early, Qwest [Covad account manager] is aware of incorrect wiring examples. Incorrect wiring results in service affecting conditions, along with need for re-work.

Shirley Tallman, Qwest asked clarifying questions and indicated that research with the methods group appears to be warranted to identify current Qwest practice, and determine what could be done to address the CR.

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 & Covad 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)} Covad is requesting Qwest to provide process/documentation available to both Qwest and CLEC at the ICDF detailing the correct cabling (& terminations) for a cross-connection.. Qwest to evaluate CR. During the February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR; or provide an expedited response to the CR.

CenturyLink Response

COVAD Communications Michael Zulevic Director Technical Regulatory Support

SUBJECT: Qwest’s Change Request Response - CR # PC011502-2 Collocation Point of Demarcation cross-connect wiring documentation

This letter responds to COVAD Communications’ Change Request PC011502-2 requesting the posting of the DS1/3 circuit wiring diagram on the Central Office ICDF DSX frames. Covad indicated that the purpose of the diagram posting was to eliminate reversed circuits as in line sharing situations and other incorrectly wired circuits as well as to provide cross connection wiring consistency between CLEC and Qwest technicians.

Qwest maintains responsibility for correctly provisioning cross connections on all order types. Qwest Central Offices contain a large and variable number of InterConnection Distribution Frame ("ICDF") Digital Signal Level X(DSX) frames, estimated to exceed 10, 000 frames, that would in turn require a large number of DSX circuit cross connection diagrams. Qwest also recognizes that concerns and questions arise surrounding the provisioning of DS1 or DS3 cross connections. Therefore, Qwest will provide a copy of the Qwest Method and Procedure ("M&P") in each Central Office location. Central Office personnel responsible for provisioning and repairing DS1/DS3 circuits will be able to access the M&P. The M&P will be available beginning in June 2002. Further, after following the office wiring steps loaded into Qwest systems for the order, Qwest ensures that the proper transmit to receive connectivity has been achieved by performing the proper post wiring tests.

Qwest reiterates its commitment to correctly wire cross connections on all types of orders and believes that providing the Qwest M&P in each Central Office will alleviate the concerns expressed. If Covad has information related to specific instances of improper wiring, Qwest continues to request that Covad provide such information so that Qwest can take the appropriate action.

Sincerely,

Laurel L. Burke Staff Adovcate Technical Regulatory Interconnection Planning Local Networks

cc: Deborah Heckart, Director Program/Project Management Mary Retka, Director Legal Issues

Open Product/Process CR PC011502-4 Detail

Description Of Change

Additional Information: Qwest agreed to provide this documentation when this problem was discovered during the initial deployment of splitters. Covad preferred to have the installations re-wired using the 1 to 100 convention, but agreed to the posting of documentation. This documentation is not currently posted in Qwest central offices. When a trouble report is identified with a customer using Covad tie pair 26, Qwest technicians must know that the customer’s service is on pair 25 on the Qwest cross-connect blocks. Without clear and available documentation available to the Qwest and CLEC technicians, service could be interrupted for the wrong customer, and resolution of the original trouble report will be further delayed.

Status History

Project Meetings

CenturyLink Response

Michael Zulevic Director, Technical Regulatory Support Covad Communications

The following response was originally issued in a letter dated February 6, 2002. It is being reissued to incorporate an updated Qwest / CLEC Interconnect Distribution Frame (ICDF) Cable Numbering table (see attachment).

SUBJECT: Change Request Form Number PC011502-4 “ Documentation of Block and Splitter Port Numbering for Virtual Splitters,” dated January 14, 2002.

Qwest has evaluated the Change Request (CR) PC011502-4, and has determined the following:

? Covad is correct with their assessment of the potential confusion that may arise from the different cable wiring schemes utilized by Qwest and the CLECs at the Interconnection Distribution Frame (ICDF). Qwest or CLEC technicians may incorrectly install or service these connections, resulting in potential customer service impacts.

? Qwest will draft a “Job Aide Table” identifying the relationship between the Qwest and CLEC cable wiring schemes. The table will augment the existing information in the current internal Central Office Job Aide. The table will be placed within the vicinity of the individual ICDF(s) in the Central Office (CO) on the back of the previously agreed to existing job aide as discussed with the Federal Communications Commission (FCC). The target date for issuing the “Job Aide Table” is March 31, 2002. Qwest will notify the CLEC community of formal issuance via the Notification Process through the Change Management Process (CMP).

Sincerely,

Jeff Cook Network Planner – Technical Regulatory Qwest

Cc: Mary Retka, Director Legal Issues, Qwest Brett Fesler, Associate Product Manager, Qwest

Attachment (See Supplemental Information)

Open Product/Process CR PC011502-3 Detail

Description Of Change

Additional Information: Covad has experienced a significant number of incorrectly cabled, or designated tie cables from Qwest which has resulted in our not being able to remotely provision customer service.

Status History

Project Meetings

Michael Zulevic, Covad Laurel Burke, Qwest Cathy Paradiso, Qwest Peter Wirth, Qwest

1.0 Introduction of Attendees Attendees introduced.

2.0 Review Requested (Description of) Change: Description: Provide documentation to CLECs upon completion of new collocation activity or augments to existing collocations, that specify all tests performed to ensure that the work completed by Qwest, or a Qwest designated vendor, was completed properly. These test records must reflect the absence of any physical or electrical faults, including incorrect numbering of cables or cross-connect blocks. Completion of test records is a requirement of Covad’s non-ILEC contractors and the same requirements must apply to Qwest. This requirement has always been placed upon Qwest’s contractors when they are performing work for Qwest. Additional Information: Covad has experienced a significant number of incorrectly cabled, or designated tie cables from Qwest which has resulted in our not being able to remotely provision customer service.

Michael Zulevic, Covad reviewed the CR and added the following points: 1) Covad is requesting testing/acceptance documentation for collocation augment and new location builds; 2) documentation to be available upon turn-over to CLEC; 3) provides some assurances to CLEC that collocation space has been properly installed/tested; and 4) Covad’s experiences have been that some problems (i.e., grounding, cable labeling, etc). Covad also suggested that some type of co-acceptance by Qwest & the CLEC may assist in this request.

Examples of occurrences were requested by Laurel Burke & Cathy Paradiso, Qwest. Examples were transmitted earlier to Laurel Burke.

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 & Covad 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)} Covad is requesting Qwest to provide documentation available to both Qwest and CLEC for collocation space augments/builds to document install/testing status for acceptance. Qwest to evaluate CR. During the February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR; or provide an expedited response to the CR.

CenturyLink Response

Michael Zulevic Director Technical Regulatory Support Covad Communications

SUBJECT: Qwest’s Change Request Response - CR # PC011502-3 Testing Documentation

This letter provides a draft response to your CLEC Change Request Form, number PC011502-3 dated January 14, 2002 - "Provide test documentation for all collocation activity including transport cable augments". Covad requested that documentation be provided upon the completion of collocation activity specifying all tests that performed to ensure cabling work by Qwest or a Qwest designated vendor, was completed properly. During the Change Management Process forum, February 20, 2002, Covad provided further clarification indicating that they would limit this request to virtual and line sharing collocations. Since no discussion included remote collocation applications, this response only addresses central office based virtual collocation and the installation of line sharing.

As part of its standard procedure, Qwest performs cable tests where needed and appropriate. As the CLEC community recognized during the forum, testing of the bulk cable in the physical collocation job does not provide much value as the cable is not terminated to CLEC equipment. However, continuity testing associated with virtual like collocations, including line sharing does not have the same limitation. Thus, on a going forward basis, Qwest agrees to provide the completed Cable Test Record (COE) document RG47-0157 (attached to this response), beginning April 1, 2002, to CLECs involved with new or augmented virtual collocations and line sharing orders, upon CLEC request.

Sincerely,

Laurel L. Burke Staff Advocate Technical Regulatory Interconnection Planning, Local Networks Qwest

cc: Mary Retka, Director, Technical Regulatory Interconnection Planning David Fong, Director, Qwest Central Office Technologies Installation Chuck Points, Director, Qwest Central Office Technologies Installation

Open Product/Process CR PC020502-1 Detail

Description Of Change

Products Impacted: Any products requiring tie cables to a collocation arrangement.

Qwest policy currently requires Covad to provide specific information relative to the tie cable assigned for use on a LSR/ASR. This information includes the type and gauge of cable of the assigned facility (CFA). If this information is not included or is not in agreement with Qwest records, the LSR/ASR is rejected, which results in delays for Covad customers. Covad believes that it should not be necessary to provide tie cable technical specifications on an LSR. This information is available to Qwest, as they originally installed the tie cables and determined the appropriate technical specifications at that time. This information should be available to them in TIRKS, if required. Further, Qwest is the only ILEC that requires this information to be provided on an LSR/ASR, indicating that the Qwest process is not consistent with industry "Best Practices."

Covad has experienced a significant number of order rejections for DS0, 1 and 3 services due to the omission of tie cable technical information or perceived discrepancies relating to these specifications resulting in delayed customer service provisioning.

Status History

Project Meetings

May 7, 2002 9:00 am (MDT) Conference Call TEL: 877-564-8688 CODE: 8973036 PC020502-1, Action Item No. 1

Attendees: Mike Zulevic, Covad Judy Hotovec, Covad Becky Neessen, Covad Ric Martin, Qwest Susan Earley, Qwest Crystal Soderlund, Qwest

Introduction of Attendees and Purpose of Meeting Introduction of the participants on the Conference Call was made. Ric explained that the purpose of the call was to clarify the action item requirements identified in April’s CMP meeting versus the requirement that was discussed in a Covad/Qwest conference call after the CMP meeting.

Review of Action Item Requirements Ric explained that it was Qwest’s understanding from the April CMP meeting that Covad was to identify a Central Office (CO) to Qwest (Susan) and Qwest Crystal would validate the CFA information at that CO. A subsequent conference call between Qwest and Covad identified the action that Qwest was to advise if a report could be generated from TIRKS to provide all of Covad’s CFA information for all COs. Ric asked which direction Covad wanted Qwest to take. Mike advised that there is a miss-match with the cable gauge information on the final CFA and what is in TIRKS. He understood the System CR needs, but indicated that would take a while to get through the process. He would like to have a 100% validation of their CFA information. Becky indicated that at the call between Qwest and Covad, Bill Fellman was to do a sampling of COs. Susan advised that she could do a sampling of a few offices. It was agreed that Covad would provide 4 COs which Qwest would validate the CFA information for each CO. Covad is to provide their APOT information, which Qwest will validate against. Becky advised that it would be a day or two before she could provide the information. Mike re-emphasized the need to have a 100% validation and would like to get a mechanized dump from TIRKS. Susan advised that she wasn’t aware if there had ever been an electronic dump. Susan will follow-up to determine if this is feasible. Judy indicated that there should be an OVC & APOT dump query. Qwest advised that they would respond to the items by May’s CMP meeting, or sooner.

Subject: RE: CFA Validation Date: Thu, 2 May 2002 12:24:11 -0600 From: "Susan Earley" To: "Michael Zulevic" CC: "Richard Martin" , "Susan Earley" , "Crystal Soderlund" , "Beckie Neesen (E-mail)"

In the meeting we had last month on line sharing and line splitters. I thought Becky brought this up and Bill Fellman was going to check with Tirks staff to see if they could run some kind of report to pull the CFA information for all of Covad's collos. Other then pulling up each one individually Bill and I knew of no way to pull all the collo information at once. I have left Bill a message asking about this. I will get back to you as soon as I hear from Bill.

Susan

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Subject: RE: CFA Validation Date: Tue, 30 Apr 2002 17:08:49 -0700 From: "Michael Zulevic" To: "Richard Martin" CC: "Susan Earley" , "Crystal Soderlund" , "Beckie Neesen (E-mail)"

Ric,

According to Beckie, we are still waiting to see how you can provide us with a report from TIRKS that will allow us to validate it against our systems. Maybe Susan has an update on this.

Mike Z.

From: Richard Martin [mailto:rhmart2@qwest.com] Sent: Tuesday, April 30, 2002 2:04 PM To: Mike Zulevic Cc: Susan Earley; Crystal Soderlund Subject: CFA Validation

Mike,

At the last month CMP meeting, you requested that Qwest validate CFA information. Crystal Soderlund would work with Susan Early on this. You were to get with Susan to identify a Central Office they can take a look at.

Please let me know if this was your understanding and if you have had a chance to provide the information to Susan.

Thanks

Ric

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Subject: RE: Action Item from April's CMP on CR PC020502-1 Date: Wed, 24 Apr 2002 16:07:48 -0700 From: "Michael Zulevic" To: "Richard Martin"

Ric,

I would like Qwest to find out why your TIRKS system has this requirement when other ILECs don't. My thought was for Qwest to use it's contacts from TIRKS user groups, or Telcordia, to determine if there is an easy way to address this. I don't think any contacts we may have would be useful in making this determination.

Mike Z.

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Subject: Action Item from April's CMP on CR PC020502-1 Date: Wed, 24 Apr 2002 15:18:52 -0600 From: Richard Martin Organization: Qwest Communications International, Inc. To: Mike Zulevic

Mike,

At April's CMP meeting, we took an action item to contact ILECs regarding their practice of not requiring cable gauge information.

With the issuance of the Systems CR, do you still want Qwest to pursue this item. If so, could you provide the various contacts at the other ILECs that you deal with on the subject.

Thanks

Ric

Subject: APOT cable gauge problem Date: Mon, 18 Mar 2002 15:08:30 -0700 From: "Michael Zulevic" To: "Richard Martin" CC: "Judi Hotovec"

Ric,

Here is another example of the problem we are having with the cable guage. I'm told this office in Denver has become a major problem.

Thanks for your help.

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

Order# 1900877, pon# 1519719 out of central office DNVRCOCH on pair 8 > has the cable gauge info as 24-NL. The correct cable gauge for this CO > is pairs 1-300 = 26-NL pairs 301-900= 24-NL. Could you change this > information for me?

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CLEC Change Request Additional Clarification Meeting

March 7, 2002 8:00 am (MDT) Conference Call TEL: 877-564-8688 CODE: 8973036 PC020502-1, ASR/LSR Cable Specification

Attendees: Mike Zulevic, Covad Judy Hotovec, Covad Richard Martin, Qwest Diana Rasmussen, Qwest Crystal Soderlund, Qwest

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

Additional Change Request Clarification Covad provided clarification that they would provide the cable name and/or cable pair number as required. They do not inventory the cable specification (i.e. cable gauge) and would prefer not to provide this. They indicated that no other ILEC required cable gauge information. They advised of past experience where the cable gauge changed and they were not aware. Qwest advised that they use TIRKS to inventory the cable information. Covad indicated that they thought the other ILECs also used TIRKS. Qwest advised that from the ASR stand point, the CLEC was required to provide the cable information if they were responsible for the cable assignment. Qwest advised that they would need to check what IMA validates in TIRKS and what is required for a partial/full flow through. It was agreed that the product type would cover UBL, UDIT and maybe Private Line, but would exclude shared loop. Qwest confirmed that the cable information is provided with the APOT and any revisions would generate a revised APOT.

Action Plan Qwest advised that they would be prepared to provide verbal options at the next CMP meeting.

Subject: CR PC020502-1 Date: Thu, 21 Feb 2002 10:50:24 -0700 From: Richard Martin Organization: Qwest Communications International, Inc. To: Mike Zulevic CC: Karen Kraas , Diana Rasmussen , Laurel Burke

Mike,

Could you please address the following questions:

1. What field(s) on the LSR and ASR do you populate with the tie cable specifications that causes the reject/delay?

2. I believe the LSR numbers you provided on our clarification call are Covad's internal LSRs. They do not appear in our system. Could you provide the corresponding Qwest LSR or PON.

Thanks

Ric

CLEC Change Request Clarification Meeting

2:30 p.m. (MDT) / Friday February 15, 2002 Conference Call TEL: 877-564-8688 CODE: 8973036 PC020502-1, Collocation Point of Demarcation cross-connect wiring

Attendees: Mike Zulevic, COVAD Richard Martin, Qwest Jeff Cook, Qwest Diana Rasmussen, Qwest Karen Krass, Qwest Laurel Burke, Qwest Bob Mohr, Qwest

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 Mike advised that on LSRs and ASRs information requested relates to the make-up of the specific tie-cable (1.e. 22/24 ga. Or 734/735 cable). Qwest provides the cable information. If COVAD doesn’t provide the cable information, or the cable information is different than what is in Qwest’s database, their order is delayed or rejected. Qwest advised that the cable information was part of the APOT number. It was confirmed that in IMA, this is a mandatory field. Qwest asked if there was a timing issue with providing the cable specification. Mike advised that there wasn’t a timing issue, but was concerned that there is no real value for the information, since Qwest has the information. Qwest advised that the cable information is provided in the APOT. COVAD indicated that sometimes the preliminary & final do not match up. COVAD provided the LSR examples: 1773574, 1738856, and 1850263. Qwest will look into these examples to determine what the downstream impact would be if the cable specification wasn’t provided.

Confirm Areas & Products Impacted COVAD advised that they would be interested in addressing any product that requires a tie cable going back to their Collo. . Confirm Right Personnel Involved Ric advised that we would need to identify another SME for this CR. The examples provided were for LSR. The SME on the call was responsible for Collo and dealt with ASRs. Qwest will identify the appropriate SME. Ric advised that if an additional clarification meeting were required, they would coordinate.

Identify/Confirm CLEC’s Expectation COVAD confirmed that they would like to remove the mandatory requirement to provide the cable specifications with the LSR/ASR.

Identify any Dependent Systems Change Requests It was confirmed that there is no corresponding Systems Change Request.

Establish Action Plan (Resolution Time Frame) Qwest to obtain appropriate SME(s). The CR will be open to the CLEC community clarification at March’s CMP Meeting.

CenturyLink Response

Michael Zulevic Director, Technical Regulatory Support Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC020502-1 Eliminate Requirement to Provide Tie Cable Specification

This letter is in response to Covad’s Change Request PC020502-1 requesting that Qwest revise its LSR and ASR requirement for providing tie cable type or technical specification (i.e. cable gauge).

The APOT CFA data for cable gauge information is a requirement for the Qwest TIRKS database. If the cable gauge information is not passed via the service order, it does not allow the order to flow through without manual design intervention. This could cause delays for the CLEC and an increase in costs and resources for Qwest to perform this manual work. Increasing manual intervention defeats Qwest’s goal to promote flow through mechanization.

Programming for retrieving the cable gauge information from TIRKS and passing it to the order would require multiple systems changes. A Systems Change Request would be required to accomplish this. If Covad would like to pursue the systems changes that could accommodate their Change Request, Qwest will open a Systems Change Request on Covad’s behalf.

Sincerely,

Crystal Soderlund Sr Process Analyst

Cc: Diana Rasmussen Karen Kraas Susie Bliss

Open Product/Process CR PC101802-1 Detail

Description Of Change

Submitted 02-11-03

PC101802-1 – Description of Change

Currently, Covad obtains demarc information from Qwest as part of the joint acceptance testing process. In the event that demarc in not transmitted at that time, Covad can obtain demarc info by calling Qwest’s Interconnect Group. By making demarc info available offline, electronically, Qwest will eliminate the need to staff this function and Covad and other CLECs can access that information at any time. All CLEC’s require demarc information on any install performed by Qwest regardless of the product. The CLEC itself or a Vendor will need to finish or extend the install to the customer and often cannot locate the line or circuit. The result is a call to obtain the information.

Expected Deliverable

Electronic Access to demarc information

==============

Currently, Covad obtains demarc information from Qwest as part of the joint acceptance testing process. In the event that demarc in not transmitted at that time, Covad can obtain demarc info by calling Qwest’s Interconnect Group. By making demarc info available offline, electronically, Qwest will eliminate the need to staff this function and Covad and other CLECs can access that information at any time.

Expected Deliverable

Electronic Access to demarc information

Status History

Project Meetings

Buckmaster-Qwest presented the response and stated that the CR would cross over to the systems side for development and implementation. The CR was crossed over.

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04-16-03 - CMP Meeting

Buckmaster-Qwest stated that Qwest had researched the Eschelon request from the March meeting and determined that it would signifigantly change the scope and cost of the solution. She suggested that current testing had shown that 100 percent of the samples included binding post information. She cautioned that Qwest could not guarantee that information would be in the report. She asked the CLECs to evaluate the strength of the Qwest solution and submit another CR if they felt that it did not meet their specific needs. The CR was moved to development status.

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03-19-03 - CMP Meeting

White-Qwest stated that an Ad Hoc meeting to discuss this CR was held on 3/17. He stated that Qwest presented a proposed solution at this meeting and, based on questions here, would present a formal response to the web after this meeting and present it at the April CMP Meeting. Johnson-Eschelon asked if binding post information would be available to the CLECs. Buckmaster-Qwest stated that binding post information would be available for POTS and designed services when it was available. She stated that the focus of this CR was on the information that was in WFA/C for designed services; primarily the location of the demarc. She stated that this database may include additional information, and that Qwest would provide all information it had. She stated that she had reviewed several examples and that all of them had the information Bonnie was interested in. Johnson-Eschelon stated that she did not want to alter this CR and would submit a separate CR if there were many instances where there was no binding post information. Buckmaster-Qwest pointed out that Qwest provides the CLECs demarc information two times, by voice and e-mail, immediately following the completion of work. Mendoza-Allegiance stated that the Qwest technicians should provide binding post information. Buckmaster-Qwest stated that the description of change for this CR did not include changing the processes for Qwest technicians. Zulevic-Covad agreed that the CR was only written to obtain access to demarc information. Thomte-Qwest asked Zulevic and Johnson if they would be amenable to opening an additional CR for this if necessary. Johnson-Eschelon and Zulevic-Covad stated that they would.

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Ad Hoc Meeting 10:00 a.m MT, March 17, 2003

Attendees Matt White – Qwest Cindy Buckmaster – Qwest Dan Busetti – Qwest Jeanne Whisenant – Qwest Dave Hahn - Qwest John Berard – Covad Rick Paine – US Link Lori Mendoza – Allegiance Liz Balvin – WorldCom Terrance Morgan - WorldCom Erica Beamus – WorldCom Jeff Gelwick - WorldCom Stephanie Prull – McLeod USA Bonnie Johnson – Eschelon

White-Qwest welcomed attendees and explained the purpose of the meeting. He asked Buckmaster to review the potential solution Qwest had identified for the CR.

Buckmaster-Qwest reviewed the issues identified on the prior Ad Hoc call and stated that Dan Busetti came up with a potential solution. Busetti-Qwest reviewed the solution. He stated that Qwest would add functionality in CEMR to meet this request. He stated that for non-design circuits, CLECs would go to the non-design services action page and select a radial button to view the demarc information. He stated that a similar process would be in place for design services.

Mendoza-Allegiance asked if this functionality would include orders that have been dispatched or only those that have not been dispatched. Buckmaster-Qwest stated that Qwest would provide any information Qwest has. She explained that there would be occasions when Qwest doesn’t have all the information. She clarified that Qwest would not dispatch just to provide information to the database. She stated that the information for Designed Services would be pulled from WFA/C. She stated that information is populated into the database by Qwest technicians at many different locations. Johnson-Eschelon stated that at the previous Ad Hoc meeting Buckmaster had stated that the times when information was not available would be rare. Buckmaster-Qwest stated that at the previous Ad Hoc call the participants discussed that the Demarc information is most important in multi-tenant environments. She stated that binding post information was ancillary to the original request. She explained that Qwest would provide all the information that it can. Johnson-Eschelon asked if Qwest would provide binding post info if it is available. Buckmaster-Qwest stated that Qwest would.

Mendoza–Allegiance asked how the information got into the database if the order was not dispatched. Buckmaster–Qwest stated that if a technician anywhere provides the information, it would provided to the CLECs. She stated that Qwest was not modifying the existing processes for Qwest technicians. She stated that any information in the databases would be available to the CLECs. She explained that POTS has a different source than the Design Services side. Busetti–Qwest stated that LMOS was the database that Qwest would be be pulling the POTS information from. He stated that this database, if properly populated, includes terminal and binding post information.

Berard–Covad asked if specials would be pulled from WFA-C. Busetti–Qwest stated that the would.

Berard–Covad asked if Qwest was setting up a separate database and if Qwest could send the information to the CLECs. Busetti–Qwest stated that Qwest would not send reports to the CLECs, but that the functionality would take a live look at the data in WFA/C and LMOS at the time of the request. Berard–Covad stated that he was happy to hear that it was a live look. He confirmed that when CLECs went into CEMR and made a request it would be live look. Busetti–Qwest stated that the information would be pulled directly from WFA/C and LMOS.

Mendoza-Allegiance asked how the data would be in these databases. Busetti–Qwest stated that it would be in the database as long as the circuit is alive. Prull–McLeod asked how long it took the technicians to update the information in the database. Buckmaster–Qwest stated that she would check. She stated that it was updated within the same workday and that the practice is to do it as soon as the work is completed.

Mendoza–Allegiance asked if the technicians would go out on the plant test date for designed services. Buckmaster–Qwest stated that she needed to check to get an accurate answer to that question.

White-Qwest asked if this met Covad’s intent for the request. Berard–Covad stated that Covad would still like the information sent to them, but that this was a good solution. Buckmaster-Qwest stated that the information is delivered to the CLECs twice for Designed Service circuits: verbally upon closure, and via e-mail within 48 hours of closure. Berard-Covad stated that was good to hear. He stated that Covad could work with that.

White-Qwest stated that Qwest would present a verbal response at the March 19 CMP Meeting and would post a written response on the interactive report following the meeting. He thanked the attendees and adjourned the meeting.

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02-19-03 - CMP Meeting

Buckmaster-Qwest presented the Qwest response. Zulevic-Covad stated that his preference was to have the information sent to the CLECs, and his second preference was to have Qwest make the information available to the CLECs. Buckmaster-Qwest stated that she understood that this CR requested three things: 1. An electronic means of accessing information regarding the Demarc and Binding Post location - for orders that were provisioned by Qwest at the CLEC’s request. 2. The CLECs would like this information for both Designed and POTS. 3. Provided as soon as possible upon completion of Qwest’s work. There were no further questions.

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Ad Hoc Meeting 02-07-03

Attendees Matt White – Qwest Cindy Buckmaster – Qwest Deni Toye - Qwest Bonnie Johnson - Eschelon Rick Paine – U.S. Link Kelly Hamilton – U.S. Link Karla Kaatz – 180 Communications Mike Zulevic – Covad Glenn Gill – ATG

White-Qwest announced attendees and explained that the purpose of this meeting was to allow Qwest to ask Covad some questions about the CR.

Buckmaster-Qwest stated that she thought the Covad was requesting demarc information in an accessible form so the company could route its technicians properly. Zulevic-Covad stated that this was the gist of the request. Johnson-Eschelon stated that she would like Qwest to give the demarc information including the where the cross-connect is made. She would like the information to include terminal and binding post information. Zulevic-Covad stated that he would revise the Description of Change to reflect this information.

Buckmaster-Qwest asked if the location of the demarc information was only important for large (primarily commercial) buildings. Zulevic-Covad stated that the majority of the sites they wanted demarc information for were commercial sites or large buildings, but there were some unique residential locations they also needed it for.

Buckmaster-Qwest stated that the demarc information may not be available on 100% of the circuits. Zulevic-Covad asked if the Qwest installation technicians reported the demarc information into WFA. Buckmaster-Qwest stated that she did not know. Toye-Qwest stated that the demarc information was communicated via the PTA e-mail after and order is completed. Johnson-Eschelon stated that the e-mail did not include binding post information except for T1’s. She stated that they CLECs were asking for a report that included POTS.

Buckmaster-Qwest stated that she might have to issue a response that commits to only giving the CLECs the information that Qwest currently has. Johnson-Eschelon stated that she understood that the information might not be everything the CLECs would like. Buckmaster-Qwest stated that currently the demarc information is supplied to the CLECs at two different times: verbally when the order is closed and electronically (via e-mail) within 48 hours after the order is closed.

Johnson-Eschelon stated that the real issue was the CLECs are having a problem finding demarc locations and binding post assignments. As a result, the CLECs call QCCC. She stated that completing this CR would result in a small call flow to the center. Zulevic-Covad stated that Covad calls the QCCC to determine demarc information for every order their technicians went on. He stated that he was not sure that Qwest had the complete information for every call.

Buckmaster-Qwest recapped that the CLECs were looking for an electronic method to access information on demarc and binding post locations. Gill-ATG stated that the appropriate means to communicate this information would be on the loop DLR/DSR. Johnson-Eschelon stated that the DLR is not available soon enough. Buckmaster-Qwest reviewed that the CLECs want access to the information about the physical location that Qwest did its work. Johnson-Eschelon stated that Buckmaster had adequately summarized the essence of the request. Zulevic-Covad stated that the CLECs wanted this information as soon as the Qwest technicians finish their work.

Zulevic-Covad stated that he was not familiar with the PTA e-mail results. He stated that that method of communication would not work for POTS.

Buckmaster-Qwest recapped that the CLECs were looking for: 1. An electronic means of accessing information regarding the Demarc and Binding Post location - For orders that were provisioned by Qwest at the CLEC’s request 2. The CLECs would like this information for both Designed and POTs services 3. Provided as soon as applicable after the close of the order

There were no further questions. White-Qwest and Buckmaster-Qwest thanked the attendees and adjourned the meeting.

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01/15/03 - CMP Meeting

Moreland-Qwest presented the Qwest response. White-Qwest recommended the CR be placed in Evaluation status when it is crossed over. Johnson-Eschelon asked if a representative from IT could explain in more detail why the CR needed to be crossed over. Schultz-Qwest stated that they could. The CR was crossed over to systems with a status of Evaluation.

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12/18/02 - CMP Monthly Product/Process Meeting

Moreland-Qwest described the CR and presented the Qwest response. Berard-Covad stated that Qwest was looking at a database but Covad was open to Qwest introducing any type of electronic means of presenting the information, not just EDI. He stated that Covad would prefer EID, however. Boudhaouia-Qwest stated that stated that Verizon doesn’t have a database and Qwest is trying to determine if there is a feasible way for Qwest to make this information available to the CLECs. Johnson-Eschelon stated that regardless of how Verizon delivers, the fact is that they do make the information available and Qwest does not. She continued that this would be a good change for all companies involved. The attendees agreed to move the CR into Evaluation status.

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11/20/02 - CMP Monthly Product/Process Meeting

Berard-Covad presented the CR. He stated that Covad wanted electronic access to demarc information and was given that access by other ILECs. White-Qwest asked which ILECs provided this information and how they provided it. Berard-Covad stated that Verizon provides CLECs a downloadable file that contained demarc information and updated this file four times a day. He stated that the information included floor/closet/binding post or language like “northwest corner of the basement.” Schultz-Qwest asked how having electronic access to this information helped Covad. Berard-Covad stated that it allowed them to access the information at any time and that Covad was hoping to streamline the process in the future to allow JAT without a phone call. Berard-Covad stated that Covad would prefer a file be sent to them every day, but would be happy with a download. Spangler-AT&T and Johnson-Eschelon stated that they would prefer delivery as well and that this should apply to all resale products as well. The CR status was updated to Presented.

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CLEC Change Request – PC1018002-1 Clarification Meeting 2:00 PM (Mountain Time) / Tuesday, November 5, 2002

1-877-550-8686 2213337#

Attendees Matt White – CRPM Minda Cutcher – Covad Brett Fesler – Qwest Neil Houston - Qwest

Introduction of Attendees White-Qwest welcomed all attendees and reviewed the request.

Review Requested (Description of) Change Cutcher-Covad reviewed the CR and stated that Covad was seeking the same information about the physical location of demarcs at customer prems through electronic means as they got when they called the interconnect center QCCC. She said an example would be to say the demarc was in the northwest corner of the basement of a building.

Houston-Qwest confirmed that Covad was seeking a physical description so the Covad Technician could find the demarc.

Cutcher-Covad stated that they currently get the information during Joint Acceptance Testing, and that she would like a means to access the information electronically. She stated that Qwest must have a database in which it records this information and surmised that to grant this request, Qwest could design a means for Covad to access that database.

Houston-Qwest asked if Covad was seeking a Web site format.

Cutcher-Covad stated that they weren’t necessarily seeking a Web site that could be accessed 24x7, just a means of getting the information electronically during normal business hours. She stated that other ILECs (Verizon and PacBell) had offered this functionality to Covad.

Houston-Qwest stated that he would work with some of his contacts at those companies to understand how they offered this information to CLECs.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted. Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Covad’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Covad to present the CR at the November Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

DRAFT RESPONSE For Review by CLEC Community and Discussion at the May 21, 2003, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101802-1

Qwest accepts this change request. Qwest will implement a solution to this request in the CEMR release currently scheduled for implementation in first quarter 2004.

Functionality, scheduled for inclusion in this release, will include: - For Designed services – any information related to demarc location and binding post termination available - For Non-Designed services – any information related to binding post termination available.

There may be instances when no information is available in the source data. In such instances, the information will not be available via the new functionality. Additionally, Qwest will continue to provide customers with all applicable demarc/binding post information, by voice and e-mail, immediately following completion of work to connect a designed services circuit.

Qwest will provide updates on the progress of the implementation of this solution at Monthly CMP Product/Process Meetings.

Sincerely, Cindy Buckmaster Product Manager

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February 12, 2003

DRAFT RESPONSE For Review by CLEC Community and Discussion at the February 19, 2003, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101802-1

Qwest recently conducted an Ad Hoc Clarification meeting with several CLECs that revealed additional complexity in this CR. Qwest recommends this CR remain in Evaluation Status while Qwest fully explores a potential solution. Qwest will provide a status of Qwest’s research at the March CMP meeting.

Sincerely, Cindy Buckmaster Product Manager

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January 6, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the January 15, 2002, CMP Product/Process Meeting

Minda Cutcher VP Government and External Affairs Covad Communications

SUBJECT: Qwest’s Change Request Revised Response - CR #PC101802-1

This is a revised response regarding Covad CR PC101802-1.

The scope of this request is extremely large and detailed, as there are literally tens of thousands of demarc locations in Qwest’s fourteen-state region.

Qwest has researched the requirements to accomplish this request and has found it to be technically feasible. Implementing this request, however, will require changes to IMA. As a result, Qwest recommends that this CR cross over to become a Systems CR.

Sincerely,

Heidi Moreland Staff Advocate Policy and Law Qwest

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December 6, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at the December 18, 2002, CMP Product/Process Meeting

Minda Cutcher VP Government and External Affairs Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101802-1

This is a preliminary response regarding Covad CR PC101802-1.

The scope of this request is extremely large and detailed, as there are literally tens of thousands of demarc locations in Qwest’s fourteen-state region.

Covad indicated that Verizon provides a database for CLECs to get this information themselves, eliminating the need to call. Qwest research determined that Verizon currently supplies CLECs with demarc location information on an order by order basis using an existing database called Wholesale Provisioning Tracking System (WPTS) which they created for CLECs to track orders (see URL below). Demarc location information is only available for orders that have been dispatched and completed. Verizon’s system does not accumulate the information as an ongoing repository for general searches, thus there is no Verizon demarc database. At this time, Qwest does not have a similar WPTS-type database available and this request would require development of such a database.

Qwest recommends that this CR be placed in Evaluation status until Qwest completes an evaluation of the scope and feasibility of the process changes necessary to implement the Covad request.

Sincerely,

Heidi Moreland Staff Advocate Policy and Law Qwest

Open Product/Process CR PC101802-3ES Detail

Description Of Change

Expected Deliverable

Reduction of interval from 3 to 2 days effective Dec. 1, 2002

Status History

Project Meetings

Buckmaster-Qwest presented the revised Qwest denial. Zulevic-Covad stated that he found the number of resources Qwest claimed it required to shorten the interval by one day to be mind-boggling. He asked if Qwest’s DSL was a flow-though process. Buckmaster-Qwest stated that she did not know if it was a flow through process. Zulevic-Covad stated that the Qwest DSL interval was a 5 day end-to-end interval. He stated that the intervals for Line Sharing, Line Splitting and Loop Splitting services were not end-to-end. Covad often took more than 2 days to finish their portion of the provisioning process. He stated that this was not parity. He stated that Qwest could continue with whatever recommendation it liked. White-Qwest stated that Qwest was denying the CR. Zulevic-Covad stated that he would escalate the CR.

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Ad Hoc Meeting 01-29-03

Attendees Matt White – Qwest Cindy Buckmaster – Qwest Deb Smith – Qwest Judy Schultz - Qwest Mike Zulevic – Covad Liz Balvin – WorldCom Sam Tenerelli – WorldCom Sharon Van Meter – AT&T

White-Qwest announced attendees and explained that the purpose of this meeting was to allow Qwest to clarify its reason for denying this CR and to answer and CLEC questions that were not addressed at the January CMP Meeting. He asked Buckmaster-Qwest to review the Qwest Response to the CR. Buckmaster-Qwest reviewed the response. She stated that Qwest was denying the CR for economic infeasibility because of resources impacts, including addition of resources, and volume of orders. She stated that the cost to Qwest when taken into consideration with the volume of Line Sharing orders compared to the volume of like orders resulted in the economic infeasibility conclusion.

Balvin-WorldCom stated that there was discussion at the Monthly Meeting around products with two-day intervals. Buckmaster-Qwest stated that the only Qwest products with two-day intervals involved record work. She explained that none of these products had any technician intervention.

Van Meter-AT&T stated that she would like to see more detail in the response. Schultz-Qwest stated that Qwest would revise the response.

Balvin-WorldCom stated that there was a Systems CR that involved flowthrough that might influence Qwest’s decision to deny this CR. Schultz-Qwest suggested that the Product/Process CR remain in Denied status and that Buckmaster-Qwest review the Systems CR to further analyze its relevance to the Product issues. Zulevic-Covad stated that it would be fine to leave the CR in Denied status but that he wanted Qwest to consider that there was another ILEC that had voluntarily changed their intervals. He also asked that Qwest reevaluate this request when the flowthrough CR was completed.

Balvin-WorldCom stated that she would like to see a more detailed discussion of the rationale for denying the CR for economic infeasibility. White-Qwest asked if there were any additional questions. There were none. Schultz-Qwest thanked the attendees.

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01/15/03 - CMP Meeting

Smith-Qwest presented the Qwest response. Zulevic-Covad stated that he had forwarded additional information to Qwest after Qwest had distributed the response. He asked if that information changed Qwest’s response to the CR. Smith-Qwest stated that it did not. Buckmaster-Qwest stated that the information had not changed Qwest’s response, that Qwest was exceeding their obligation of parity with retail, and that the request was economically infeasible. She continued that there was an agreement between Qwest and Covad in March 2002 when Qwest had voluntarily revised the interval from 5 to 3 days that Covad would not approach Qwest for another interval reduction. Balvin-Worldcom asked for clarification of the reason the CR was economically infeasible. Buckmaster-Qwest stated that the work to implement the CR was extremely manually intensive and costly, especially in light of the relatively low volume of orders. Balvin-Worldcom asked if there was a systems CR open that might help this process change be less expensive. Zulevic-Covad stated that there was a systems CR open for line sharing flow through. Buckmaster-Qwest stated that the change requested in PC101802-3 would not be facilitated by the systems CR. She stated that this change did not involve order fallouts. She continued that there were three manual changes Qwest would need to make to the IMA system, the FOC system and the Operations system to implement this change. Zulevic-Covad asked if the same cost would apply if the interval were reduced to 4 days. Buckmaster-Qwest stated that the same costs would still apply. She stated that in order for this interval to change in any way, Qwest would have to implement extensive manual handling of orders. She stated that the issue behind the denial of this CR was the amount of manual operations and the relatively low volume of orders. Zulevic-Covad stated that he did not recall any agreement that Covad would not request an additional reduction of this interval. Balvin-Worldcom recommended that the CR remain open for an additional month for Qwest to conduct additional research. Buckmaster-Qwest stated that additional would not change Qwest’s response. Zulevic-Covad recommended rewriting the response to more clearly emphasize the reasons that the CR was economically not feasible. Thomte-Qwest stated that Qwest would hold an ad hoc meeting before the next monthly meeting to discuss this CR. The CR remains in Evaluation.

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12/18/02 - CMP Monthly Product/Process Meeting

Smith-Qwest presented the Qwest response. The attendees agreed to move the CR into Evaluation status.

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11/20/02 - CMP Monthly Product/Process Meeting

Zulevic-Covad presented the CR. He stated that BellSouth already offered shorter intervals, and that Qwest should be able to as well. Burke-Qwest stated that she had no questions. The CR status was updated to Presented.

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CLEC Change Request – PC1018002-3 Clarification Meeting 10:30 AM (Mountain Time) / Wednesday, November 6, 2002

1-877-550-8686 2213337#

Attendees Matt White – CRPM Laurel Burke – Qwest Crystal Soderlund – Qwest Deb Smith – Qwest Mike Zulevic – Covad Make Lanoue - Qwest

Introduction of Attendees White-Qwest welcomed all attendees and reviewed the request.

Review Requested (Description of) Change Zulevic-Covad reviewed the CR. He stated that Covad would most prefer an interval of 1 day, but would be happy with a 2 day interval.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted.

Smith-Qwest stated that the current interval for line splitting and line sharing was 3 days, and the interval for loop splitting was 5 days.

Zulevic-Covad stated that loop splitting was not a product Covad currently used (although that may soon change) and that Covad was OK with an interval other than 2 days for Loop Splitting, but they want some reduction of the current interval. Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Covad’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Burke-Qwest stated that the current Line Sharing CR may be related to this one.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Covad to present the CR at the November Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

AMENDED RESPONSE For Review by CLEC Community and Discussion at the February 19, 2003, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Revised Response - CR #PC101802-3

This letter is in response to CLEC Change Request PC101802-03. This CR is a request by Covad to reduce the interval for Line Sharing, Line Splitting and Loop Splitting from 3 days to 2 days as Covad suggested that BellSouth had done.

This response confirms Qwest’s denial of this CR, for the reasons identified in the January 8, 2003, response, and clarifies the justification for the economically not feasible reason for denial. The following are the major reasons supporting Qwest’s decision to consider the CR economically not feasible:

Line Sharing Volumes: - Total In-Service Line Sharing Orders as of 12/31/02 – 26,083 (average 1,400 incremental lines per month). - Total In-Service UBL* Orders as of 12/31/02 – 483,308 (average 14,000 incremental lines per month). - Line Sharing represents just 5% of the total of these 2 product lines (10% of the average monthly volumes). - This is considered a Low Volume of requests.

Process Changes: - One additional Resource in the Service Center to move Orders more quickly. - A minimum of 60 to 90 additional Central Office Resources across Qwest’s 14 state region to move Orders more quickly. (Line Sharing is currently ordered in 12 of Qwest’s 14 in-region states)

The economic magnitude of adding the indicated resources is too large for the small number of orders. Therefore, Qwest has determined that reducing the interval on Line Sharing orders is economically not feasible. Qwest respectfully declines this change request.

The Line Sharing product is already provisioned in an interval that is shorter than the Retail interval. As the requirement is parity with retail, this requirement is more than met with the current interval.

Qwest continuously evaluates its ability to deliver products in a more timely fashion. If such an opportunity presents itself in the future, Qwest will implement and notify CLECs via the established processes.

Sincerely, Cindy Buckmaster Product Manager

*The comparison made to UBL is made solely on the basis of the functions required to install both services. These functions are comparable for both the Order Processing and Central Office provisioning.

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January 6, 2003

REVISED RESPONSE For Review by CLEC Community and Discussion at the January 15, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Revised Response Response - CR #PC101802-3

This letter is in response to CLEC Change Request PC101802-03. This CR is a request by Covad to reduce the interval for Line Sharing, Line Splitting and Loop Splitting from 3 days to 2 days as Covad suggested that BellSouth had done.

At this time, Qwest has no plans to reduce the interval for the Line Sharing, Line Splitting and Loop Splitting Products. Qwest is denying this request because it is economically not feasible. The following are the major reasons supporting Qwest’s decisions:

Installation intervals for these products were negotiated during the ROC TAG forums held in 2001 and 2002. SGAT Exhibit C Service Interval Tables provides the agreed upon intervals. Qwest will continue to be consistent with these agreements.

Qwest retail interval for the DSL product is 5 business days. As the wholesale interval is already less than retail, Qwest is not inclined to reduce the wholesale interval further. This is consistent with the discussions that took place with the CLECs earlier in 2002, when Qwest reduced the interval from 5 to 3 business days on Line Sharing and Line Splitting.

Both system and process changes would be required. System changes are required any time an interval is modified. These system changes are both manually intensive and time consuming, therefore costly. Due to low volumes of new Line Sharing and Line Splitting requests, and the lack of Loop Splitting requests, changes to the system for the small volume of Line Sharing products would be prohibitive. (The Line Sharing, Line Splitting and Loop Splitting products represent less than 5% of the total product volumes.) In addition, Qwest processes cannot guarantee a 2-business day interval causing potential problems with missed commitments for the end user customer.

Upon reviewing BellSouth’s service interval guide, Qwest has found that Qwest is already providing a comparable interval to BellSouth’s, if not superior in some cases. BellSouth applies their interval differently than Qwest. BellSouth applies their 2-business day interval after the request goes through their LSR processing interval. The LSR processing interval ranges from 10 business hours (or 1 business day) to 24 business hours (or 2 ½ business days). Total order completion interval for BellSouth is their service interval added to their LSR processing interval, which is 3 – 4 ½ business days. Qwest, on the other hand applies their 3 business day interval at the time the LSR is received (application date). Qwest includes the LSR processing time within their 3-business day interval; thus Qwest’s total order completion interval is 3 days.

In any case, it is Qwest’s understanding that BellSouth applies the interval that matches their retail offering. Qwest’s retail offering is currently 5 business days.

Therefore, Qwest respectfully declines this change request.

Sincerely, Debra Smith Product Manager

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December 6, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at the December 18, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101802-3

This is a preliminary response regarding Covad CR PC101802-3.

Qwest has reviewed the current Line Sharing provisioning interval. There are a number of issues to be analyzed in answering this request. For this reason, Qwest would like to move this Change Request into the Evaluation Status to provide a complete answer to this request.

Qwest will provide a status update at the January CMP meeting and will outline their response at that time.

Sincerely,

Debra Smith Product Manager Qwest Corporation

Open Product/Process CR PC102102-1 Detail

Description Of Change

Expected Deliverable

April 1, 2003

Original Request: Covad requests that our collocation DS0 tie cables be inventoried in both TIRKS and SWITCH/FOMS so that we can use our available inventory of tie cables for either Line Sharing or UNE/second line DSL services. Currently, we must designate the type of service we intend to provide on each cable in advance and if we find we need to re-designate the use of a specific tie cable, we are assessed a cable reclassification charge. The concept of dual inventorying has been proven in SBC and is no longer an issue. Having to declare the use of tie cables in advance greatly inhibits our ability to efficiently use our investment in tie cable.

Expected Deliverable

Dec. 1, 2002

Status History

Project Meetings

Cook-Qwest presented the Qwest response. White-Qwest recommended the CR be placed in Evaluation status when it is crossed over. Zulevic-Covad stated that this was fine. The CR was crossed over to systems with a status of Evaluation.

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Ad Hoc Meeting 1:00 PM (Mountain Time) / Monday, January 6, 2003

Attendees Matt White – Qwest Jeff Cook – Qwest Becky Neesen – Covad John Berard – Covad Kim Issacs – Eschelon Bonnie Johnson - Eschelon Sharon Van Meter – AT&T

Introduction of Attendees White-Qwest welcomed all attendees and described the purpose of the meeting. He explained that Qwest and Covad had had further discussions about the request over the last several weeks and that Qwest had identified several differences between Qwest and SBC’s architecture that made the request, as written, difficult to implement. After discussion of these differences, Covad had revised their description of change. White-Qwest asked Cook-Qwest to describe the network architecture differences. Cook-Qwest explained the differences between the Qwest network architecture and the SBC architecture. He stated that in order to grant the Covad request as it was currently written Qwest would have to rewire much of its existing network in order to allow CLECs using Common Area Splitter Collocation the ability to use its DSL terminations from the DSLAMs for either xDSL Unbundled Loops or Line Sharing-type services. He stated that he had some questions about Covad’s request as it pertained to their intentions to use it to provision xDSL Unbundled Loops through the data only 410 termination block.

Neesen-Covad stated that her understanding was that this request now asks that Covad will be able to look up all future and presently unused facilities on the same functionality. Cook-Qwest stated that this was his impression. Neesen-Covad asked if this only applied to collocated splitters or for both collocated and common area splitters. Cook-Qwest stated that it only applied to only collocated splitters. Neesen-Covad stated that Covad has set a soft due date of April 1, 2003. She explained that Covad is doing an internal OSS change and may end up changing the date.

White-Qwest stated that Qwest’s analysis had revealed that in order to fully meet Covad’s request there were IMA changes that needed to be made. He explined that this required the CR to be crossed over into the systems side of CMP. Berard-Covad asked for an explanation of the IMA implications. Cook-Qwest stated that Qwest was looking at doing a dual look into both inventories and implementing an up-front ability to look into both systems on a pre-order basis.

Neesen-Covad stated that Covad’s original objective was to minimize collocation costs, use existing inventory on command and reduce wiring errors. Berard-Covad asked how this would work to convert existing blocks? Jeff-Qwest stated that there had been no discussion of blocks would be converted. He explained that if a block used a common area splitter, it would not be converted.

White-Qwest asked if there were any other questions. There were none. White-Qwest thanked the participants and adjourned the meeting.

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Additional Clarification Meeting 2:00 PM (Mountain Time) / Thursday, January 2, 2003

Attendees Matt White – CRPM Jeff Cook – Qwest Scott Sharket – Qwest Mike Zulevic – Covad Becky Neesen – Covad

Introduction of Attendees Cook-Qwest welcomed all attendees and reviewed the request and his reason for calling the meeting. He explained the differences between the Qwest network architecture and the SBC architecture. He stated that in order to grant the Covad request as it was currently written Qwest would have to rewire much of its existing network in order to allow CLECs using Common Area Splitter Collocation the ability to use its DSL terminations from the DSLAMs for either xDSL Unbundled Loops or Line Sharing-type services. He stated that he had some questions about Covad’s request as it pertained to their intentions to use it to provision xDSL Unbundled Loops through the data only 410 termination block.

Zulevic-Covad stated that Covad was trying to establish a situation where Covad could convert existing DSO’s to line sharing without extensive delays.

Neesen-Covad stated that Qwest currently enforces a 90 day interval and completed work often includes errors.

Cook, Zulevic and Neesen discussed several potential ways to overcome the gap between the request and what was physically possible on the Qwest network. The three agreed that this request would be better implemented of the description was rewritten to be more forward looking.

Sharkey-Qwest asked if Covad was interested in this functionality for pre-order as well as ordering.

Neesen-Covad stated that they were.

White-Qwest stated that he and Cook would revise the Description of Change and forward it to Zulevic and Neesen for review.

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12/18/02 - CMP Monthly Product/Process Meeting

Cook-Qwest described the CR and presented the Qwest response. Zulevic-Covad stated that if Qwest had any questions when it was deciding options to pursue it should contact Covad for an ad hoc meeting. Van Meter-AT&T asked that she also be included in the ad hoc meeting. She also asked how Qwest would determine the best solution. Cook-Qwest stated that Qwest would decide based on the most efficient option that fully satisfied the CLEC request. Balvin-WorldCom stated that Qwest should document all the options it is considering and why it chooses to pursue, or not pursue, each. Zulevic-Covad stated that he would like to see this option because Covad may opt to use the SCRP to fund a systems change that Qwest feels is too expensive. White-Qwest stated that he would work with Cook-Qwest and Zulevic-Covad to set up an ad hoc meeting. The CR was moved into Evaluation status.

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11/20/02 - CMP Monthly Product/Process Meeting

Zulevic-Covad presented the CR. He stated that SBC had already allowed its wholesale customers to do a one-time conversion of DSO tie cables to both databases for no charge. Cook-Qwest stated that he had no questions. The CR status was updated to Presented.

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CLEC Change Request – PC102102-1 Clarification Meeting 2:00 PM (Mountain Time) / Wednesday, November 6, 2002

1-877-550-8686 2213337#

Attendees Matt White – CRPM Jeff Cook – Qwest Brett Fesler – Qwest Mike Zulevic – Covad Becky Neesen – Covad

Introduction of Attendees White-Qwest welcomed all attendees and reviewed the request.

Review Requested (Description of) Change Zulevic-Covad reviewed the CR. He stated that there is a delay if Covad uses the existing inventory for tie pairs with line sharing because the pairs need to be reclassified from UNE to line sharing. He stated that this was because Qwest maintains two different databases for the two inventories. He continued that there was a similar problem at SBC until SBC solved by adopting a dual inventory system where the same pairs were inventoried in TIRKS and SWITCH/FOMS. He summarized that Covad wanted some way to utilize tie cables from either service without additional cost of delay to transfer.

Zulevic-Covad stated that he had recently come from a meeting with Steve Nelson. He stated Nelson was aware of this CR and would probably send someone to work on it.

Fesler-Qwest stated that he worked with Nelson’s group and was the product SME for this CR.

Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted. Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Covad’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Covad to present the CR at the November Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

REVISED RESPONSE For Review by CLEC Community and Discussion at the January 15, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Revised Response - CR #PC102102-1

Qwest conducted a meeting on January 6th to discuss with the CLECs Covad’s request for dual inventory of tie cables. From this meeting, it was determined that one solution to Covad’s request is to have the IMA systems automatically check SWITCH and TIRKS to ensure that the requested pair is not in use in either system. This verification will be required on all Line Sharing, Line Splitting, Loop Splitting (excluding orders requesting the use of Common Area Splitters), and xDSL capable loops. Qwest recommends that this CR crossover to become a Systems CR. It should be understood that Qwest cannot agree to implement this solution until Qwest determines its operational functionality and/or the cost associated with it.

Sincerely,

Jeff Cook Staff Advocate – Policy & Law

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December 6, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at the December 18, 2002, CMP Product/Process Meeting

Mike Zulevic Director - GEA Covad Communications

SUBJECT: Qwest’s Change Request Response - CR #PC102102-1

Currently, Qwest does not have an automated process in place to inventory the DS0 terminations in both the TIRKS and SWITCH systems. Duplicating DS0 terminations in both systems requires there be a mechanism to synchronize assignments for DS0 terminations between the systems. As a result, manual processes would be necessary to ensure the DS0 inventories in TIRKS match those in SWITCH.

To better understand this issue and to gain clarity around how SBC has successfully employed this capability, Qwest pursued a very high-level explanation from SBC of the SWITCH/TIRKS enhancements implemented by SBC. While on the surface it appears that SBC does maintain a dual inventory of DS0 terminations, Qwest has not yet been able to determine how SBC maintains the data in both systems to ensure inventory consistency and accuracy.

Qwest would like to move this Change Request into the Evaluation Status in order to explore the potential options available to address this request. Qwest will provide a readout of where we are at the December CMP meeting and will outline the next steps to be accomplished at the January CMP meeting.

Sincerely,

Jeff Cook Staff Advocate – Policy & Law Qwest

Open Product/Process CR PC122302-1 Detail

Description Of Change

Covad requests that Qwest remove DAML's at locations where the end users are currently only served one voice line to the premise. In addition, Covad would like Qwest to create a process where we can request the removal of a DAML when the customer is currenlty using their second line for dial up and are now seeking DSL.

DAML - Digital Added Main Line

Expected Delivery:

A process to flag DAML's that are currently only serving one voice line that is served via a DAML and allow for the removal of the DAML in the placement of the DSL order. (This order should be allowed to be placed against DAML's that have one or two working voice lines to the premise.

Status History

Project Meetings

04/16/03 - April CMP Meeting PC122302-1: Removal of DAMLs to allow installation of DSL

Jamal B – Qwest advised this report is available on the ICONN web site as of today. The CLEC can access by wire center/TN. This CR will move to CLEC Test and potentially close in May. John Berard – Covad asked if there is a DAML against the order and there is 1 line or DAML is removed, do we get a jep back? Jamal replied that if you place an order and line has a single line DAML the order will be jep. For the double line DAML the order will be rejected. Mike Zulevic asked what the intervals are. Jamal advised removal of a DAML is 5 days, and conditioning interval is 15 days. Mike asked if the process is going to be documented in one place with dates for each procedure. Cindy Buckmaster replied there is a link from the PCAT to the assignments document. This discussion will continue when we get to the CR that this conversation relates to.

03/19/03 - CMP Meeting Neil Houston – Qwest reported the CR has been accepted and Qwest also has initiated a CR that addresses this. Neil reported we are currently developing a process for flagging DAMLs and this will be placed on the ICONN web site by April 15, 2003. Mike Zulevic asked when the prototype will be ready. Neil advised approximately 2 weeks. We agreed to move this CR to Development status until April 15 and then move to CLEC test.

02/19/03 - CMP Meeting

Neil Houston–Qwest provided the initial response to this CR. Qwest advised we do not presently remove DAMLs for our retail customers. However, should Qwest change this policy Qwest will remove DAMLs for Wholesale customers in substantially the same time and manner. Qwest advised they are reviewing this in more detail. Qwest also described how the CLECs can use the Raw Loop Data Tool to determine the presence of a DAML. Qwest advised this CR will stay in evaluation status until our analysis is complete. An update will be provided at the March CMP meeting. Mike Zulevic-Covad clarified they would like to request the removal of DAMLs when there are 2 lines, one is disconnected and the 2nd line is used for high speed data transmission.

01/15/03 - CMP Meeting

Zulevic-Covad presented the CR. The CR moves to Presented.

Clarification Meeting January 8, 2003 1-877-561-8688 7385723# CR PC122302-1 Removal of DAMLs to allow installation of DSL

Attendees Name/Company: John Berard Covad Neil Houston Qwest Russ Urevig Qwest Brett Fesler Qwest Heidi Moreland Qwest Cindy Macy Qwest

Meeting Agenda: 1.0 Introduction of Attendees Team members introduced themselves. Neil Houston will be the lead SME on the CR

2.0 Review Requested Change John Berard Covad reviewed the CR with the team. We discussed what DAML (Digital Added Main Line) or UDC (Universal Digital channel) technology is. John and Russ explained it is a piece of network equipment that is placed on a facility. It multiplexes the TN across the facility so the provider is able to service multiple lines from one facility (analog service is provided). John explained 2 situations how this service could be used: 1st- end user that has a second line in house and provided a UDC. This 2nd line has been disconnected but is being serviced via a UDC and now the customer wants DSL. We would need to disconnect the UDC.

2nd-end user has 2nd line served over UDC and is using a dial up and now wants DSL. We would need to convert or disconnect the UDC.

Qwest confirmed to remove the UDC it would require a dispatch

Qwest should be able to identify if the customer has UDC via LFACS and Raw Loop Data Tool. It is identified as a carrier, not via a usoc on the CSR.

The team clarified this CR only applies when the end user who has a UDC is the only customer on the line. If the end user had a second line and the UDC is servicing more than one customer we could not remove the UDC. This CR would only apply to single customer situations.

Qwest asked John to provide examples / account information of customers that have UDC so we can investigate this CR and determine what the account looks like in our systems and identify the impacts of this CR. John will send to Cindy Macy-Qwest account examples. Accounts in different states would give us the best sample to investigate. We would like data on UDC that serve 1 and 1+ customers in multiple states.

Heidi Qwest asked if other ILEC/CLECs provide this data and Neil Houston advised Bell South may provide this data.

3.0 Confirm Areas & Products Impacted Unbundled Loop, Lineshare DSL, Line splitting, Distribution Feeder, Customers with existing service or service already in place at location. Pre Ordering, Ordering, Provisioning IMA EDI GUI and Bulk Extract Pre Qual Database and EDI

4.0Confirm Right Personnel Involved Yes

5.0 Identify/Confirm CLEC’s Expectation John confirmed he is looking for a process to FLAG these customers. Potentially something in Raw Loop Data tool that would identify the customer has UDC, or be able to extract data and perform a query against the data to identify the TNs that have UDC

6.0 Identify any Dependent Systems Change Requests none

7.0Establish Action Plan (Resolution Time Frame) Next steps will be for John or Covad representative to ‘Clarify this CR’ at the January CMP meeting. John advised he will not attend the January meeting but Mike Z will be there to clarify the CR. John will send to Qwest Cindy Macy examples of customers with UDC on their service so we can investigate. Qwest will meet internally and begin investigation of this CR to determine the impacts.

CenturyLink Response

March 11, 2003

Covad Communications John Berard

SUBJECT: Qwest’s Change Request Response - CR # PC122302-1 Process to remove DAMLs off line to provide DSL to Qwest Customers

This letter is in response to Covad Communications Change Request (CR) PC122302-1. This CR requests that Qwest create a process to remove Digitally Added Main Lines (DAMLs) off of working residential lines, to enable Covad Communications to provide DSL data service to Qwest’s voice customers.

Qwest uses many different technologies to provision voice services to its end user customers. DAMLs, also known as Universal Digital Channels (UDCs) in Qwest’s Network, are one of these technologies and are deployed throughout the Network to meet growth and service demands for POTS (voice) service. The voice paths that are constructed by use of the DAMLs are local loops and the DAML is an essential element of such loops. In addition to customer requests for POTS voice service, loops derived from DAMLs can be used to provision resold, UNE-P and Internet dial-up services to CLECS.

Qwest accepts this Change Request with the conditions identified below and will remove DAMLs for wholesale customers in the same time and manner that DAML’s are removed for Qwest’s retail customers. This process will align with the process change currently being submitted by Qwest on CR PC022403-7, Perform UDC Removal for Line Shared orders at no charge to the CLEC/DLEC. DAMLs will be removed at no charge and only where the following conditions apply: - Loop used for line sharing will be non-design - DAML serves only one end user customer premise - 2 line DAML only - Only 1 voice line in service (only 1 channel is being used, the other channel is vacant) - 5 day provisioning interval will apply to the orders for DAML removal

This CR also requests that Qwest implement a process to flag DAMLs that are currently only serving one voice line. Qwest is presently investigating the appropriate means to inform the CLECs and Qwest retail of the existence of this situation. This information will be available via the ICONN web site by April 15, 2003.

Qwest requests that this CR remain in the Evaluation Status. Qwest will provide an update at the April CMP.

Sincerely,

Neil Houston Staff Advocate Policy & Law

Cc: Mary Retka

INITIAL RESPONSE For Review by CLEC Community and Discussion at the February 19, 2003 CMP Meeting

February 12, 2003 Covad Communications John Berard

SUBJECT: Qwest’s Change Request Response - CR # PC122302-1 Process to remove DAMLs off line to provide DSL to Qwest Customers

This letter is in response to Covad Communications Change Request (CR) PC122302-1. This CR requests that Qwest create a process to remove Digitally Added Main Lines (DAMLs) off of working residential lines, to enable Covad Communications to provide DSL data service to Qwest’s voice customers.

Qwest uses many different technologies to provision voice services to its end user customers. DAMLs are one of these technologies and are deployed throughout the Network to meet growth and service demands for POTS (voice) service. The voice paths that are constructed by use of the DAMLs are local loops and the DAML is an essential element of such loops. In addition to customer requests for POTS voice service, loops derived from DAMLs can be used to provision resold, UNE-P and Internet dial-up services to CLECS.

Qwest does not presently remove DAMLs for its retail customers in order to provision digital services. However, should Qwest change this policy, Qwest will remove DAMLs for wholesale customers in substantially the same time and manner.

This CR also requests that Qwest implement a process to flag DAMLs that are currently only serving one voice line. Qwest presently has a process in place that identifies the use of DAMLs. The Raw Loop Data Tool (RLDT) indicates the presence of a DAML when queried, the Pair Gain Type field will indicate UDC where the loop is provisioned via a DAML. Additionally, telephone numbers and addresses served by a DAML will indicate UDC in the Terminal I and Cable Name fields.

Qwest requests that this CR be placed in Evaluation Status. Qwest will provide an update at the March CMP.

Sincerely,

Neil Houston Staff Advocate Policy & Law

Cc: Mary Retka

Open Product/Process CR PC123002-1 Detail

Description Of Change

Status History

Project Meetings

This CR was implemented with the changes in PC100401-1XMN.

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04-16-03 - CMP Meeting

Wells-Qwest stated that Qwest would respond to CLEC comments to the changes on 4/28 and implement the changes on 5/13. No status change.

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03-19-03 - CMP Meeting

Anderson-Qwest stated that the documentation in support of this change would be out for CLEC review on 4/1.

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02-19-03 - CMP Meeting

Anderson-Qwest presented the Qwest response. Johnson-Eschelon stated that all she was asking for was for Qwest to document the existing process. She appreciated Qwest’s acceptance of the CR but was curious about why it would take until April 1 to distribute the documentation for review. She asked if it was because the documentation would represent a combined process. Anderson-Qwest stated that Johnson-Eschelon was correct; the integrated process document was more functional but took longer to develop. White-Qwest stated that the CR would move into Development status.

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01/15/03 - CMP Meeting

Johnson-Eschelon presented the CR. CR moved to Presented.

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Clarification Meeting 1:30 PM (Mountain Time) / Friday, January 10, 2003

1-877-550-8686 2213337# PC123002-1; Migrate and move documentation on Qwest Wholesale Web site for the process used when the customer is converting and moving to a different CO and remaining in the same rate center

Attendees Matt White – CRPM Bonnie Johnson – Eschelon Jill Anderson – Qwest Joan Wells - Qwest

Introduction of Attendees White-Qwest welcomed all attendees and asked Johnson to review the request.

Review Requested (Description of) Change Johnson-Eschelon reviewed the submitted description of change. She stated that she just wanted the manual process back out on the web site. Well-Qwest stated that there is a CR that will change the process for Port-In. Once that CR is approved, Qwest may create documentation for both CRs at the same time. Johnson and Wells discussed the means of documenting this change. Wells-Qwest stated that Jill Anderson will take over that piece to get this documented. Anderson-Qwest stated that she had no questions. Johnson-Eschelon described a related process that she would submit a CR for in the near future. Wells-Qwest stated that was fine and that she could take a look at it when the CR came in. Confirm Areas and Products Impacted White-Qwest confirmed that the attendees were comfortable that the request appropriately identified all areas and products impacted.

Confirm Right Personnel Involved White-Qwest confirmed with the attendees that the appropriate Qwest personnel were involved.

Identify/Confirm CLEC’s Expectation White-Qwest reviewed the request to confirm Eschelon’s expectation.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they knew of any related change requests.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Eschelon to present the CR at the January Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

INITIAL RESPONSE For Review by CLEC Community and Discussion at the February 19, 2003, CMP Product/Process Meeting

Bonnie Johnson Eschelon Communications

SUBJECT: Qwest’s Initial Change Request Response - CR #PC123002-1

This change request is accepted. Qwest will add documentation to the Wholesale web site to address this issue. This documentation will be included in a general document, which will also include the Port In Trial process (CR-PC081302-1). Qwest will provide a status of this documentation effort at each Monthly CMP Product/Process Meeting until this change is implemented.

Qwest recommends this CR be updated to Development status.

Sincerely,

Jill Anderson Process Analyst

Open Product/Process CR PC112502-1 Detail

Description Of Change

Expected Deliverable

Document on the Qwest Wholesale web site the existing defined process for correcting an inaccurate CSR prior to conversion (CR 5608163). CLECs have already waited several months for the process. Per the CMP process section 2.4.4 Qwest had an obligation to modify is external as well as its internal documentation and train all appropriate Qwest personnel as to change. If Qwest had done so, Eschelon would not have to train Qwest personnel on the appropriate procedures as it has had to do. Also per section 2.4.4 the documentation and training should have taken place by the implementation date therefore implementation is already past due and should be completed without delay.

Status History

Project Meetings

01/15/03 January CMP Meeting Michelle Thacker with Qwest presented the draft response to this CR and said that CLEC facing documentation changes are already in progress and they are targeted for review January 31, 2003. This CR is in Presented status.

12/18/02 December CMP Meeting Bonnie Johnson with Eschelon presented this CR and explained that CR5608163 was submitted and in response to that CR, Qwest provided two options to correct CSRs prior to customer conversion. Eschelon is asking that the process for updating the CSR be posted on the Qwest Wholesale web site for viewing as soon as possible because the process is not changing, but needs to documented for CLECs. Judy Schultz and Bonnie discussed that this should be a Level 1 change because the existing process is not changing, but is being documented. This CR will move to Presented status.

CLEC Change Request Clarification Meeting

December 4, 2002, 3:00 p.m. (MT) Conference Call 1-877-554-8688 PIN 1930099 # PC112502-1 CSR process documentation to correct inaccuracies for Qwest CSR’s posted on the Qwest Wholesale web site.

Attendees Name/Company: Bonnie Johnson, Eschelon Kim Issacs, Eschelon Monica Manning, Qwest Michelle Thacker, Qwest Linda Sanchez-Steinke, Qwest

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

Review Requested (Description of) Change The description of change requested in the CR was reviewed. Bonnie said the CR is asking for the 2 processes for CSR corrections, described in CR 5608163, be documented on the Wholesale Web site because Eschelon still gets rejects in error and then have to escalate to service management to resolve.

Confirm Areas & Products Impacted Bonnie & Kim indicated that all products are impacted.

Confirm Right Personnel Involved Qwest confirmed that the right personnel were involved in the conference call.

Identify/Confirm CLEC’s Expectation Eschelon would like Qwest to document, on the wholesale web site, the two options for updating a CSR, 1) indication of manual handling with remarks, and 2) opening an escalation ticket with the Call Center. Eschelon uses both processes and still receives rejects in error that are difficult to resolve. Bonnie said that Eschelon knows up front that the CSR is wrong and supp the LSR for manual handling and have received rejects from the SDC and then are told that the customer should call the business office to update the CSR. Eschelon then has to go to the service management team and provide the closed CR number, explain how the process should work, before the CSR gets updated. Kim and Bonnie said they would like to take out the need to escalate these rejects in error and feel that with the previous CR, documentation on the Qwest web site there should have been provided.

Establish Action Plan (Resolution Time Frame) This CR will be presented by Bonnie for review CLEC Community Review at the December CMP Meeting.

CenturyLink Response

DRAFT RESPONSE For Review by CLEC Community and Discussion at January’s CMP Meeting

Bonnie Johnson Sr. Manager ILEC Relations Eschelon

SUBJECT: Qwest’s Change Request Response - CR # PC112502-1 (CSR process documentation to correct inaccuracies for Qwest CSR’s posted on the Qwest Wholesale web site.)

This is in response to Eschelon’s Change Request PC112502-1, requesting that Qwest provide documentation on the Wholesale Web Site that provides details explaining how a CLEC issues an LSR when the CSR has inaccuracies.

Qwest accepts this CR and will update CLEC facing documentation. Updates to Qwest External Documentation are targeted to be available for review by January 31, 2003.

Sincerely,

Michelle Thacker Process Specialist Qwest

Open Product/Process CR PC100102-1CM Detail

Description Of Change

Expected Deliverable:

Qwest will change to a Red Line format for Web Change Notification Forms.

Status History

Project Meetings

12/18/02 - December CMP Monthly Meeting Minutes Qwest-Blackmun explained we are able to update PCATs using Red Lined instead of Green Highlight for Level 1-4 changes. In addition, for Level 1 changes the Web Notification form would not be used any longer. Instead, the PCAT would be updated and posted to the Archive Document review site. World Com-Balvin asked if the History Log would still be referenced and the changed identified on that. Qwest advised yes. The vote process was then explained and conducted. The change passed by unanimous vote 7 ‘Yes’ and 0 ‘No’. White-Qwest proposed the change to the CMP Document be made in combination with the change from CR PC102502-1CM in a January 6, 2003, Level 1 notification. The attendees agreed.

12/10/02 - CLEC / Qwest Meeting to review trial results Held CLEC Meeting and shared Qwest's proposal for changes to the CMP process and described the new method to access Level 1 changes. Qwest agreed we can change to Red Line updates for Level 1-4 CRs. CLECs and Qwest agreed we would vote on the proposal at the December CMP Meeting. Qwest agreed to distribute a Vote Notification by 12/11/02.

11/20/02 - November CMP Monthly Meeting Minutes Qwest advised a trial is underway until November 27 to determine the impact to changing to Red Line format. Due to the trial Qwest is requesting the vote be delayed until after the trial is completed. Qwest explained if we are able to change to Red Lind format a change to the Web Notification process would also need to occur as the Microsoft Word program does not accommodate 'cut and paste' of Red Lined changes from one document to another. If the result of the trial allows Qwest to change to Red Lined format we will also present the suggested change to the Web Notification process. It is anticipated the change for Level 1 Web Notifications would be to post the description of the change and the PCAT document to the web site minus a comment cycle, instead of cutting and pasting the updated sections to the Web Notification form. Eschelon and other CLECs in attendance agreed to postpone the vote until after the trial. Qwest agreed they would offer 3 options for meetings to review the results of the trial. After the results are reviewed a meeting will be held to vote on this CR.

10/31/02 - CLEC Input Meeting held to discuss this CR. Scope was confirmed that this CR affects Web Notification forms and all Levels of PCATs. Green highlighted and Red lined documents were reviewed and compared. Discussion of concerns from CLECs and Qwest occurred. No feasible options were agreed upon during the meeting. Agreement was reached that Qwest would determine if we have any options to present. In addition, Qwest would issue the Vote Notification so a vote could take place at the November Monthly Product Process CMP meeting, if Qwest is not able to determine other acceptable options.

10/16/02 - October CMP Monthly Meeting Minutes Eschelon clarified the CR and reasons for submitting the CR. Qwest confirmed this CR will follow section 2.1 of the CMP process. Agreement was reached on the input approach. Qwest will propose multiple meeting dates. The agreed upon meeting will be held to gather additional data, understand the scope of the CR to make sure the CLEC community is aware of what will be voted on, and potentially identify new options for document updates. The CMP process identifies a vote would not occur earlier than the November meeting. Eschelon requested an example of both update methods (Green highlight and Red Lined) be shared in the meeting. Notification of meeting time options will be sent out via the Notification process.

CLEC Change Request Clarification Meeting Time/Date: 9:30 p.m. (MDT) / Wednesday 9th October 2002 Conference Call-In No.: 1-877-561-8688 7385723# CR No.: PC100102-1CM Change format of the Web change notification form to a Red Line Format

Attendees: Bonnie Johnson – Eschelon Jarby Blackmun – Qwest Mark Coyne – Qwest Cindy Macy – Qwest

Meeting Agenda: 1.0 Introduction of Attendees

1.1 Introduction of the participants on the Conference Call was made and the purpose of the call discussed.

2.0 Review Requested (Description of) Change

2.1 Reviewed the details of the change request and confirmed that Bonnie requested updates to the PCAT be made using Red Line format instead of Green Highlight format. This applies to Level 1- 4 changes. Bonnie sent in a redlined version of the CMP process identifying changes should be made to Level 1, but we clarified she is requesting the change be made to Level 1- 4.

3.0Confirm Areas & Products Impacted It was confirmed that Bonnie is requesting changes to the ‘Notification Process’.

4.0Confirm Right Personnel Involved Jarby Blackmun will be the SME on this CR. Mark Coyne will participate.

5.0Identify/Confirm CLEC’s Expectation Eschelon requests Qwest to change to a Red Line format for Web Change Notification forms (update PCATs using Red Line format, just as Tech Pubs are done)

6.0 Identify any Dependent Systems Change Requests None

7.0Establish Action Plan (Resolution Time Frame) Bonnie will present this CR to the CLEC community at the October 16 CMP P/P Monthly Meeting.

Open Product/Process CR PC070202-1X Detail

Description Of Change

Expected Deliverable

A process to supply CLECs with an "Invoice" of repair charges at the time of the repair visit.

Status History

Project Meetings

08/21/02 - August CMP Meeting Minutes: Qwest reviewed its draft response and advised that this CR would be reviewed in conjunction with other CRs related to trouble tickets, repair charges, etc. scheduled for August 27, 2002. The CLEC participants agreed to have this CR reviewed at that meeting. Eschelon stated that the systems CR timeframe may be too long for Eschelon and would like to see the data that Qwest provides to its retail end users because the retail invoice provides quite a bit of information such as; Name of technician and date. Qwest said that we don’t want to mail an invoice and that the system report may capture data Eschelon would like to receive. Eschelon agreed we don’t want to mail the invoice. This CR was moved to evaluation status.

07/17/02 - July CMP Meeting Minutes: Eschelon presented their Change Request. CR status is clarification

Alignment/Clarification Meeting Conference Call Time/Date: 2:00 p.m. (MDT) / Wednesday, July 10, 2002 Place:TEL: 877.521.8688 Conference Call-In No.: CODE: 7901848 CR No.:CLEC Change Request PC070202-1"Time & Material Repair Charges invoice process"

Kathy Stichter, Eschelon, ILEC Relations Manager Craig Suellentrop, Qwest, 271 Network Technical Regulatory Alice Matthews, Qwest, Process Specialist Michael Keegan, Qwest, CMP Manager

Introduction of Attendees Attendees introduced.

Review Requested (Description of) Change Description: Currently Qwest leaves a "Time and Materials Invoice" with its retail customers during a repair visit when the trouble was not found in the Qwest network. Qwest does not supply anything to CLECs. This "Invoice" would assist Eschelon in reconcilling its bill. Eschelon asks Qwest to develop, document and train an adhered to process to supply CLECs with this same "Invoice" or something similar, with the same detail, that will state the charges that Qwest plans to bill at the time of the repair visit. The "Invoice" should contain the Qwest repair ticket number, the number or circuit ID which was reported in trouble, the customer's name and address, the Qwest technicians name and telephone number, the date, the USOCs that Qwest will bill, the quantity of each USOC, the cost of each USOC, the total cost and the reason for the charge.

Discussion: Eschelon is requesting that the same type of time & material invoice that is generated by Qwest technicians for Qwest retail customers be generated for the CLECs prior to billing and mailed to the CLEC for review and signature.

Qwest indicated that they understood the scope of this CR. Craig Suellentrop will coordinate the production of the Qwest response. N/A

Confirm Areas & Products Impacted Areas Impacted: Maintenance/Repair Products Impacted: Centrex, Unbundled Loop, UNE Loop, UNE-P, Resale N/A

Confirm Right Personnel Qwest confirmed the correct personnel were on the call.

Identify/Confirm CLEC’s Expectation A process to supply CLECs with an "Invoice" of repair charges at the time of the repair visit.

Identify any Dependent Systems Change Requests None

Establish Action Plan (Resolution Time Frame) Eschelon can present this Change Request to the CLEC community at the July Product/Process CMP meeting scheduled for July 17 Qwest will issue draft response to this Change Request by Aug 14 (one week prior to the Aug 21 CMP meeting). Qwest will discuss the draft response at the Aug 21 CMP meeting.

CenturyLink Response

August 13, 2002

DRAFT RESPONSE For Review by CLEC Community and Discussion at August’s CMP Meeting

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Response - CR PC070202-1 “Time and Material Repair invoice process.”

This CR states that “Qwest leaves a ‘Time and Materials Invoice’ with its retail customers during a repair visit when the trouble was not found in the Qwest network.” The CR requests that Qwest “supply CLECs with this same ‘invoice’ or something similar, with the same detail that will state the charges that Qwest plans to bill at the time of the repair visit.”

Qwest does leave a Time and Materials Invoice with retail customers when a repair dispatch will result in a charge. This invoice is informational in nature. The technician that is dispatched leaves it at the premises. The actual bill (for both wholesale and retail customers) is generated through automated systems and manual processes that occur when a technician closes a trouble ticket. Qwest does not have a billing relationship with CLEC end-users; therefore, Qwest’s process is to not leave invoices with CLEC end-users. CLECs may use electronic maintenance and repair systems (CEMR) to view trouble ticket history as it appears in Qwest’s systems. This information would be valuable in disputing or substantiating repair charges.

Qwest does not have an organization that is responsible for collecting and distributing these invoices. Qwest believes that a systems CR should be opened to generate an automated report that would provide CLECs with data regarding maintenance and repair billing in the timeframe requested. A meeting will be scheduled for late August to discuss CR’s involving maintenance and repair billing, including this CR. Further clarification and direction for this CR will be determined after this meeting.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest Susie Bliss, Director-Process Management, Qwest Alice Matthews, Senior Process Analyst, Qwest

Open Product/Process CR PC062702-12 Detail

Description Of Change

Expected Deliverable:

Capture the critical information needed for DSL feature on a Centrex Plus/Centron line. Develop an interim process for the CLEC's to work with repair until that is done. Identify all existing DSL on CLEC's accounts when the fix is in place and populate the information needed in the systems. Identify any other Qwest product this may apply to.

Expected Deliverable:

Update Qwest systems to capture the critical information needed for DSL feature on a Centrex Plus/Centron line. Develop an interim process for the CLEC's to work with repair until that is done. Identify all existing DSL on CLEC's accounts when the fix is in place and populate the information needed in the systems. Identify any other Qwest product this may apply to.

Status History

Project Meetings

Mark Coyne-Qwest stated that Eschelon had been contacted regarding this CR and agreed to withdraw this request. This CR will now drop off the list. Bonnie Johnson-Eschelon nodded in agreement. This CR moves to Withdrawn status.

October 3, 2007 Email Sent to Eschelon: Thanks Bonnie. I will place the CR in Pending Withdrawal status; and do the formal withdrawal at the October CMP Meeting. Looking forward to seeing you.

- October 3, 2007 Email Received From Eschelon: Hi Peggy, Eschelon agrees to withdraw this CR per your request based on the fact that Qwest has made changes that provide Eschelon with this information. Bonnie Johnson Director Carrier Relations

October 3, 2007 Email Sent to Eschelon: Good Morning Bonnie, RE: PC062702-12 Update Qwest Back End Systems to Show DSL Feature Information for Repair This email is in regard to a CMP CR that Eschelon submitted, to Qwest, in June 2002, requesting DSL feature information. Attached to this email is a copy of that Change Request. In the 5+ years since this CR was submitted, there have been some changes. The Qwest DSL product was grandparented via PC110205-2 and as of January 28, 2006, Qwest offers Qwest DSL (transport only - no ISP) as a non-common carrier service via a commercial agreement only. Because Qwest DSL is no longer a product that can utilize the CMP Process, will Eschelon agree to withdraw PC062702-12? Thank you, in advance, for your prompt reply. Peggy Esquibel-Reed Qwest Wholesale CMP

12/18/02 December CMP Meeting Qwest Susie Bliss reported that the short-term process is working. The order volume does not justify mechanizing another solution. CLEC Community and Eschelon (Johnson) agreed to move this CR to Deferred Inactive status.

11/20/02 November CMP Meeting

Qwest (S Wells) indicated that the interim process was still functioning. Qwest has a request out to determine the magnitude of change that might be required. That information should be available soon. Qwest (S Wells) indicated that they were expecting some information back from Eschelon. Eschelon indicated that they had responded. Qwest clarified that they were still waiting for concurrence on the list of existing Centrex with DSL accounts. Eschelon indicated that they were having someone look over the list, and would be sending concurrence or additions as soon as possible. This CR will remain in Development status.

10/16/02 October CMP Meeting

Qwest (Wells) provided status on the four components of the CR. Only one component remains open. A response is due in mid October outlining a proposed mechanical solution. The implementation plan will be developed for early November. This CR remains in Development status.

09/18/02 September CMP Meeting Qwest (Bliss) this CR has three components:

1. The interim process: The interim process seems to be working well from a Qwest perspective. A handful of orders came in and have been processed using the interim solution. Eschelon (Bonnie) is aware of the interim process but hasn’t received any feedback from her personnel. Bonnie will use the orders provided by Susie to take back internally for feedback. The interim process is applicable to all CLECs submitting orders that fit the criteria.

2. Long term system solution: Exploration of a mechanized solution is ongoing.

3. Embedded base: This addresses the existing customers, the repair centers need to have the information available, this is not completed but the list of customers will be available soon.

Participants agreed that this CR will remain in "Development" status

08/21/02 - Auguast CMP Meeting Minutes Qwest (Bliss) indicated that the CR was still open. Qwest and Eschelon are ready to trial a manual process that was established on August 6th. On August 6th a request came in from Eschelon but Qwest was unaware the request was to trial this manual process. Qwest is assessing the feasibility of a mechanized solution. Eschelon is working on a forecast to determine if Qwest should pursue a mechanized solution. Meanwhile, Qwest has received a worksheet that identifies all existing DSL on CLEC's accounts and are working towards ensuring the Repair Center has the needed information. This CR was moved to"Development" status.

07/17/02 - July CMP Meeting Minutes: Eschelon (Johnson) reviewed the CR and indicated that the appropriate information does not show up in the repair systems. This problem is not experienced by Qwest Retail customers because Retail does not use DPA. DPA is not a problem in Western region. Qwest (Bliss) indicated that this was an issue that was being addressed by the DSL Swat Team.

7/10/02 Clarification Meeting

Attendees: Bonnie Johnson - Eschelon, Susie Wells - Qwest, Kit Thomte - Qwest, Cindy Schwartz - Qwest, Paulette Westerfield - Qwest, Dan Busetti - Qwest, Jean Novak - Qwest

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

Review Requested (Description of) Change

Bonnie Johnson - Eschelon reviewed the change request. Currently when a CLEC orders the DSL feature on a Centrex Plus or Centron line, the order can be processed and installed but the critical information does not flow through to repair. The result is an inability to get a customers DSL service repaired once installed.

She also said that this problem only applies to the Eastern and Central Regions only.

Confirm Areas and Products Impacted Bonnie Johnson said that the Products impacted are Resale - Centrex Plus/Centron and UNE-P Centrex Plus/Centron

Confirm Right Personnel Involved Susie Wells will be the SME at this time.

Identify/Confirm CLECs Expectation Bonnie Johnson confirmed that Eschelon would like Qwest to develop an interim process that would capture the critical information needed for the DSL feature on a Centrex Plus or Centron line and provide the information to repair.

Identify any Dependent Change Requests Lynn Stecklein advised Bonnie Johnson that Qwest has determined that this change request will be handled as a Product/Process CR. Bonnie Johnson asked why this would not be considered a system request and Lynn Stecklein said that the CLECs do not have access to the interface/system impacted. The interface impacted is internal to Qwest.

Establish Action Plan (Resolution Time Frame) Lynn Stecklein will create a Product/Process CR. This CR will comply with the CMP Product/Process CR process and is eligible for presentation at the appropriate July Monthly CMP meeting

CenturyLink Response

December 10, 2002

Bonnie Johnson Senior Manager ILEC Relations Eschelon

SUBJECT: CR PC062702-12 Update Qwest back end systems to show DSL feature information for Repair

When we discussed this during last month’s CMP meeting, there were two outstanding issues. Those issues and their current status is as follows: 1. What was the long term implementation plan? Current status: we received the estimate for the system changes and the benefits do not outweigh the expenses at this time due to the low volume of orders. We recommend moving this to an inactive deferred status and if the volume of orders get in the range of 400 orders, we would reopen the CR at that time. The existing process that we implemented July 29, 2002 does fulfill the requests of this CR and we have not encountered any problems with the new process. 2. We needed concurrence from Eschelon on the list of existing Centrex with DSL accounts. Current status: Qwest has received confirmation from Eschelon that the embedded base of accounts is in agreement between the two companies.

Given the above, Qwest is recommending that we defer this CR pending a change in order volumes and would like to discuss this during the December CMP meeting.

Sincerely,

Susie Bliss Director Process Management Qwest

-- October 3, 2002

Bonnie Johnson Senior Manager ILEC Relations Eschelon

SUBJECT: CR PC062702-12 Update Qwest back end systems to show DSL feature information for Repair

There are four pieces to the CR. They are: Capture the critical information needed for DSL features on a Centrex Plus/Centron line. Develop an interim process for the CLEC's to work with repair until that is done. Identify all existing DSL on CLEC's accounts when the fix is in place and populate the information needed in the systems. Identify any other Qwest products this may apply to.

The CR is still open. The current status is as follows: Open - Qwest is currently investigating potential implementation of a long term mechanized solution. An automated system solution is still in discovery. Qwest has less than 20 occurrences of the service requirement, both from correction to the embedded base and new service activity. We expect to have system recommendations by October 18 and an implementation plan by November 1, 2002.

Closed - Qwest has developed a manual process by which Qwest's repair personnel will have access to the information they need to take repair reports on DSL service provided with Resold/UNE-P Centrex Plus and Resold/UNE-P Centron. After an order completes in the SOP, Qwest's personnel will manually intervene to stop the order processing before the order posts in CRIS. The repair record is automatically created based on the way the order is written following the manual process. The manual process after the fact is only to get the order to post correctly to generate an accurate CSR. We have successfully trialed the manual process on eight orders that have been submitted by Eschelon.

Closed - Qwest has identified all accounts that required updated repair records, and has issued orders to correct those records effective September 27, 2002.

Closed - This situation is unique only to Central and Eastern Region Resold and UNE-P Centrex and Centron.

Sincerely,

Susie Bliss Director Process Management Qwest

August 13, 2002

Bonnie Johnson Senior Manager ILEC Relations Eschelon

SUBJECT: CR PC062702-12 Update Qwest back end systems to show DSL feature information for Repair

There are four pieces to the CR. They are: Capture the critical information needed for DSL features on a Centrex Plus/Centron line. Develop an interim process for the CLEC's to work with repair until that is done. Identify all existing DSL on CLEC's accounts when the fix is in place and populate the information needed in the systems. Identify any other Qwest products this may apply to.

The CR is still open. The current status is as follows: Open - We are pursing a system solution to capture this information. We are looking at a few possible solutions and will report the current status at the next CMP meeting. Open - Qwest has developed a manual process by which Qwest's repair personnel will have access to the information they need to take repair reports on DSL service provided with Resold/UNE-P Centrex Plus and Resold/UNE-P Centron. After an order completes in the SOP, Qwest's personnel will manually intervene to stop the order processing before the order posts in CRIS. At that time, Qwest personnel will add the appropiate repair organization information to the order. Finally the order will be released to continue through its normal processing and posting to CRIS. We will trial the interim process with Eschelon. Open - Qwest is still looking at how we would identify these accounts and ensure the Repair Center has the needed information. Closed - This situation is unique only to Central and Eastern Region Resold and UNE-P Centrex and Centron.

Sincerely,

Susie Bliss Director Process Management Qwest

Open Product/Process CR PC071202-1 Detail

Description Of Change

Expected Deliverable

A process to ensure that the PON on service orders for Maintenance of Service Charges, Dispatch Charges and Optional Testing Charges include the Qwest repair ticket number so that information is shown on the completion report..

Status History

Project Meetings

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08/21/02 - August CMP Meeting Minutes: Eschelon reviewed their CR requesting that Qwest trouble ticket number be included with their PON because it would provide another piece of information to help Eschelon verify charges. Qwest advised that this CR would be reviewed in conjunction with other CRs related to trouble tickets, repair charges, etc. scheduled for August 27, 2002. The CLEC participants agreed to have this CR reviewed at that meeting and will be changed to evaluation status.

07/17/02 - July CMP Meeting Minutes: Eschelon presented their Change Request. CR status is clarification.

Clarification Call Time/Date: 10:30 a.m. (MDT) / Tuesday, July 16, 2002 Place: Conference Call Conference: TEL: 877.521.8688 Call-In: CODE: 7901848 CR No: PC071202-1 "Use Qwest design services ticket number in the PON on Service Orders for Maintenance of Service Charges, Dispatch Charges and Optional Testing Charges so that information is shown on the completion report."

Attendees: Kathy Stichter, Eschelon, ILEC Relations Manager Alice Matthews, Qwest, Sr Process Analyst - Billing Craig Suellentrop, Qwest, 271 Network Technical Regulatory Bob Mohr, Qwest, Product Manager Michael Keegan, Qwest, CMP Manager

Introduction of Attendees Attendees introduced. Review Requested (Description of) Change Description:

Currently Qwest issues orders to bill Maintenance of Service Charges, Dispatch Charges and Optional Testing Charges for design services trouble tickets when the trouble was not found in the Qwest network. The completion report sent to Eschelon includes a PON TIC and then information. Sometimes that information is a billing telephone number (BTN) and sometimes the information is the Qwest ticket number. During the reconciliation process Eschelon has found that when Qwest uses the Qwest ticket number in the PON it is easier to find the original Eschelon ticket for reconciliation purposes. Therefor Eschelon requests that Qwest implement a process to use the Qwest repair ticket number in the PON so that the PON would be TIC + the Qwest repair ticket number.

Discussion: Qwest asked if the scope of the change request is for the design services side only. Eschelon agreed, and confimed that non design (resale) is excluded.

Confirm Areas & Products Impacted Areas Impacted: Billing and Maintenance/Repair Products Impacted: Unbundled Loop Confirm Right Personnel Qwest confirmed the correct personnel were on the call.

Identify/Confirm CLEC’s Expectation A process to ensure that the PON on service orders for Maintenance of Service Charges, Dispatch Charges and Optional Testing Charges include the Qwest repair ticket number so that information is shown on the completion report.. Identify any Dependent Systems Change Requests None Establish Action Plan (Resolution Time Frame) Eschelon can present this Change Request to the CLEC community at the August Product/Process CMP meeting scheduled for August 21 Qwest will issue draft response to this Change Request by Sep 11 (one week prior to the Sep 18 CMP meeting). Qwest will discuss the draft response at the Sep 18 CMP meeting. Alice Matthews will coordinate the production of the Qwest response.

CenturyLink Response

September 24, 2002

Kathleen Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Revised Response – PC071202-1 “Use Qwest design services ticket number in the PON on Service Orders for Maintenance of Service Charges, Dispatch Charges, and Optional Testing Charges so that information is shown on the completion report.”

This CR requests that Qwest populate the Qwest trouble ticket number as the data in the PON field of service orders issued to generate Designed Services Maintenance of Service, Dispatch and Optional Testing charges. This Change Request was discussed during the CR synergies meeting between Qwest and the CLEC Community on August 27, 2002. During that discussion Eschelon indicated that they issued this Change Request because they are concerned two other CRs: SCR042902-01 and SCR060402-04, may not be implemented or may be delayed. In addition, Eschelon indicated that their solution of choice is for Qwest to provide the CKT ID or Telephone Number, Qwest ticket number, CLEC ticket number and date work was completed on all bill formats (as requested in SCR042902-01 and SCR060402-04).

If implemented, CR PC071202-1, would provide only the Qwest ticket number, which is only one of the data elements Eschelon has specified as critical. With this CR, the Qwest trouble ticket number would appear on the Completion Report in lieu of the account information, e.g., AN, MAN or SBN, that appears today. The implementation of this CR would result in providing different information not more information.

Implementation of this Change Request would require scripting changes to populate the PON field with the Qwest ticket number and, due to PON field character limitations, Qwest would no longer be able to populate the billing account information. Because this CR would change a process changed at the CLEC’s request in February 2002, Qwest asked for feedback from the CMP Community at the September 18th Product and Process CMP Meeting.

At the CMP Meeting, Eschelon agreed to withdraw this CR, and, the Qwest Billing Center will provide the Qwest trouble ticket number on the CLEC spreadsheet until SCR042902-01 and SCR06402-04 are completed.

Sincerely,

Alice Matthews Senior Process Analyst, Qwest

Cc: Sue Burson, Director Process Management, Qwest Alan Zimmerman, Manager Process Management, Qwest Craig Suellentrop, Staff Advocate Policy and Law, Qwest

September 11, 2002

Kathleen Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Response – PC071202-1 “Use Qwest design services ticket number in the PON on Service Orders for Maintenance of Service Charges, Dispatch Charges, and Optional Testing Charges so that information is shown on the completion report.”

This CR requests that Qwest populate the Qwest trouble ticket number as the data in the PON field of service orders issued to generate Designed Services Maintenance of Service, Dispatch and Optional Testing charges. This Change Request was discussed during the CR synergies meeting between Qwest and the CLEC Community on August 27, 2002. During that discussion Eschelon indicated that they issued this Change Request because they are concerned two other CRs: SCR042902-01 and SCR060402-04, may not be implemented or may be delayed. In addition, Eschelon indicated that their solution of choice is for Qwest to provide the CKT ID or Telephone Number, Qwest trouble ticket number, CLEC trouble ticket number and date work was completed on all bill formats (as requested in SCR042902-01 and SCR060402-04).

If implemented, CR PC071202-1, would provide only the Qwest trouble ticket number, which is only one of the data elements Eschelon has specified as critical. With this CR, the Qwest trouble ticket number would appear on the Completion Report in lieu of the account information, e.g., AN, MAN or SBN, that appears today. The implementation of this CR would result in providing different information not more information.

Implementation of this Change Request would require scripting changes to populate the PON field with the Qwest trouble ticket number and, due to PON field character limitations, Qwest would no longer be able to populate the billing account information. Because this CR seeks to change a process changed at the CLECs’ request in February, 2002, Qwest would like to solicit feedback from the CMP Community at the September 18th Product & Process Monthly CMP Meeting before proceeding with this request.

Sincerely,

Alice Matthews Senior Process Analyst, Qwest

Cc: Sue Burson, Director Process Management, Qwest Alan Zimmerman, Manager Process Management, Qwest Craig Suellentrop, Staff Advocate Policy and Law, Qwest

Open Product/Process CR PC093002-06X Detail

Description Of Change

Status History

Project Meetings

-- 10/16/02 October CMP Meeting Michael Buck gave historical information about previous system change request that was denied and said that Qwest had an alternative approach and Eschelon submitted the CR as Product and Process. There was agreement to cross-over the system CR and we will look to close the systems CR. Eschelon presented the CR to the CMP participants and explained that they need associated information to identify correct deaveraging. Qwest had proposed that the web site could have an Excel spreadsheet with the information needed. Dennis Martinez with Qwest asked if the spreadsheet would be static and contain only updates from the LERG. Kathy Stitcher with Eschelon agreed. Qwest understands the requested deliverables and the CR will be updated to Evaluation Status.

10/7/02 Clarification from Kathy Stichter

Kathy Stichter/Eschelon called to confirm that Eschelon did not want the interactive web site. They want the spreadsheet only.

10/7/02 - Clarification Meeting

Introduction of Attendees - Kathy Stichter - Eschelon, Bonnie Johnson, Eschelon, Ric Martin - Qwest, Beth Foster - Qwest, Dennis Martinez - Qwest, Lynn Stecklein - Qwest

Review Requested Change Lynn Stecklein - Qwest reviewed the request. Eschelon is requesting that Qwest provide documentation, in an Excel spreadsheet, on its Wholesale web site which lists each NPA NXX with its associated CLLI and Rate Zone. Currently, Eschelon is using the LERG to get the CLLI information and find it very time consuming.

Confirm Areas & Products Impacted This change request applies to UNE and UNE-P.

Confirm Right Personnel Involved The Product/Process CRPM (Ric Martin) attended the call because this CR will be handled as a crossover to Product/Process.

Identify/Confirm CLECs Expectation Dennis Martinez/Qwest confirmed that Eschelon was looking for Web functionality. Eschelon agreed. Dennis Martinez/Qwest also confirmed that Eschelon wanted the spreadsheet only and did not want interactive functionality. Kathy Stichter/Eschelon said that she would verify and get back to Lynn Stecklein/Qwest. Bonnie Johnson/Eschelon asked if this web site existed. Dennis Martinez/Qwest said that it does not exist today and that he website will most likely be added to the Wholesale web site. Dennis Martinez/Qwest also said that there might be a gap with number portability. Kathy Stichter/Eschelon said that did not appear to be a problem for Eschelon.

Identify any Dependent Systems Change Requests This will be handled as a Product/Process Crossover. This CR is an alternative to a denied CR, SCR061902-01.

Establish Action Plan Lynn Stecklein/Qwest will create the Crossover CR. The Crossover CR (PC093002-06X) will be presented in the October CMP Systems Meeting.

CenturyLink Response

Kathy Stitcher ILEC Relations Manager Eschelon

SUBJECT:Qwest’s Change Request Response - CR #PC093002-06X Request for NPA/NXX with corresponding CLLI and Rate Zone documentation on the Qwest Wholesale Web Site

This CR requests that Qwest provide documentation, in Excel spreadsheet format, on its Wholesale web site which lists each NPA-NXX with its associated CLLI and Rate Zone.

Qwest has investigated the creation of downloadable Excel Spreadsheets that would provide by State, all CLLIs within the state, all NPA/NXX combinations valid for each CLLI, and, the Geographic Deaveraging Zone that is applicable.

It is noted that this information is already currently available. The NPA/NXX can be used to perform a look up on the LERG to determine the associated CLLI or the CLLI can be used to perform a look up on the LERG to determine the NPA/NXXs associated with a particular CLLI. The Qwest web site for Geographic Deaveraging (http://www.qwest.com/wholesale/guides/geozone.html) can be used to view or download a spreadsheet that displays the associated CLLI code and zone.

As a result of this investigation, Qwest must respectfully deny this change request due to legal implications. By providing the information, we would breech our contract and copyright agreement with Telcordia. These restrictions prohibit Qwest from providing the information in the format requested or in any format beyond what is currently provided.

Sincerely,

Elaine Maynard Senior Process Analyst Qwest

Open Product/Process CR PC101402-1 Detail

Description Of Change

Status History

Project Meetings

White-Qwest described the CR and asked Eschelon if Qwest could close the CR. Stichter-Eschelon stated that, during the January CMP Meeting, she had asked if Service Managers would have access to the Billmate information. White-Qwest stated that he had phoned Stichter-Eschelon a week following the January meeting to discuss this issue. He stated that Qwest Service Managers would have access to Billmate information and that Qwest Billing Representatives could add Qwest Service Managers onto calls when CLECs were disputing bills. Masztaler-Qwest stated that Billing Representatives were the CLECs first contact with billing disputes and they would have access to Billmate. If requested, Qwest’s Service Management teams would partner with the Billing Representatives to resolve billing issues. Kriebel-Qwest agreed with this description. Stichter-Eschelon stated that the CR could be closed.

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01-15-03 - CMP Meeting

White-Qwest asked Eschelon if they had had an opportunity to exercise the new process. Stichter-Eschelon asked if Service Managers had access to BillMate. White-Qwest stated that he would check to see if the Service Managers had access to the system and call Stichter off-line. Stichter-Eschelon stated that it was fine with Eschelon if only the Billing Representatives have access to BillMate. CR moved to CLEC Test.

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12/18/02 - CMP Monthly Product/Process Meeting

Kriebel-Qwest described the CR and presented Qwest’s response. White-Qwest proposed that the CR be placed into development status and the Qwest distribute a Level 1 notification to announce the change. The attendees agreed. The CR was moved into Development status.

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11/20/02 - CMP Monthly Product/Process Meeting

Stichter-Eschelon presented the CR. She stated that Eschelon uses Bilmate but the Qwest billing representatives do not, and cannot understand Eschelon’s concerns because they cannot look at the same screen Eschelon looks at. Sear-Qwest asked what Stichter meant by her statement in the CR about “blank spaces.” Stichter-Eschelon stated that this referred to columns in Billmate that were not populated. She stated that the billing representatives could not see these blank fields and Eschelon thought these columns ought to be populated. Schultz-Qwest asked if Eschelon had submitted CRs to address the issue of blank columns. Stichter-Eschelon stated that they had two active CRs out on this issue. Pardee-AT&T asked that this request be expanded to include CRIS and CABS/IABS billing. Burson-Qwest stated that this expansion would require a huge effort and asked Pardee-AT&T to clarify her request. Pardee-AT&T stated that she would like to leave the Eschelon CR as it was currently submitted. Johnson-Eschelon stated that she was concerned about Sear-Qwest’s comment that the Qwest representatives would be unable to assist Eschelon if there was missing information on the bill. Sear-Qwest stated that requests for additional information to be included on the bill should be sent through CMP. Schultz-Qwest stated that if there is additional information needed on the bill it should be requested with a systems CR. Stichter-Eschelon asked if she could ask the billing representatives for additional information in another form, like a spreadsheet. Burson-Qwest stated that she could. Stichter-Eschelon stated that the language in the description of change section the referenced blank or missing columns could be removed. The CR status was updated to Presented.

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CLEC Change Request Clarification Meeting 8:30 AM (Mountain Time) / Tuesday October 22, 2002

1-877-550-8686 2213337# PC101402-1; BillMate access and training for Qwest billing representatives, billing managers and service managers

Attendees Matt White – CRPM Kathy Stichter – Eschelon Carl Sear – Qwest Mark Gonzales – Qwest Paul Diamond – Qwest

Introduction of Attendees White-Qwest welcomed all attendees and asked Stichter to review the request.

Review Requested (Description of) Change Stichter-Eschelon stated that Eschelon uses BillMate files to validate charges, determine amounts to dispute and to determine amounts to submit for payment to Qwest. She explained that Qwest employees do not have access to or training for our BillMate files and that causes confusion between Eschelon and Qwest when trying to reconcile disputes. She continued that when Eschelon calls Qwest asking to have all columns populated in BillMate, or when Eschelon questions rates in anticipation of a potential dispute, or when there is a question as to the charges on the bill, Qwest always asks for examples from Eschelon because the billing representatives can not see what Eschelon sees. She concluded that this creates significant work for Eschelon as Qwest billing figures never match Eschelon billing figures. Eschelon requests that Qwest provide access and training to its employees that interact with Eschelon.

Confirm Areas and Products Impacted White-Qwest asked meeting attendees if the Qwest Service, Account and Billing representatives were the only Qwest representatives impacted. The attendees agreed. Sear-Qwest clarified that there was no system involved and that the bill Stichter was referring to was a file sent to Eschelon.

Confirm Right Personnel Involved White-Qwest asked meeting attendees if the appropriate Qwest personnel were involved. Diamond-Qwest stated that Qwest may need to involve someone from billing after further review of the request and its impacts. Diamond-Qwest asked whom Stichter was dealing with within Qwest. Stichter-Eschelon stated that Eschelon dealt primarily with Terry Clooke, Vicky Keller and Scott Martin in regards to these issues.

Identify/Confirm CLEC’s Expectation White-Qwest asked Stichter if Eschelon's expectation was that all Qwest billing and service representatives who dealt with Eschelon would have access to and be trained on BillMate. Stichter-Eschelon agreed.

Identify and Dependant Systems Change Requests White-Qwest asked the attendees if they were aware of any other CRs related to this request. The attendees stated that there were none.

Establish Action Plan White-Qwest asked attendees if there were any further questions. There were none. White-Qwest stated that the next step was for Eschelon to present the CR at the November Monthly Product/Process Meeting and thanked all attendees for attending the meeting.

CenturyLink Response

RESPONSE For Review by CLEC Community and Discussion at the December 18, 2002, CMP Product/Process Meeting

Bonnie Johnson Eschelon Communications

SUBJECT: Qwest’s Change Request Response - CR #PC101402-1

This is a preliminary response regarding Eschelon CR PC101402-1.

Qwest will arrange for training and access to BillMate ASCII bill files by the Qwest Billing Centers upon request of individual CLEC’s, for the purpose of reconciling bills and disputes. CLEC’s can contact Carl Sear, 303-965-4465, to make the request, with an expected implementation time frame of 60-90 days.

If the volume of requests becomes such that technical restraints become an issue, Qwest will open a change request through CMP.

Qwest recommends this CR be updated to Development status.

Sincerely,

Carl Sear Process Specialist Qwest

Open Product/Process CR PC021502-1 Detail

Description Of Change

January 2002/Qwest’s Minneapolis Orchard Central Office: Qwest's Orchard Central Office is currently under construction for a new addition. That addition includes modification to the existing mechanical system, as well as additional floor space. Eschelon leases space, from Qwest, for a collocation in the Orchard Central Office. During a dispatch, in January 2002, Eschelon's technician discovered dirt, dust and metal shavings on its collocation equipment. Photographs showing the extent of the problem are attached. Qwest would not expose its own equipment to these conditions. Qwest had not notified Eschelon of this construction or the potential impact on Eschelon’s collocation space. When Eschelon discovered the problem, Eschelon immediately contacted Qwest to report the problem, request resolution, and obtain assurances that this serious problem would not be repeated. During later visits to this collocation site, Eschelon discovered excessive temperature levels that could also damage its equipment. Cleaning the equipment required 'powering down' the equipment, resulting in customer outages. Qwest removed all essential cooling to the area and replaced it with a fan, an inadequate solution. Qwest would not find that a fan would be adequate to cool its own equipment. The problem also required one of Eschelon's technicians to be available for the time period while a vendor was completing the clean up. This tied up a technician who should have been doing other work. This incident caused down time for our customers and forced Eschelon to incur unnecessary time and expense and could have caused major damage to our equipment. Eschelon believes that at least two other CLEC collocation spaces were adversely affected by the same construction. Qwest has an obligation to protect the CLEC collocation equipment with at least as much care, as it would use to protect its own equipment. Eschelon asks Qwest for an improved process to ensure that our collocations are protected during construction in any Qwest building that houses one of our collocations.

March 2001/Denver Main Central Office: On March 15, 2001, Eschelon conducted a site survey of its physical collocation located at the Denver Main Central Office. The conditions discovered at the site indicated a deliberate breach in security and potential damage to our equipment. Qwest had not notified Eschelon of this construction or the potential impact on Eschelon’s collocation space. When Eschelon discovered the problem, Eschelon contacted Qwest immediately asking for resolution of the following issues:

1. Eschelon's cage was accessed without Eschelon authorization or knowledge. A Qwest approved contractor removed the pins securing Eschelon's collocation cage to gain access and Qwest security failed to notify Eschelon of the intrusion. Eschelon pays security charges on a monthly basis and expects Qwest to provide and maintain a secure environment. Eschelon told Qwest that this matter is of utmost importance as the integrity of Eschelon's collocation equipment was jeopardized.

2. A 1 inch copper pipe running across the span of Eschelon's cage was installed. The location and height of the pipe severely restricted Eschelon's ability to expand the existing cable ladder racking for future growth. Additionally, the pipe was believed to be a water pipe, which if ruptured, had significant potential for causing damage to personnel and property.

3. There was a significant amount of dust within the cage and on the collocation equipment. This presented an operational issue with Eschelon's hardware and its ability to operate properly. Eschelon asked Qwest to thoroughly clean Eschelon's collocation cage and the surrounding area.

4. There were two additional 1/2 inch copper pipes running across the cage at ceiling height. These pipes also posed a significant problem, as they appeared to be water pipes serving the cooling unit adjacent to Eschelon's cage. The same potential for damage to personnel and property existed.

Both of these examples involved serious problems concerning the integrity of Eschelon's collocation cage. Eschelon had to escalate the issues within Qwest in an attempt to resolve them. An after-the-fact clean up, however, is not a satisfactory remedy. The breaches to security and integrity to the collocation cannot be undone. Eschelon also had to incur unnecessary time and expenses, in addition to its customers experiencing unjustified downtime.

Qwest would not expose its own equipment to such conditions or allow CLECs to treat Qwest’s space and equipment in this same manner. One can only imagine how Qwest would react if a CLEC removed the pins to a Qwest door to get around a lock securing access to the Qwest area of a building. On a much smaller scale, recently, a Vice President of Qwest in charge of Qwest’s network directly contacted Eschelon’s Executive Vice President of Operations and Engineering to allege that Eschelon’s equipment was causing a Qwest fire alarm near Eschelon’s cage to go off. Eschelon was able to show that was not the case. Nothing in Eschelon’s cage had caused the alarm to sound. Eschelon believes that the Qwest fire protection system in that building has had false alarms before, for reasons unrelated to collocation. The mere proximity of a CLEC collocation to a fire protection device that sounded a false alarm was sufficient to draw an immediate call from Qwest’s top management.

In contrast, Eschelon has had difficulty in getting appropriate attention to the very serious issues that have occurred with respect to violations of its collocation space. Eschelon had to expend substantial resources escalating these issues to obtain after-the-fact resolutions. Even after the first situation was resolved, and assurances were received that the problem would not occur again, serious problems occurred again, this time in the Orchard Central Office. In response to its escalation of the most recent situation (Orchard Central Office), Qwest provided Eschelon with a written response that said: “Throughout the life of this construction project, Qwest has insured that all methods of procedures (MOP’s) were followed and that dust protection was appropriate and in place.” Please review the enclosed photographs in light of this statement. Obviously, if following the current procedures at Qwest produces this result, the current procedures are inadequate.

Qwest needs to promptly establish an improved process. Eschelon requests that a solution be developed and implemented quickly to avoid further serious breaches.

The law and interconnection agreements provide support for Eschelon’s request. Examples include:

47 U.S.C. § 551(c)(6): Incumbent local exchange carrier has -- “The duty to provide, on rates, terms, and conditions that are just, reasonable, and nondiscriminatory, for physical collocation of equipment necessary for interconnection or access to unbundled network elements at the premises of the local exchange carrier, except that the carrier may provide for virtual collocation if the local exchange carrier demonstrates to the State commission that physical collocation is not practical for technical reasons or because of space limitations” (emphasis added).

Minnesota Qwest-Eschelon interconnection agreement, Second Amendment: “USW shall provide Collocation in a nondiscriminatory manner on rates, terms and conditions that are just, reasonable and nondiscriminatory.” § 2.1; see also Part A, § 4.

Status History

Project Meetings

February 26, 2002, 12:00 (MT) Conference Call

877-564-8688 PC021502-1, Collocation: Construction Process (in, near or affecting CLEC collocation space)

Attendees: Ric Martin, Qwest Clyde Just, Qwest Laurel Burke, Qwest Chuck Frauenfeld, Qwest Paul Williams, Qwest Deb Heckart, Qwest Steve Sheahan, Qwest Kay Daugaard, Qwest Kathy Stichter, Eschelon Paul Hanser, Eschelon Bonnie Johnson, Eschelon

Introduction of Attendees Introduction of the participants on the Conference Call were made and the purpose of the call discussed Ric advised that there were two issues surrounding the Change Request. The first deals with the issues at the Orchard Central Office and the second deals with the process change requested in the Change Request. Ric advised that it would be best to discuss the first issue in a separate meeting and focus on the process in this meeting. Steve Sheahan would facilitate the meeting with Eschelon personnel with Kathy Stichter. Eschelon agreed with this path forward.

Review Requested (Description of) Change Kathy reviewed the requirements of their CR and their expected deliverable. Bonnie advised that Eschelon was aware that there is a documented process, but the concern is that it is not being followed 100%. Paul Hanser indicated that Eschelon would like to be involved in the planning process and be made aware of the construction activity. They want to know how the equipment is going to be protected and that it is kept cool and clean. Paul indicated that Eschelon would like to be involved in the project planning phase. Paul Williams asked if Eschelon would like to be notified on all construction activity. Paul Hanser indicated that they were more interested in the building construction activity rather than equipment installations. It was confirmed that Eschelon would prefer to be notified when there is facility construction as opposed to equipment installations. Paul clarified that some equipment installations could create a fair amount of dust (i.e. drilling through thick concrete) and they would want to be made aware of this type of installation. Ric confirmed that the process followed for construction activity is Technical Publication 77350. Clyde asked what name would Eschelon want Qwest to contact. Paul Hanser indicated that they would like the name on the emergency list provided to each Central Office, or the 800 number on their Collo cages contacted. This allows the call to go to operations that coordinate Eschelon’s activities. Clyde expressed concern that not all CLECs operate in the same manner. The only consistency is the name on the application. Paul Hanser advised that the person on the application and the associated number may change, but the posted 800 number remains the same. Qwest advised that this could be difficult to get a consistent approach from all CLECs. Ric asked Eschelon if discriminatory meant the same process for all parties involved. Kathy added that all equipment is treated the same for Qwest and CLECs.

Confirm Areas & Products Impacted It was confirmed that the CR addressed Collocation equipment. . Confirm Right Personnel Involved Ric advised that there are several SMEs that will be working on the CR. Laurel Burke will be the Owner identified on Qwest’s reports, but the other SMEs are Howard Cooper, Real Estate, Jerry Jenson, C.O. Staff, and Jeff Bostow, Technical Publications.

Identify/Confirm CLEC’s Expectation Eschelon confirmed that their expectation is their written statement under Expected Deliverable in the Change Request.

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

Establish Action Plan (Resolution Time Frame) Qwest will facilitate a separate meeting to review the Orchard Construction activity. Ric advised that the CR will have the Community CLEC clarification and Qwest will present potential options at the March 20th CMP meeting.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

SUBJECT: Qwest Change Request Response - CR PC021502-1 Collocation: Construction Process (in, near or affecting CLEC collocation space)

This letter responds to Change Request PC021502-1 requesting that Qwest develop a written, trained and adhered to nondiscriminatory process that addresses proper procedures when Qwest and/or its vendors perform construction activities in buildings that house CLEC collocations. Additionally, the two (2) examples described in your Change Request will be addressed in Attachment 1 to this letter.

Eschelon suggested that the process include the following:

1. Improved Qwest process for building construction activity in Central Offices that house CLEC collocations.

Qwest’s process for building construction utilizes a project management approach. Due to the nature of individual building construction activity, project design drawings and specifications documents embody the performance expectations associated with each construction project. The very specific nature of such projects and the quantity of detailed information associated with these projects prohibit Qwest from providing a detailed building construction process in this response. However, Qwest provides below a description of activities common across building construction projects.

Qwest Building Construction Project Management

When a project is initiated, Local Design Construction teams, coordinated by Real Estate Project Managers, develop project plans and specifications in conjunction with Registered Professional Consulting Architects/Engineers and selected Qwest General Contractors. Prior to entering into a contract with Qwest (Real Estate), these consultants and contractors must have a demonstrated track record of proficiency while working with electronic equipment environments. Methods used to demonstrate this include checking work references from other clients and reviewing the contractors project portfolio. Local teams may then choose projects small in scope to evaluate the contractor for larger projects such as Central Office building additions.

The Local Design Construction team assembles the project work scope and customizes it according to the specific project at hand. The documentation and scope of the project work utilizes engineering and operational elements from Qwest policy documents, engineering and operational standards, as well as engineering guideline documentation specifically applicable to Central Office projects. Building environment specifications, or operational standards, commonly contain aspects of several Qwest and industry standards. Examples of these standards include:

? Class 100,000 clean room requirements for airborne particulate control (reference Qwest Regional Policy REGN 000-010-019RG); ? Temperature control requirements meeting industry standards (reference Bellcore (Telcordia) Network Equipment Building Systems (NEBS) document NEBS GR-63-CORE, and REGN 000-010-019RG); ? Technical Publication 77350 for equipment isolation and protection; ? National Electrical Code (NEC) specifications; and ? Project specific Methods of Procedure ("MOP").

Real Estate Consultants and Contractors use Qwest policies and standards in project documents and are held accountable for performing and utilizing these policies and standards. Local Design Construction teams are reminded on each project about the consequences of not following and/or failing to perform to these policies and standards, including the potential for contract termination or probation. In fact, during 2001, Qwest terminated contracts with three (3) real estate contractors and placed two (2) others on probation for failing to adhere to documented policies and standards.

Additionally, before construction begins, an approved MOP document must be posted. The construction contractor must describe all tasks associated with a project that may represent a direct threat to service such as AC Power work affecting DC power and work generating airborne debris open to working equipment, in order to describe the method for protecting the equipment from the threat. The Local Network Central Office Manager and/or Supervisor reviews the MOP and approves the equipment protection strategies - validating that those strategies are present and to be utilized during the construction activity.

Finally, Qwest provides contractors with explicit expectations regarding adherence to standards and an audit mechanism for ensuring compliance. The Introduction to Qwest Technical Publication 77350 provides "the material and workmanship requirements for personnel working in Qwest Central Offices and provide the basis for audit and evaluation of a job." Contractors are individually responsible for adhering to Qwest standards as well as applicable law and industry standards. When work operations jeopardize the network or fail to comply with safety standards, Qwest employees may expel contractors from the facility. Qwest employees are encouraged to stop construction work in progress to question a threat to personnel safety or risk to working equipment. Also, when problems are identified with a specific Real Estate contractor, a thorough root cause analysis is completed and appropriate action taken up to and including termination of a contractor.

2. Provide Advance Notification to and coordination with affected CLECs of construction occurring in Qwest Central Offices containing CLEC collocations. The General Mailout notification process would not be adequate.

Qwest agrees to provide CLECs with an Advance Notification process providing notice of building construction in Qwest Central Offices containing CLEC collocations. Advance Notification will provide targeted email to CLECs collocated in the affected Central Office at the time the project is funded by Qwest. The email, provided by the Collocation Project Management Center ("CPMC") will include the Central Office affected, description of the construction activity, date construction is planned to begin, date construction is planned to complete, and a Qwest contact name and number for the project. The Qwest contact can be used by CLECs to identify environmental issues or concerns during the project. Qwest will also provide status updates in the event the project changes significantly, i.e. the start date is moved forward or the scope of the activity increases. This process will be implemented effective May 2002 or as soon thereafter as possible in compliance with the agreed upon notification schedule. The following real estate work will be the subject of CLEC notifications: ? Building Additions ? HVAC Infrastructure Modifications ? Electrical Infrastructure Modifications ? Building Work for Space Rearrangements or Compartmentation ? Roof Replacement ? Other Building work that could affect the equipment environment

3. Ensure measures are in place to protect the collocation equipment environment including but not limited to protection from:

? Dust ? Dirt ? Metal Shavings ? Adverse Temperature conditions

Qwest contractors performing building construction work within Qwest Central Offices are required to apply appropriate industry standards in an effort to limit and control dust, dirt, metal shavings and temperature variations. As stated earlier, prior to starting any work activity the work steps for protecting working equipment must be documented in a MOP, Method of Procedure. After construction starts and during Real Estate building construction activities, the real estate contractors apply specific environmental requirements as described in the project design and specifications documents.

Qwest requires its contractors to adhere to specific aspects of American Society of Heating, Refrigerating and Airconditioning Engineers (ASHRAE) industry standards as it relates to Class 100,000 clean room requirements (described in Qwest Regional Policy REGN 000-010-019RG). These requirements provide specific airborne particulate standards that in turn are used for isolating working equipment from construction zones. Typically project specifications state that all construction work shall comply with Class 100,000 clean room requirements and must maintain a Class 100,000 environment in the Central Office environment regardless of any activity construction or otherwise. This means that airborne particulates of 0.5 micron and larger cannot exceed a count of 100,000 in one cubic foot of air.

Qwest requires its contractors to meet ASHRAE Class 100,000 requirement by specifying two methods in its project specifications:

? Isolation/Vacuum: Isolate working equipment form the construction zone, pressurize and seal for migration of airborne construction debris; o If isolation is not possible, then directly extract dust dirt and debris by using a HEPA vacuum with the operation of cutting and drilling tools. ? Filtration: If filtration of airborne particulates is questionable then particulate monitoring with instrumentation is used. Particulate counting monitors the environment only at one point in the room environment and is not necessary if the construction zone is isolated.

In addition to ASHRAE requirements, Qwest contractors must adhere to Section 2 of Tech Pub 77350 that specifically addresses Qwest’s expectations of personnel including employees, contractors and suppliers, while performing construction activities within Central Office buildings:

2.3.6 The cutting, filing, drilling, and milling or painting of the Qwest approved auxilliary framing, cable rack, etc., shall be done outside of the equipment area. When drilling of equipment or structures, that can not be removed from the facility, proper protection, and the use of HEPA vacuum shall be required. 2.3.7 General cleaning of the equipment facility or storage area in which work is being done shall be performed by the Service Supplier during the entire installation or removal process. Care shall be taken to generate a minimal amount of airborne dust. 2.3.8 The Service Supplier shall use only a High Efficiency Particulate Arrestor (HEPA) vacuum, capable of filtering particles larger than .3 microns in size, and equipped with a static dissipative hose in QWEST facilities to capture dust and chips from the drilling of floors, walls, ceiling, ironwork, and equipment during the uncrating process, and while cleaning cable racks and equipment. 2.3.9 The Service Supplier shall be aware of conditions that may result in equipment thermal shock (failure or degraded service brought on by a rapid change in temperature) and take steps to prevent its occurrence.

4. Prohibit unauthorized entry into CLEC space and ensure that CLEC security is not breached.

Qwest has documented procedures regarding physical security associated with CLEC collocations. Refer to Qwest’s PCAT under heading Central Office Security.

Additionally, in order to provide more direction to Qwest suppliers performing duties in Central Offices with CLEC collocations, pursuant to the agreed upon notification process, Qwest proposes replacement of Section 16.1.6 of Tech Pub 77350 to read as:

Qwest requires emergency access to all cages for safety purposes. Combination locks (or combination lock-boxes, with a key inside to unlock a keyed padlock) must be provided by the CLEC and attached to each cage. This will provide the Qwest representative with emergency access into the cage when needed. Qwest also requires that the CLEC forward the combination code to its cage lock to the appropriate personnel, e.g., State Interconnect Collocation Manager (SICM). The CLEC’s representative (emergency contact phone number located on the CLEC cage placard) must also retain the combination.

Qwest reserves the right to access CLEC enclosure when work is required in the Qwest-owned space above the cage (this includes access to the overhead ironwork, cable racking, electrical conduit, etc.). CLEC enclosure space will not be entered by anyone, for any reason, without first contacting the CLEC representative and the Qwest State Interconnect Collocation Manager and obtaining the required approval(s).

Qwest is committed to protecting CLEC equipment collocated in Qwest premises when performing activities within a Qwest Central Office that may reasonably be foreseen or predicted to harm such equipment. While Qwest strives to provide an environment for equipment to operate throughout its expected life cycle, it is reasonable to expect that some failures from environmental support equipment or personnel cannot always be avoided. Qwest does require its suppliers (including Qwest personnel) to comply with all published Qwest standards, applicable laws as well as industry standards and disciplines noncompliance. However, since Qwest can not provide a 100% event free environment for its network facilities and equipment, it in turn cannot provide this to CLECs. Nonetheless, Qwest remains committed to protecting and responding to the needs of the CLEC equipment environment with timely responses to correct adverse environmental events.

In response to the two (2) incidents identified by Eschelon in the Change Request, Attachment 1 provides Qwest’s evaluation of the incidents and the corrective action initiated by Qwest.

Sincerely,

Laurel L. Burke Staff Advocate, Policy & Law Technical Regulatory Interconnection Planning Local Networks, Qwest Corporation

cc: Mary Retka, Director, Legal Issues Barry Orrel, Director, 271 Technical Regulatory Paul Williams, Jr, Manager, Real Estate Wolfgang Wiewel, Director, Real Estate

Attachment 1

Eschelon described two locations, Minneapolis Orchard and Denver Main, where they believe Qwest’s current procedures failed to protect Eschelon's equipment effectively resulting in discrimination. Qwest’s evaluation and response to the issues are set forth below.

January-February 2002/Qwest’s Minneapolis Orchard Central Office

? Eschelon’s technician discovered dirt, dust and metal shaving on its collocation equipment ? Qwest had not notified Eschelon of this construction or its potential impact on Eschelon’s collocation space. ? During later visits to the site, Eschelon discovered excessive temperature levels that could also damage its equipment ? Cleaning the equipment required “powering down” the equipment which in turn resulted in customer outages ? Qwest removed all essential cooling to the area and replaced it with a fan ? Eschelon provided a technician to be available for the time period while a vendor was completing the clean-up ? Eschelon believes that at least two other CLEC collocations spaces were adversely affected by the same construction ? Qwest has an obligation to protect the CLEC collocation equipment with at least as much care as it would use to protect its own equipment ? Dust problem continued after the professional cleaning of the equipment. ? The lack of environmental control at this Qwest C.O. disturbs Eschelon. Eschelon does not believe Qwest equipment is subjected to similar environmental conditions. ? Eschelon requires that Qwest take immediate action to have their equipment cleaned again by a professional service. ? Eschelon will be submit their internal cost to Qwest for our clean-up effort ? Dust was also observed on other CLEC’s equipment.

Qwest Response:

Qwest Real Estate completed a root cause investigation of the Orchard environmental event and discovered the following:

? Project documentation for the construction related activity conveyed the proper information about Class 100,000 clean room requirements and the proper environmental temperature control requirements to the supplier. ? An approved MOP was in place identifying the required protection for working equipment ? Contractor provided protection in the form of dust partition walls separating the construction zone from working equipment. ? Contractor provided supplemental cooling equipment with the proper high efficiency filtration for temperature and airborne particulate control. ? Contractor failed to achieve proper room pressurization to prevent particulate migration from the construction zone to working equipment. ? Contractor failed to recognize the lack of room pressurization after the first event and a repeat of the migration occurred within days after the first event. ? The lack of proper pressurization was caused by incorrect placement of temporary floor fans and created improper air-flow and pressurization in the working equipment area. Incorrect fan placement provided a recirculating air-flow which allowed transport of airborne and non-airborne construction debris to the working equipment area.

Qwest Real Estate completed a root cause investigation of the Orchard environmental event and concluded the following:

? Qwest Real Estate concluded the root cause was contractor error, meaning the contractor was provided with appropriate environment specifications to protect equipment but did not perform to those specifications. ? Qwest confirmed that air filtration and temperature control was adequately provided in all areas of the Central Office and that the same high efficiency filtration was provided to the CLEC area during construction activity. ? It was observed that Qwest equipment was also soiled due to particulate migration from construction activities. ? The contractor did provide proper pressurization and sealing procedures in the MOP but failed in the attempt to properly pressurize and seal the working equipment area from the construction zone. ? While it was observed that measures were in place and seemed to be properly applied, the contractor failed to identify the recirculating air flow/ negative pressurization that resulted in subsequent environmental problems a few days later.

Qwest action taken:

? Contractor has been placed on probation. ? Lack of information to the contractor was not an issue, but Qwest will verify going forward that all construction documents contain the Class 100,000 clean room requirement with improved awareness. ? Temporary air flow, pressurization and sealing of construction zones will be added as specific MOP check list items to address and will be standard for all projects requiring construction zone isolation. ? Placement of floor fans and other temporary cooling equipment will be secured to prevent tampering. ? Contractors will be reminded that they are responsible for placement and operation of all temporary air movement as well as pressurization equipment to achieve and maintain environmental conditions. ? The MOP will require contractors to observe particulate accumulation and soiling of equipment surfaces before and periodically during construction activity and will address reporting this information to the Central Office Manager and the Real Estate Project Manager. ? Advance Notification process will identify people to contact for concerns about construction debris, temperature control and other environmental issues. ? To prevent the potential for pressurization and/or construction zone seal failure, only Real Estate contractors/agents will be permitted to provide fans and/or other means of cooling during construction periods.

March 2001/Denver Main Central Office

? Eschelon’s collocation cage was accessed without Eschelon's authorization or knowledge. A Qwest approved contractor removed the pins securing Eschelon’s collocation cage to gain access and Qwest security failed to notify Eschelon of the intrusion. ? A 1-inch copper pipe running across the span of Eschelon’s cage was installed. The location and height of the pipe restricted Eschelon’s ability to expand the existing cable ladder racking for future growth. Additionally, the pipe was believed to be a water pipe, which, if ruptured, had significant potential for causing damage to personnel and property. ? There were two (2) additional ½-inch copper pipes running across the cage at ceiling height. These pipes appeared to be water pipes serving the cooling unit adjacent to Eschelon’s cage. ? There was a significant amount of dust within the cage and on the collocation equipment. Eschelon asked Qwest to thoroughly clean Eschelon’s collocation cage and the surrounding area.

Qwest response:

The Qwest State Interconnect Manager ("SICM") for Colorado arranged a meeting between himself, Eschelon representatives shortly after Eschelon notified Qwest of the problems in March 2001, the Qwest Real Estate Manager and the contractor performing work in the Qwest Central Office at the time Eschelon voiced their concern. The contractor was remodeling space in the west half of the 7th floor of Denver Main to support future equipment placement in that area.

? The meeting was held at Denver Main and the investigation resulted in the contractor being directed to perform several additional tasks: ? Remove copper pipes placed at the 8' level above the Eschelon cage; ? Place piping pans under the existing water pipes to ensure that no dripping water would fall into Eschelon's cage; ? Have Eschelon's space and equipment cleaned; ? Make arrangements with Eschelon PRIOR to entering their space to correct the pipe related issues; ? Take steps to ensure no further unauthorized entry would occur by adhering to the access guidelines and permissions required. ? The Central Office Supervisor indicated that he had not been contacted by the contractor for permission to enter the collocation cage; he also indicated that he had no way to access the cage as he did not have a combination or the key. Qwest action taken:

? The SICM and the Real Estate Manager reiterated to the contractor that they must have specific permission to enter CLEC space using first the number located on the cage. Product Catalog ("PCAT") language has been provided since this occurrence that clarifies Qwest personnel and vendor roles while working in CLEC physical collocations. Additionally, Qwest proposes to add additional clarity in its Technical Publication 77350 regarding contractor requirements relating to CLEC security while working in Qwest buildings. ? The SICM reviewed collocation access requirements with the Central Office supervisor. ? Qwest employees are now encouraged and expected to question any activity that does not comply with security guidelines. ? Eschelon provided the appropriate access information to the Central Office supervisor. ? Following the submittal of this change request, a Design Construction Director and Project Manager physically confirmed that leak protection had been installed and conforms to that for other equipment in Denver Main. ? The temporary applications of filters for all new ductwork grilles, registers and diffusers will be a MOP checklist item. o Qwest will reconfirm the application of temporary filtration on all new ductwork outlets is contained in construction documents.

Finally, upon acceptance of this response by the CLEC community, Qwest Real Estate will issue a document to alert Qwest Real Estate Design Construction Field Directors of all actions contained in this Change Request response. This alert will require confirmation that all construction documents contain the items specified herein.

Open Product/Process CR PC022802-1 Detail

Description Of Change

Eschelon sent a request on 1/30/02 to convert service for a customer. The conversion to Eschelon Unbundled Loop service was due on 2/9/02. Although the line was equipped with DSL, Eschelon was not aware of the DSL because it was not reflected on the CSR. Eschelon did not find out that the line was equipped with DSL until the conversion had started. It became necessary to push-out the Due Date (DD) for the conversion of this service to a later date, because of the DSL. Eschelon followed a Qwest process by sending a supplement for a DD change and escalating with Qwest. Qwest took down the DSL service. Eschelon opened a repair ticket. Qwest gave a 24-hour commitment. This customer was without their DSL for 24 hours because Qwest had already removed it, not waiting for the conversion to complete. If Qwest had completed the order in the Service Order Processor, the customer could have been without DSL for up to 10 days because the customer would have had to place a new order.

On another LSR to convert both the customer’s voice lines and DSL, with an original DD of 2/20/02, Eschelon issued a supplement for a DD change. Following the Qwest process, Eschelon issued the supplement 2/19/02 at 3:31 PM and escalated with Qwest. The customer’s voice lines remained in service however Qwest took down the DSL service on 2/20/02.

Eschelon asks Qwest to develop, document and train an adhered to process to keep all ancillary services working, as is, until the conversion to the CLEC is complete, accepted and Qwest translations are completed. Eschelon also asks Qwest to include in the process a more ‘real time’ flow of order changes to the departments that provision the DSL services.

Expected Deliverable

A developed, documented, trained and adhered to process to ensure ancillary products, such as DSL, remain working with Qwest until the conversion to a CLEC is complete, the services are working with the CLEC and the conversion is accepted by the CLEC.

Status History

Project Meetings

12/18/02 December CMP Meeting Cindy Schwartze presented the Qwest updated response and said that Qwest had adjusted an internal DSL system to recognize normal processing when Frame Due Time is entered on an order. Frame Due Time (FDT) on orders accepted after 12/17/02 will be recognized in the Qwest internal DSL system. The level 1 notification of this Qwest internal system change was sent on Monday, December 16th and the change was implemented on December 17th. Eschelon suggested that this CR be moved to CLEC Test and the CLEC Community agreed.

11/20/02 November CMP Meeting Cindy Schwartze reviewed the Qwest updated response dated 11/7/02 and said Qwest expects to implement changes 12/15/02. The change will adjust an internal Qwest system to recognize and adjust normal processing when the Frame Due Time is populated and will keep Ancillary services, such as DSL up and working until the CLEC services are installed. This CR will remain in Development status.

- 10/16/02 October CMP Meeting Susie Bliss reviewed the revised response dated October 2, 2002 and said that she had not been made aware of any recent outages since the August 30th outage. Bonnie Johnson with Eschelon said that they are working around the problem. Susie said the technical team recommendations will be made by 10/18/02 and the implementation plan will be developed by 10/30/02. The CR will remain in Development status.

- 09/18/02 September CMP Meeting Qwest provided an update on this CR, which was put into CLEC test at the August CMP Meeting. There was one case where DSL went down in error. Qwest is having a technical meeting later this week to discuss work that needs to be done to resolve the problem and will provide a read-out at the October CMP meeting. Because there is further work required on this CR, Qwest and Eschelon agreed to move this CR to Development status.

-- From: Bonnie Johnson@eschelon.com on 9/3/02 4:48p To: "'ljsanch@qwest.com'" , jlnovak@qwest.com cc: "Clauson, Karen L." , "Knudson, Ronda K." , "Johnson, Bonnie J."

Hi Jean and Linda, I would like to provide you an example of DSL being taken down prior to cut. In this case, the customer was so upset Eschelon had to push the cut. If this customer cancels the conversion I will let you know. I am uncertain who will provide this example to Susie Bliss.

Please read below.

The Perfect Blend DD 8/30/02 @11:30 cst. At ~10:30am TNT was notified by Sales Rep the customer's DSL service was down. Because the customer was so upset about the DSL being disconnected the conversion was put on hold with the Qwest tester and the order was sup'd in IMA for new dd. Qwest DSL repair was contacted, An Eschelon tester stayed on line with repair for ~1 hr until service was re-established. The tester verified with the customer their service was up and running. Roughly 2 hours of downtime for the end user.

Thanks,

Bonnie

08/21/02 - August CMP Meeting Minutes: Qwest provided an update on the DSL SWAT team findings and the process improvements that have been put in place. Qwest requests feedback from the CLEC community on DSL orders disconnected in error. Eschelon said that migration orders were going well and that they have people watching conversion orders. This CR will be moved to CLEC test and Eschelon will let Qwest know of problems.

07/17/02 - July CMP Meeting Minutes: Eschelon stated there are multiple issues associated with DSL. There are weekly calls between Eschelon and their Qwest Service Managers to discuss DSL issues. Eschelon requested to keep this CR in Evaluation status. Qwest asked what it would take in Eschelon’s view to take this CR to completed status. Eschelon replied zero orders going down . Qwest stated that trials on DSL orders have been successfully performed. It was agreed to keep the Eschelon and Qwest teams working closely together on DSL issues. CR status remains evaluation.

Alignment/Clarification Meeting Time/Date:10:00 a.m. (MDT) / Thursday 7 March 2002 Place: Conference Call Conference Call-In No.: TEL: 877.564.8688 CODE: 6265401 PC022802-1 "Qwest services live until CLEC services installed"

Attendees: Kathleen Stichter, Eschelon Tina Schiller, Eschelon Jeffery B. Cook, Qwest Michael Keegan, Qwest Deni Toye, Qwest Russ Urevig, Qwest Brett Fesler, Qwest Michael Whitt, Qwest Cindy Buckmaster, Qwest

Introduction of Attendees Attendees introduced.

Review Requested (Description of) Change Description: When a customer has ancillary products, such as DSL, on one of their lines, it is Eschelon’s understanding that Qwest handles the provisioning of the DSL in a different department, within Qwest, than the normal line provisioning. It has been Eschelon’s experience that the department that handles the DSL does not recognize the FDT on an order and that it does not receive updates to orders as quickly. This will cause the DSL to go down before a scheduled time on a conversion and will also cause the DSL to go down when a supplement to the LSR is issued to change a DD. Eschelon sent a request on 1/30/02 to convert service for a customer. The conversion to Eschelon Unbundled Loop service was due on 2/9/02. Although the line was equipped with DSL, Eschelon was not aware of the DSL because it was not reflected on the CSR. Eschelon did not find out that the line was equipped with DSL until the conversion had started. It became necessary to push-out the Due Date (DD) for the conversion of this service to a later date, because of the DSL. Eschelon followed a Qwest process by sending a supplement for a DD change and escalating with Qwest. Qwest took down the DSL service. Eschelon opened a repair ticket. Qwest gave a 24-hour commitment. This customer was without their DSL for 24 hours because Qwest had already removed it, not waiting for the conversion to complete. If Qwest had completed the order in the Service Order Processor, the customer could have been without DSL for up to 10 days because the customer would have had to place a new order. On another LSR to convert both the customer’s voice lines and DSL, with an original DD of 2/20/02, Eschelon issued a supplement for a DD change. Following the Qwest process, Eschelon issued the supplement 2/19/02 at 3:31 PM and escalated with Qwest. The customer’s voice lines remained in service however Qwest took down the DSL service on 2/20/02. Eschelon asks Qwest to develop, document and train an adhered to process to keep all ancillary services working, as is, until the conversion to the CLEC is complete, accepted and Qwest translations are completed. Eschelon also asks Qwest to include in the process a more ‘real time’ flow of order changes to the departments that provision the DSL services.

Confirm Areas & Products Impacted Unbundled Loop UNE (Unbundled Network Elements) Resale

Confirm Right Personnel Cindy Buckmaster indicated her group will take responsibility for coordinating the response to this CR.

Identify/Confirm CLEC’s Expectation A developed, documented, trained and adhered to process to ensure ancillary products, such as DSL, remain working with Qwest until the conversion to a CLEC is complete, the services are working with the CLEC and the conversion is accepted by the CLEC.

Identify any Dependent Systems Change Requests None.

Establish Action Plan (Resolution Time Frame) Initial Qwest Response to Eschelon will be coordinated/delegated by Cindy Buckmaster. She will attempt to have the draft response issued by April 10.

CenturyLink Response

DRAFT REVISED RESPONSE For Review by CLEC Community and Discussion at December’s CMP Meeting

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT:Qwest’s Change Request Revised Response - CR PC022802-1 Qwest DSL services live until CLEC services installed.

On December 16, 2002 Qwest will send out a Level 1 notification to all CLECs regarding the implementation of this CR. The notification will remind CLECs that the internal DSL system change will be implemented on December 17, 2002. This change will adjust the internal system to recognize and adjust normal processing when Frame Due Time is present on the CLEC order. CLEC orders received after December 17, 2002 with a Frame Due Time will then be recognized by this system.

Sincerely,

Susie Bliss Director Process Management Qwest

- November 7, 2002

DRAFT REVISED RESPONSE For Review by CLEC Community and Discussion at November’s CMP Meeting

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT:Qwest’s Change Request Revised Response - CR PC022802-1 Qwest DSL services live until CLEC services installed.

As Qwest communicated during the October 16, 2002 CMP meeting, we were working with the DSL technical team to develop some options on how we could meet the requests of this CR. We also committed to having an implementation plan developed by 10/30/02.

We have researched our options, developed our implementation plan and are driving towards a solution. Our solution is targeted for implementation no later than December 15, 2002. This solution will adjust an internal DSL system to recognize and adjust normal processing when Frame Due Time is entered on an order. This internal system change will enable the process to keep ancillary services, like DSL, working as is, until the conversion to the CLEC is complete and accepted. This adjustment will also keep ancillary services, like DSL, working as is when supplementing or canceling a disconnect order.

Again, we are committed to identifying and implementing solutions so DSL is kept live during a conversion. We will continue to work with the technical team on this system enhancement through CLEC evaluation to ensure success.

Sincerely,

Susie Bliss Director Process Management Qwest

- October 2, 2002

DRAFT REVISED RESPONSE For Review by CLEC Community and Discussion at October’s CMP Meeting

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT:Qwest’s Change Request Revised Response - CR PC022802-1 Qwest DSL services live until CLEC services installed.

Qwest agreed at the September 18, 2002 CMP Meeting to provide an updated response to Eschelon’s Change Request PC022802-1, which requested the following:

-Qwest develop a process which keeps ancillary services like DSL working as is, until the conversion to the CLEC is complete and accepted. -Qwest develop a process which keeps ancillary services like DSL working as is, when supplementing or canceling a disconnect order.

First, Qwest understands the importance of keeping the DSL live during conversions and is committed to working with customers when outages occur. For the Retail/Resale to UNE-P orders, our July 11th process improvements are still working and 201 orders were processed successfully from July 26 - September 23.

Secondly, Qwest recently had an outage on August 30th. The SWAT team investigated the outage and it was an unbundled loop order with DSL. A Technical SWAT team was then pulled together. This team is identifying short and long term mechanical solutions and will have options and recommendations by October 18th, 2002. From there Qwest expects to have an implementation plan developed by October 30th.

Finally, we are committed to identifying and implementing solutions so that DSL is kept live during a conversion. We will continue to monitor and implement solutions when/if problems arise.

Sincerely,

Susie Bliss Director Process Management Qwest

Open Product/Process CR PC012902-2 Detail

Description Of Change

Status History

Project Meetings

Subject: FW: PC012902-2 System Outage Notification Date: Tue, 9 Apr 2002 14:18:53 -0500 From: "Stichter, Kathleen L." To: tmead@qwest.com CC: "Johnson, Bonnie J."

Todd, If Qwest does not send an Initial Event Notification when it resolves the issue within an hour then I do believe that the Closure Notification should indicate that it is initial and closure. It would decrease confusion. Thanks for the proposal.

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

--

04/09/02 - Reply e-mail from Qwest with modification proposal

Subject: Re: PC012902-2 System Outage Notification Date: Tue, 09 Apr 2002 11:42:43 -0600 From: Todd Mead Organization: Qwest Communications International, Inc. To: "Stichter, Kathleen L." Kathy, I have talked to the people here about this example and they told me the following:

"If an event occurs that is settled rather quickly (within 1 hour), we only send out a Closure Notification since the event has passed. No Initial Notification is required. To decrease confusion, I believe we could accommodate this request by simply checking both the Initial and Closure boxes, and putting the date and time in the Closure Box. But the name of the document and subject line will read Closure only."

Could you let me know if what they propose above will help you. If it does, they can implement immediately.

Thanks

Todd

--

04/09/02 - Update e-mail from Eschelon on System Outage Notification Process

Subject: RE: PC012902-2 System Outage Notification Date: Tue, 9 Apr 2002 10:08:56 -0500 From: "Stichter, Kathleen L." To: tmead@qwest.com

Todd, I am monitoring the process. Qwest sent one Event Notification, which dealt with SOPAD, it was a closure. We never did get the initial. I do not know why.

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

--

02/05/02 - Clarification Meeting conducted with submitting CLEC.

11:30 a.m. (MDT) / Tuesday 05th February 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC012902-2 "System Outage Notification"

Attendees: Kathleen Stichter, Eschelon Ken R. Olson, Qwest Stephen Sheahan, Qwest Monica Manning, Qwest Peter Wirth, Qwest

Introduction of Attendees: Attendees introduced.

Review Requested (Description of) Change: Currently when Qwest's backend systems experience problems or outages that affect CLECs, the CLECs are not notified. This can cause considerable time and energy. For example, sometime around 1/14/02, CARS was experiencing a problem so Service Orders would not post. Eschelon can not complete all of its tasks in its systems to bill a customer until the Qwest Service Order posts. Eschelon starts checking following the fifth business day after the DD and continues to check until the Qwest Service Order posts. This is very time consumming. Requested Deliverables: A process to notify CLECs when a Qwest backend system experiences problems or outages that directly or indirectly affect CLECs.

Kathy Stichter, Eschelon reviewed the CR description. Backend systems identified relating to the CR include CARS and BOSS, with potential others. Ken Olson addressed the Eschelon CARS example. He did provide notification to Eschelon, via e-mail of the outage (01/14/02). Qwest issues notifications to the CLECs for front-end systems when outages occur.

Confirm Areas & Products Impacted: Appropriate products & areas identified in CR.

Confirm Right Personnel Involved: Qwest & Eschelon confirmed appropriate personnel were in attendance; however the Qwest Systems representative did not attend.

Identify/Confirm CLEC’s Expectation: Qwest to evaluate CR. During the February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR; or provide an expedited response to the CR.

CenturyLink Response

Ms. Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

SUBJECT: Qwest’s Change Request Response - CR #PC 012902-2 System Outage Notification

REQUEST: Currently when Qwest's backend systems experience problems or outages that affect CLECs, the CLECs are not notified. This can cause considerable time and energy. For example, sometime around 1/14/02, CARS was experiencing a problem so Service Orders would not post. Eschelon can not complete all of its tasks in its systems to bill a customer until the Qwest Service Order posts. Eschelon starts checking following the fifth business day after the DD and continues to check until the Qwest Service Order posts. This is very time consuming.

RESPONSE: Qwest has developed a new Unplanned Event Notification process that is based upon the newly approved Change Management Process (CMP) guidelines (See Production Support, Section 11.0). This process was launched on February 1, 2002.

Qwest is also completing the Unplanned Event Notification process document that will be available on the Wholesale Web site.

Qwest will continue to send Notifications that specifically correlate to the CMP approved systems.

Sincerely,

Tamara Ames IT 271 CLEC NOTIFICATION TEAM Qwest

cc: Barbara Spence, Director Information Technology, Qwest

Open Product/Process CR PC012902-1 Detail

Description Of Change

Status History

Project Meetings

Announcement Date: March 12, 2002 Effective Date: April 11, 2002 Document Number: PROD.03.12.02.F.00733.UNEC&PDeaverage Notification Category: Product Notification Target Audience: CLECs, Resellers Subject: Updates for UNE-C, UNE-P ISDN BRI and Geographic Deaveraging Beginning April 11, 2002, Qwest will issue updates to its Wholesale Product Catalog that includes new/revised documentation for UNE-C, UNE-P ISDN BRI and Geographic Deaveraging.

The UNE-C PCAT will be modified to include links to the new Geographic Deaveraging PCAT and the CLEC Requested UNE Construction (CRUNEC) process. The UNE-P ISDN BRI PCAT will be updated to include USOCS UGUST, UGUFM on the downloadable USOCs table. The Geographic Deaveraging PCAT will provide general information on Geographic Deaveraging pricing for Unbundled Local Loop, Unbundled Network Elements-Platform (UNE-P) and Unbundled Network Element Combination (UNE-C) with state specific effective dates. Geographic Deaveraging zones may be applied based on distance from the Central Office (CO) or by the wire center.

You will find a summary of these updates on the attached Web Change Notification Form. Actual updates are found on the Qwest Wholesale Web site at these URLs:

UNE-C: http://www.qwest.com/wholesale/pcat/unec.html UNE-P ISDN BRI: http://www.qwest.com/wholesale/pcat/unepisdnbri.html Geographic Deaveraging: http://www.qwest.com/wholesale/clecs/geodeavg.html

You are encouraged to provide feedback to this notice through our web site. We provide an easy to use feedback form at http://www.qwest.com/wholesale/feedback.html. A Qwest representative will contact you shortly to discuss your suggestion.

--

02/05/02 - Clarification Meeting conducted with submitting CLEC.

11:00 a.m. (MDT) / Tuesday 05th February 2002 Conference Call TEL: 877.554.8688 CODE: 3269208 PC012902-1 "Deaveraged Rate Zones by Address"

Kathleen Stichter, Eschelon Bernadette Derlein, Qwest Stephen Sheahan, Qwest Craig Saunders, 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} Description: Loop rates are based upon geographically deaveraged rates, so the rates vary by zone. Eschelon needs to know what rate Qwest will bill for each Unbundled Loop we order. Qwest must have a means of determining the rate zone per address in ordeer to bill the CLEC correctly. Eschelon asks Qwest for the documentation that allows Eschelon to determine where our existing lines and our future lines fall within the zones that have been established for geographically deaveraged loop rates. Such information should be posted on Qwest's Wholesale web page. Requested Deliverables: Easily accessable, user friendly, current and accurate documentation used for billing deaveraged loop rates. This could be by address, wire center, CLLI, so long as it is clear which lines fall within which zones.

Kathy Stichter, Eschelon reviewed the CR description. Bernadette Derlein, qwest indicated that the requested information for AZ, CO, WY & MT may be extracted from IMA when using the "Address Validation" capability, and referencing the RTD fields for the appropriate zone. A cross-reference can then be made to the applicable SGAT, Exhibit A for rates. Spread sheets should have been distributed to the CLECs for the states in the Qwest region containing similar information (Qwest to verify). CLECs will need to otain zone maps from the commission to determine rates using the spreadsheets.

Issues identified in the meeting include: (1) spreadsheet availability [Qwest item] ; (2) zone map availability from commission [Qwest item]; and (3) availability of a web based system for Loop rates [Qwest item].

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 & Eshelon 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 February 2002 Monthly P&P CMP Meeting, Qwest will either solicit input from CLEC community & provide potential solutions to the CR; or provide an expedited response to the CR.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc

SUBJECT: Qwest’s Change Request Response - CR # PC 012902-1: Deaveraged Rate Zones by Address

This letter is in response to your Change Request PC012902-1, requesting documentation to allow CLECs to determine where their existing and future lines fall within the zones that have been established for geographically deaveraged loop rates.

For the states of AZ, CO, WY and MT the zones are distance sensitive from the Central Office to end user premis. CLECs currently can input an end user address through IMA using “address validation”. The RTZ field will populate with the appropriate zone in relation to the address. The CLEC would then cross-reference the zone with the applicable rate either in their contract or SGAT Exhibit A.

For the remaining states (MN, IA, SD, ND, NE, OR, WA, NM and UT) the zones are based on wire center. As Cost Dockets were completed by state the CLEC community received CLEC Notifications in regards to the De-Averaging. In the CLEC Notification, a spreadsheet provided wire center in relation to the zone. The CLEC would then be able to cross-reference the zone with the applicable rate in their contract or SGAT. CLEC Notifications are provided with this response.

In response to this CR, Qwest will provide the CLECs with a spreadsheet that will reflect the zones based on wire center for MN, IA, SD, ND, NE, OR, WA, NM and UT. This information will be located on the Qwest Wholesale Website in April. The URL and the date to be published will be provided to the CLEC Community by March 25, 2002

Zone maps for distance sensitive states AZ, CO, MT, WY are available at the state commissions office. As these maps are not electronic, Qwest will not publish them on the Wholesale website at this time.

Sincerely,

Bernadette Derlein Unbundled Loop Product Manger Qwest

Cc: Cindy Buckmaster, Manager Product Management, Qwest Debra S Smith, Product Manager, Qwest Bill Campbell, Director Product Management, Qwest Todd Mead, Change Management, Qwest

Open Product/Process CR PC050902-1 Detail

Description Of Change

Status History

Project Meetings

Qwest (Dinwiddie) indicated that the revised response discussed in the July Product and Process CMP meeting had been provided to the CLEC community. Eschelon (Johnson) indicated that the CR could move to “Completed” status

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07/17/02 - July CMP Meeting Minutes: Qwest (Dinwiddie) provided an overview of the CR and the initial response that had been provided to Eschelon. Qwest indicated that it does not have a process available to install Retail DSL in a shorter than standard interval. Thus, no expedited process exists for the installation new Resale DSL. However, Qwest recently reduced the interval for both Retail and Resale DSL from 10 days to 5 days. Eschelon (Johnson) indicated that shortening the interval does help and is beneficial. Also inquired if Service Managers could assist with future expedites? Qwest indicated that the Service team had provided assistance in the past and would continue to do so. Qwest (Bliss) iterated that an MCC has been produced to assist SDCs in expediting the restoration of Resale DSL service that was disconnected in error by Qwest. She also indicated that a Swat Team has been established and meets daily to review DSL issues. Eschelon (Johnson) indicated its agreement with Qwest’s approach and requested that Qwest’s initial written response be modified to reflect (a) the process improvements for the expedited reconnection of Resale DSL disconnected in error by Qwest, and (b) the intent of the Service team to remain responsive to expedited installation requests for Resale DSL. Qwest (Dinwiddie) agreed to modify the initial written response. The CR will move to "CLEC Test" and Qwest will provide the revised written response in advance of the August CMP meeting.

Time/Date: 3:00 p.m. (MDT) May 20, 2002 Place: Conference Call-In No.: 1-877 550-868 1885858 CR No.:CLEC CR 050902-1 Change Request Clarification Meeting

Attendees Attended Conference Call Name/Company: Bonnie Johnson Eschelon Senior Manager ILEC Relations Neil Houston Qwest Network Regulatory Cindy Schwartze Qwest Wholesale Process Bob Shaheen Qwest Retail DSL Product Manager Kit Thomte Qwest Wholesale CRPM Linda Miles Qwest Wholesale Process

Meeting Agenda: Offer expedites on Qwest resale DSL feature order Action 1. Introduction of Attendees CRPM introduced all attendees and reviewed the agenda 2.0 Review Requested (Description of) Change The attendees reviewed the Change Request that was submitted by Eschelon.

3.0 Confirm Areas & Products Impacted The attendees agreed that the impacted products would be DSL resale as indicated on the CR.

4.0 Confirm Right Personnel Involved The attendees also agreed that the appropriate subject matter experts were on the call.

5.0 Identify/Confirm CLEC’s Expectation On occasion a DSL Resale is disconnected in error. This could occur for various reasons, such as the DSL being associated with the wrong line on the Customer Service Record. Or the customer makes a change and for some reason Qwest can change the voice order but the system associated with the DSL order aren’t updated in time. Also when requests are submitted to Qwest if the end customer or Eschelon is wanting the service earlier than the ten day interval, no process exists within Qwest to achieve an earlier due date.

The end result for Eschelon is they receive the same answer when they attempt to expedite a due date or disconnect in error.

Eschelons objective is to have a process that will allow CLECs to have an option to expedite when either a disconnect in error occurs or when the customer requires a shorter interval.

Bob Shaheen asked for a clarification regarding moves, is this a Qwest to Eschelon move? It would be the Eschelon customer moving to a new location.

Cindy Schwartze inquired about the types of requests that might be made.. Conversion Qwest to CLEC Disconnect in error New connect

6.0 Identify any Dependent Systems Change Requests Neil indicated that the closure of the other DSL CR 022802-1 might resolve at least one aspect of this CR. Bonnie indicated that a process still would need to be available for those times when a expedite is required.

7.0 Establish Action Plan (Resolution Time Frame) Qwest is prepared to review this CR in a collaborative clarification at the June Product and Process monthly meeting.

CenturyLink Response

Bonnie Johnson Sr. Manager, ILEC Relations Eschelon Telecom 730 Second Avenue South, Suite 1200 Minneapolis, MN 55402

SUBJECT:Qwest’s Change Request Response - CR #PC050902-1 Offer Expedites on Qwest Resale DSL Feature Order

Eschelon’s Change Request petitioned for the following: *Currently Qwest policy does not allow a CLEC to expedite any request to add the DSL feature whether the DSL was disconnected in error by Qwest or the CLEC has a need to expedite the request due to customer needs. DSL is a specific service and not related to the dial tone itself. As a result, in some cases Eschelon customers are negativly impacted without the use of DSL even if they have dial tone. Eschelon requests that Qwest develop, train and adhere to a process to expedite the DSL feature order for Qwest resale DSL. *Qwest will develop and implement an expedite process for the feature order of Qwest resale DSL.

Qwest has documented and communicated several internal process improvements around the restoral of Resold DSL service when disconnected by Qwest in error. This was communicated to impacted Qwest organizations via a Multi-Channel Communicator (MCC) dated 07/16/02, Call Handling Procedures Supporting Resale/UNE P DSL Orders, issued by Michelle Thacker. CLECs should continue to utilize the Expedites & Escalations Overview business procedures document. This document can be accessed at the following link: http://www.qwest.com/wholesale/clecs/exescover.html

Additionally, effective June 21st, 2002, Qwest significantly reduced both the Retail and Resale Qwest DSL standard provisioning interval from 10 business days to 5 business days. This improvement is outlined in announcement PROS.06.26.02.F.00487.SIGUpdateDSL dated May 31st, 2002. The archived announcement can be accessed at the following link: http://www.qwest.com/wholesale/notices/cnla/bysubcat/1,1834,16,00.html

Qwest does not have a process available to install new Retail or Resale Qwest DSL within a shorter than standard interval; however, Qwest’s Wholesale Sales and Service Organization remains available to receive escalation requests on an individual case basis.

The following references are provided for your review:

Qwest Resale General Product Catalog, Located at the following link: http://www.qwest.com/wholesale/pcat/resalegeneral.html *Qwest's retail telecommunications products and services are available for resale by Competitive Local Exchange Carriers (CLECs) to their end-users. The term 'Resale' generally refers to the 'resale' of fully finished Residential, Business, Private Line and Integrated Services Digital Network (ISDN) services. This means that Qwest provides the end-to-end service all the way to the end-user, with your brand instead of Qwest

Template SGAT/Contract Language at 6.2.3: Qwest shall provide to CLEC Telecommunications Services for resale that are at least equal in quality and in substantially the same time and manner that Qwest provides these services to itself, its subsidiaries, its affiliates, other Resellers, and Qwest's retail end users. Qwest shall also provide resold services to CLEC in accordance with the Commission's retail service quality requirements, if any.

Qwest Business Procesures Product Catalog (PCAT) Expedites & Escalations Overview, Located at the following link: http://www.qwest.com/wholesale/clecs/exescover.html * 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; otherwise utilize your normal trouble-reporting channel into the appropriate Center for repair call handling, trouble report creation, status updates, and escalation management. *Expedites: Requests for an improved standard interval, Individual Case Basis (ICB) or committed to ICB (Ready for Service (RFS) + Interval) date Escalations: Requests for status or intervention around a missed date. *Expedites - While Qwest standard intervals, defined in our Service Interval Guide (SIG) identify reasonable intervals, at times a valid expedite situation can occur such as: * Fire * Flood * National emergency * Conditions where your end-user is completely out of service (primary line) * Disconnect in error by Qwest * Requested service necessary for your end-user's grand opening event delayed for facilities or equipment reasons with a future RFS date * Delayed orders with a future RFS date that meet any of the above described conditions. * If an expedite situation occurs, call the assigned Qwest Wholesale Center Representative responsible for processing your service requests. All expedite requests require approval to ensure resource availability. The Qwest Wholesale Center Representative will coordinate with you and Qwest internal organizations to resolve. Expedite charges may apply. If your expedite request is denied, denial reason(s) will be provided. * The PCAT indicates that expedite/escalation requests can be directed to the Wholesale LSR Service Center at 888-796-9087.

Sincerely,

Cliff Dinwiddie Sr. Manager, Product Strategy & Regulatory Support Qwest

July 10th, 2002

Bonnie Johnson Sr. Manager, ILEC Relations Eschelon Telecom 730 Second Avenue South, Suite 1200 Minneapolis, MN 55402

SUBJECT:Qwest’s Change Request Response - CR #PC050902-1 Offer Expedites on Qwest Resale DSL Feature Order

Eschelon’s Change Request petitioned for the following: *Currently Qwest policy does not allow a CLEC to expedite any request to add the DSL feature whether the DSL was disconnected in error by Qwest or the CLEC has a need to expedite the request due to customer needs. DSL is a specific service and not related to the dial tone itself. As a result, in some cases Eschelon customers are negativly impacted without the use of DSL even if they have dial tone. Eschelon requests that Qwest develop, train and adhere to a process to expedite the DSL feature order for Qwest resale DSL. *Qwest will develop and implement an expedite process for the feature order of Qwest resale DSL.

Qwest has formed a DSL Swat team that is meeting daily to investigate root causes of DSL issues raised by customers. Currently, Qwest is reviewing and trialing some improved internal escalation processes around the restoral of Resold DSL service when disconnected by Qwest in error. As we learn more, Qwest will be advising the CLECs of any changes utilizing the existing CMP processes.

Effective June 21st, 2002, Qwest significantly reduced both the Retail and Resale Qwest DSL standard provisioning interval from 10 business days to 5 business days. This improvement is outlined in announcement PROS.06.26.02.F.00487.SIGUpdateDSL dated May 31st, 2002. The archived announcement can be accessed at the following link: http://www.qwest.com/wholesale/notices/cnla/bysubcat/1,1834,16,00.html Qwest does not have a process available to install new Retail or Resale Qwest DSL within a shorter than standard interval.

The following references are provided for your review:

Qwest Resale General Product Catalog, Located at the following link: http://www.qwest.com/wholesale/pcat/resalegeneral.html

Qwest's retail telecommunications products and services are available for resale by Competitive Local Exchange Carriers (CLECs) to their end-users. The term 'Resale' generally refers to the 'resale' of fully finished Residential, Business, Private Line and Integrated Services Digital Network (ISDN) services. This means that Qwest provides the end-to-end service all the way to the end-user, with your brand instead of Qwest.

Template SGAT/Contract Language at 6.2.3: “Qwest shall provide to CLEC Telecommunications Services for resale that are at least equal in quality and in substantially the same time and manner that Qwest provides these services to itself, its subsidiaries, its affiliates, other Resellers, and Qwest's retail end users. Qwest shall also provide resold services to CLEC in accordance with the Commission's retail service quality requirements, if any.

Sincerely,

Cliff Dinwiddie Sr. Manager, Product Strategy & Regulatory Support Qwest

Open Product/Process CR PC053002-1 Detail

Description Of Change

Status History

Project Meetings

Qwest reviewed the draft response. Qwest advised that Designed Services currently accommodate Eschelon’s request. However, the only way to accommodate Non-Designed Services is to create an MCO, and, to do that is not economically feasible due to the volume of calls received. Qwest said that the system CRs assist the dispute process for Maintenance of Service charges and TIC charges. Eschelon said that for Designed Services the Qwest technician very seldom advises if there will be a charge for the trouble ticket, unless Eschelon specifically asks if there will be a charge. Qwest will open a Global Action Item and will evaluate the situation. Eschelon indicated that since a part of the CR was denied, the CR should be status as Denied. It was agreed that the status of this CR would be Denied.

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08/21/02 August CMP Monthly Meeting Minutes

Qwest advised that the response remained the same as last month for Designed Services. The Non Designed Services will be reviewed in conjunction with other CRs related to trouble tickets, repair charges, etc. scheduled for August 27, 2002. The CLEC participants agreed to have this CR reviewed at that meeting. It was agreed that the CR status would be changed to Evaluation.

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07/17/02 - July CMP Meeting Minutes: Qwest presented the initial response as follows: The current repair process for Designed Services Trouble Tickets supports this request by allowing CLECs to dispute charges before they are billed. For Designed Services Qwest uses a Maintenance Control Organization (MCO) to manage trouble tickets. Qwest’s process is to hold a Designed Services Trouble Ticket for two weeks after closure before sending the charges to billing. When Qwest is discussing the resolution of Designed Services Trouble Tickets with the CLEC, the MCO technician will advise the CLEC that charges will be applied. If the CLEC disputes the resolution of the ticket, the ticket will not be closed. If a CLEC was advised during a previous Trouble Ticket that charges would be applied and that ticket has not been sent to billing, the CLEC can dispute that with the MCO technician during a subsequent Trouble Ticket. After the charges have been sent to billing, the CLEC must contact their Billing Representative to dispute any charges.

Because Qwest does not use an MCO for Non-Designed Trouble Tickets, the above process cannot be applied to these tickets. Qwest will continue to investigate alternatives that meet the needs of both Qwest and the CLECs. Qwest intends to respond to this CR regarding Non-Designed Trouble Tickets at the August CMP meeting.

Eschelon asked how Qwest will confirm the CLEC was not charged for the initial trouble ticket when a second trouble ticket for the same problem has been issued. Qwest agreed to investigate. Eschelon stated that the Qwest stated policy of having a closed trouble ticket sit at the center for two weeks prior to it being sent to billing has not been their experience. Eschelon stated they are not allowed enough time to confirm with their customer the problem has been fixed prior to trouble ticket being closed. AT&T stated they are having the same problem. Eschelon would like the opportunity to test prior to trouble ticket being closed. Eschelon asked why can’t Non-Designed Trouble Tickets remain open for 24 hours. Qwest responded there is no place to hold them. Qwest stated the response will be revised in August to address the Non-Design Trouble Ticket portion of this CR. CR status was changed to evaluation.

CLEC Change Request Clarification Meeting

June 5, 2002, 9:00 a.m. (MT) Conference Call 877-564-8688 PC053002-1, Real Time Dispute of TIC, Maintenance of Service Charges and Dispatch Charges

Attendees: Ric Martin, Qwest Alice Matthews, Qwest Craig Suellentrop, Qwest Bob Mohr, Qwest Kathy Stichter, Eschelon

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

Review Requested (Description of) Change Kathy indicated that Eschelon was looking to be able to dispute TIC and MOS charges on a real time basis. They want a process to dispute charges they do not believe are legitimate before they get billed. She explained that she realized that repair personnel close the tickets which get forwarded to the center which in turn gets a service order issued that goes to billing. She also explained that she understood that TIC was for resale (non-design) and MOS was for Design services. She indicated that she realized that there would be two (2) processes involved and that it would be handled differently for each situation. Craig questioned how would they know if there was going to be a charge. Kathy indicated that per Eschelon’s ICA they are to be notified before the ticket is closed. She explained that CEMR provides them with an e-mail notification after a ticket is closed. Ric asked if this was the same for Design and Non-design. Kathy wasn’t sure, but Craig thought it was the same. Kathy was going to investigate. Kathy advised that Eschelon wants a dispute process before the charges are billed and believed it would be best if the process occurred before the ticket was closed. Craig indicated that for loops on the design side, they should be getting a coordinated closure and Eschelon’s Tech shouldn’t agree to close if they felt the charge wasn’t correct. Kathy advised that, for the most part, they are getting a call on design, but cannot get with the customer in a reasonable time that is within the required timeframe. Ric asked if Kathy had received the Question and Answers from the CLEC forums on Maintenance and Repair. In the May Mailout there was a dispute resolution matrix. It was agreed that the CR request was asking for more than what was on the matrix.

Confirm Areas & Products impacted It was confirmed that the products are those covered by Non-Design Services (Resale and Centrex) and Designed Services (UNEs)

Confirm Right Personnel Involved Qwest confirmed that Craig was the Lead SME for this CR. Qwest will need to bring some repair personnel into the evaluation.

Identify/Confirm CLEC’s Expectation It was confirmed that Eschelon was looking for a process to allow them to dispute charges before they get billed.

Identify any Dependent Systems Change Requests Eschelon submitted a Systems CR, SCR060402-04, which has to do with information being added to the bills. Kathy advised that per Alice’s comments at the CLEC forum, the information is not on the bills. Kathy to submit examples to Ric.

Establish Action Plan (Resolution Time Frame) Ric advised that the CR would have the CLEC Clarification at the CMP Meeting on June 19th. After the meeting Qwest will evaluate and present its response by the next CMP meeting.

CenturyLink Response

Kathleen Stichter Eschelon

SUBJECT: Qwest’s Revised Change Request Response - CR PC053002-1 “Real Time Dispute of TIC, Maintenance of Service and Dispatch Charges.”

This CR requests that Qwest develop “a process to allow CLECs to dispute miscellaneous repair charges before Qwest bills them.” During the clarification call with Eschelon and at the General Clarification at the June CMP meeting, the two repair processes (designed and non-designed) and the fact that the solution may be different for the different processes were discussed.

At the July CMP meeting Qwest responded that the current Designed Services process meets this request. Qwest uses a Maintenance Control Organization (MCO) to manage Designed Services trouble tickets. The process for Designed Services is to hold trouble tickets for two weeks after closure before sending charges to billing. When Qwest is discussing the resolution of Designed Services trouble tickets with the CLEC, the MCO technician will advise the CLEC that charges will be applied. If the CLEC disputes the resolution of the ticket, the ticket will not be closed. If a CLEC was advised during a previous trouble ticket that charges would be applied and that ticket has not been sent to billing, the CLEC can dispute that with the MCO technician during a subsequent trouble ticket. After the charges have been sent to billing, the CLEC must contact their Billing Representative to dispute any charges.

Because of the large number of Change Requests related to Maintenance and Repair a meeting was held on August 27, 2002 to discuss possible synergies between the various CRs. It was agreed at the August CMP meeting to defer the response regarding Non-Designed Services trouble tickets until after the August 27 meeting. At that meeting Eschelon agreed that the Designed Services process met their needs. It was also determined that this CR should have its own response to address the Non-Designed process. Qwest agreed to supply a revised response at the September CMP meeting. However, Qwest believes that the Systems CRs CRs SCR030702-1 – CLEC Trouble Ticket Cross Reference and SCR042902-01 – Use CLEC Internal Repair Ticket number on CLEC bill to identify maintenance and repair charges will aide CLECs in auditing their bills and address some of the CLECs underlying concerns.

Because Non-Designed trouble tickets are generally less complex and have much larger volumes, Qwest doesn’t use an MCO technician to manage their closure. For non-designed trouble tickets the technician that resolves the trouble closes the ticket. Any applicable charges are then automatically sent to billing for inclusion on the next bill. Waiting for a customer to clear voice mail and reply back to Qwest before closing a Non-Designed trouble ticket may result in increased resolution time, missed appointments, and technician idle time. It is not economically feasible for Qwest to create a new organization to manage non-designed trouble tickets, and at this time Qwest’s systems are not technically capable of holding non-designed trouble tickets before charges are sent to billing. Therefore, Qwest respectfully denies this request as it relates to the Non-Designed trouble ticket process.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest Alice Matthews, Senior Process Analyst, Qwest Catherine R. Garcia, Lead Process Analyst, Qwest Don Tolman, Manager-Process Management, Qwest

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August 13, 2002

Kathleen Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Supplemental Change Request Response - CR PC053002-1 “Real Time Dispute of TIC, Maintenance of Service and Dispatch Charges.”

This CR requests that Qwest develop “a process to allow CLECs to dispute miscellaneous repair charges before Qwest bills them.” During the clarification call with Eschelon and at the General Clarification at the June CMP meeting, the two repair processes (designed and non-designed) and the fact that the solution may be different for the different processes was discussed.

At the July CMP meeting Qwest responded that the current Designed Services process meets this request. Qwest also said that investigation of alternatives for the Non-Designed Process would continue and further information would be available at the August CMP meeting. However, because of the large number of Charge Requests related to Maintenance and Repair billing, a meeting will be scheduled for late August to discuss all of these, including this CR. Further clarification and direction for this CR will be determined after this meeting.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest

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July 10, 2002

Kathleen Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Response - CR PC053002-1 "Real Time Dispute of TIC, Maintenance of Service and Dispatch Charges."

This CR requests that Qwest develop "a process to allow CLECs to dispute miscellaneous repair charges before Qwest bills them." During the clarification call with Eschelon and at the General Clarification at the June CMP meeting, the two repair processes (designed and non-designed) and the fact that the solution may be different for the different processes was discussed.

The current repair process for Designed Services Trouble Tickets supports this request by allowing CLECs to dispute charges before they are billed. For Designed Services Qwest uses a Maintenance Control Organization (MCO) to manage trouble tickets. Qwest’s process is to hold a Designed Services Trouble Ticket for two weeks after closure before sending the charges to billing. When Qwest is discussing the resolution of Designed Services Trouble Tickets with the CLEC, the MCO technician will advise the CLEC that charges will be applied. If the CLEC disputes the resolution of the ticket, the ticket will not be closed. If a CLEC was advised during a previous Trouble Ticket that charges would be applied and that ticket has not been sent to billing, the CLEC can dispute that with the MCO technician during a subsequent Trouble Ticket. After the charges have been sent to billing, the CLEC must contact their Billing Representative to dispute any charges.

Because Qwest does not use an MCO for Non-Designed Trouble Tickets, the above process cannot be applied to these tickets. Qwest will continue to investigate alternatives that meet the needs of both Qwest and the CLECs. Qwest intends to respond to this CR regarding Non-Designed Trouble Tickets at the August CMP meeting.

Sincerely,

Craig Suellentrop Staff Advocate, Policy & Law Qwest

Cc: Mary Retka, Director-Legal Issues, Qwest Don Tolman, Manager-Process Management, Qwest Alice Matthews, Senior Process Analyst, Qwest

Open Product/Process CR PC053002-1X Detail

Description Of Change

Expected Deliverables: Spreadsheets with rate changes should indicate which USOCs the CLEC is currently ordering. An alternative is that only USOCs that are currently or have been billed by Qwest to CLEC in the past is reflected on the rate notification rate sheet.

Status History

Project Meetings

SCR053002-01 Clarification Meeting

2:00 p.m. (MDT) /Thursday June 6,2002

877 570-8688 Conference ID 7807739 SCR053002-01 Attendees Name/Company:

Kathy Stichter - Eschelon Michael Buck - Qwest Kit Thomte - Qwest Kristen Hathway - Qwest Lynn Stecklein - Qwest

Meeting Agenda: Introduction of Attendees Introductions of the participants on the conference call were made and the purpose of the call was discussed.

Review Requested (Description of) Change Kathy reviewed the change that Eschelon is requesting as follows: Qwest sends a high level notification and then follows with a spreadsheet of the rate change. Qwest is populating the spreadsheet with all of the USOCs that a CLEC is allowed to order via interconnection. Eschelon would like to see somewhere on the spreadsheet which USOCs they are actually ordering.

Confirm Areas & Products Impacted Eschelon verfied that all Products would be impacted with this change request

Confirm Right Personnel Involved All appropriate Personnel were involved

Identify/Confirm CLEC’s Expectation Eschelon would like to see somewhere on the spreadsheet which USOCs they are actually ordering.

Identify any Dependent Systems Change Requests

Michael Buck asked why Eschelon submitted this request as a system change. He explained that a change to a spreadsheet would be considered a process change. Kathy Stichter said that she was not aware that this would be considered a process change or else Eschelon would have submitted a Process CR. Michael Buck said that this change request would be handled as a Cross-over CR and Kathy Stichter said that was not a problem.

Establish Action Plan (Resolution Time Frame) A Cross-over CR will be created on behalf of Eschelon. The CR# will be PC053002-1X.

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Response - CR #PC053002-1X Indicate which USOCs a CLEC is currently using somewhere on the spreadsheet sent to a CLEC to advise of rate changes

Qwest provides 10-day advance CLEC notification for any corrections to rates in a CLEC's contract. The notification is provided via an excel spreadsheet that enables the manipulation of the data by the CLEC to sort against their billing records. In order to provide the most comprehensive information regarding rate corrections, Qwest notifies CLECs of changes to any rates in their contract. This is due the fact that all contracted rates are loaded in the billing system and can be ordered at any time.

Providing only the specific CLEC USOCs that have been ordered would be cost prohibitive and could prevent Qwest from correcting rates in the billing system in a timely manner. Providing this additional information on the rate correction CLEC notification would require approximately 60 additional Qwest resources for the CLEC notification process to be completed in a timely manner.

Future rate validation efforts will result in a lesser number and size of notifications than CLEC’s may have received to this point, and thus will be smaller in size of impact to CLEC’s regarding comparing the data to their billing records.

Denied – Economically not feasible – low demand, cost prohibitive to implement the request, or both.

Sincerely,

Susan Burson Director Process Management Qwest

Cc: Christie Doherty, Judy Taylor, Toni Dubuque, Joan Masztaler

Open Product/Process CR PC053002-2X Detail

Description Of Change

Expected Deliverables: Spreadsheets with rate changes should show the actual rate (money amount) being billed incorrectly and not the percentage or tariffed rate. Spreadsheet should show the correct rate that will be billed going forward (money amount). Effective dates should be date when rate was first billed incorrectly.

Status History

Project Meetings

SCR053002-02 Clarification Meeting

2:00 p.m. (MDT) /Thursday June 6,2002

877 570-8688 Conference ID 7807739

Attendees Name/Company:

Kathy Stichter - Eschelon Michael Buck - Qwest Kit Thomte - Qwest Kristen Hathway Qwest Lynn Stecklein - Qwest

Meeting Agenda: Introduction of Attendees Introductions of the participants on the conference call were made and the purpose of the call was discussed.

Review Requested (Description of) Change Kathy Stichter reviewed the change that Eschelon is requesting as follows: When Qwest discovers an error in what they have billed, they populate the spreadsheet with a discount instead of the actual incorrect rate and correct rate. She also said that the effective date is a random date.

Confirm Areas & Products Impacted This request applies to all products.

Confirm Right Personnel Involved All appropriate personnel are involved in this change request.

Identify/Confirm CLEC’s Expectation Eschelon would like the spreadsheets to reflect the actual rate being billed incorrectly and not the percentage or tariffed rate. Kathy Stichter also said the Eschelon would like the date to reflect the actual effective date, not just any date.

Identify any Dependent Systems Change Requests Michael Buck asked why Eschelon submitted this request as a system change. He explained that a change to a spreadsheet would be considered a process change. Kathy Stichter said that she was not aware that this would be considered a process change or else Eschelon would have submitted a Process CR. Michael Buck said that this change request would be handled as a Cross-over CR and Kathy Stichter said that was not a problem.

Establish Action Plan (Resolution Time Frame) A Cross-over CR will be created (PC053002-2X)

CenturyLink Response

Kathy Stichter ILEC Relations Manager Eschelon

SUBJECT: Qwest’s Change Request Response - CR #PC053002-2X Supply current rate and new rate when issuing changes sent to CLECs via spreadsheet. Effective date of correction should go back to when the rate was first billed incorrectly, not an arbitrary date chosen by Qwest as to when the rate is effective.

When Qwest provides CLEC notification for any corrections to a CLEC's billing rates, Qwest provides the current and corrected rate in the manner that it appears in the contract. For UNE rates, facility based OS/DA usage rates and unbundled switching rates, the dollar amount is what is provided in the CLEC contract. So Qwest provides the dollar amount for the current rate and the corrected rate. For Resale (USOC and usage rates) and toll usage rates, the percent discount is the rate provided in the CLEC contract. So for Resale (USOC and usage) and toll usage rate corrections, Qwest provides the percent of Resale (1 minus the Resale percent discount). The CLEC can refer to the Retail Tariff (http://tariffs.uswest.com:8000/) to obtain the actual dollar amount against which the percent discount is applied.

Providing the actual resale (USOC and usage) and toll usage money amounts would be cost prohibitive and could prevent Qwest from correcting rates in the billing system in a timely manner. Providing this additional information on the rate correction CLEC notification would require approximately 50 additional Qwest resources for the CLEC notification process to be completed in a timely manner.

Future rate validation efforts will result in a lesser number and size of notifications than CLEC’s may have received to this point, and thus will be smaller in size of impact to CLEC’s regarding comparing the data to their billing records.

The effective date is provided on all CLEC rate correction notifications. The effective date is generally when the rate was first billed incorrectly (e.g. the contract or cost docket effective date).

If the CLEC has any specific questions regarding a CLEC notification for a rate correction (including the effective date for the rate correction), the CLEC can contact their Qwest Billing Representative.

Partially Denied - Economically not feasible – low demand, cost prohibitive to implement the request, or both.

Sincerely,

Susan Burson Director Process Management Qwest

Cc: Christie Doherty, Judy Taylor, Toni Dubuque, Joan Masztaler

Open Product/Process CR PC093002-05X Detail