Wholesale: Products & Services

Prior Archived Product/Process CMP's in One File

Open Product/Process CR 4302321 Detail

 
Title: CSR Form Sub Account Number Field
CR Number Current Status
Date
Area Impacted Products Impacted

4302321 Withdrawn
2/18/2000
Originator: Grigsby, Geoff
Originator Company Name: Covad
Owner: Routh, Mark
Director:
CR PM: Routh, Mark

Description Of Change

Begin placing a field on the CSR form that USW would populate with the sub-account number. This is necessary because the sub-account number is required to disconnect and USW does not tract this number, which may happen many years after the installation was completed.


Status History

11/17/99 Submitted11/19/99 Received email submission11/22/99 Logged and provided title/complete email. Received status of New – To be industry reviewed. Sent email to Geoff Grigsby on CR status.

12/15/99 During the industry team meeting questions arose as to whether there maybe a misunderstanding and the CR might be a training issue. Barbara Peterson has the action item to contact you about this one. Also, Tona is to contact Geoff. Status change “New – To be clarified”

12/30/99 Sent email to Geoff on CR status change and requested quick clarification.12/31/99 Cory Hamiltorn, Training and Services, responded to this CR to Geoff to clarify training issue.

02/02/00 Sent email to Goeff and Bogdan on CR Form update to version 04, included text of Cory’s email above, and noted the CR has a status of “New – To be clarified”

02/18/00 Status change to Cancelled – Clarification not completed. Sent email to Geoff and Bogdan that CR is cancelled per CICMP. That is, a CR is automatically cancelled if it remains in New – To be clarified for 60 or more days.


Project Meetings


Open Product/Process CR 4302410 Detail

 
Title: DSL Pre qualification Loop Length Tool
CR Number Current Status
Date
Area Impacted Products Impacted

4302410 Withdrawn
1/24/2000
Originator: Grigsby, Geoff
Originator Company Name: Covad
Owner: Routh, Mark
Director:
CR PM: Routh, Mark

Description Of Change

DSL CLECs need to know actual loop length in order to determine what speed DSL service can be provided to a Customer. Using air feet to determine these speeds is only an estimate and the carrier must submit a request and wait for USW to respond. Often the order must be downgraded but this takes time while USW investigates loop length and rejects the order and a SUPP must be submitted. Providing an interactive tool that would give actual loop length prior to submitting the order would reduce costs for both CLECs and USW by preventing the resubmission of orders.


Status History

11/17/99 Submitted

11/19/99 Received email submission11/22/99 Logged and validated. Received status of New – To be industry reviewed. Sent email to Geoff Grigsby on CR status.

12/15/99 During the industry team meeting questions arose as to whether this was a duplicate of Rhythms #4261631 "Enhancements to ADSL Loop Pre-qualification". Tona Moore was to talk to Geoff about this.

12/29/99 Sent email to Geoff on CR status with request for quick resolution.

01/24/00 Cancelled – Co-Provider. Combined with CR 426163102/02/00 Sent email to Geoff and Bogdan


Project Meetings


Open Product/Process CR 5236247 Detail

 
Title: Implement a process for CLECs to upload PIC information to Qwest to compare to the PICs in Predictor
CR Number Current Status
Date
Area Impacted Products Impacted

5236247 Withdrawn
8/15/2001
Originator: Douglas, Kerrie
Originator Company Name: Eschelon
Owner: Routh, Mark
Director:
CR PM: Routh, Mark

Description Of Change

We would like a process created to compare CLEC PIC information to what is in Qwest’s Predictor system. Although we understand that there is a Feature Verification section in CSR– the information is not real time. Ideally, we would like to upload a file to Qwest and have them run a query comparing the PIC information, which resides on a particular Qwest switch and then have the query results returned to the CLEC. We want this process to have the ability to be run on a nightly basis as needed. We would like Qwest to indicate what file format would work the best for Eschelon send for this type of query. If Qwest can return the query information in Excel, Access or common delimited format that would be preferred. The information we would like to have in compared is TN and PIC Codes.


Status History

11/17/00 New – To be validated

11/21/00 New – To be industry evaluated. Sent email to Kerrie Douglas and Pat Brolsma with CR # and Status

12/04/00 Status changed to Reviewed – Under consideration

12/05/00 Sent email to Lynne Powers with updated CR.

01/12/01 Status changed to New- to be reviewed. T-Shirt size and options to be presented at the 2/21/01 CICMP meeting. New status is based on new requirements for this CR.

01/12/01 Sent email to Lynne Powers and Judy Rixe with updated CR.

02/07/01 Status changed to Reviewed – Under Consideration. T-Shirt size Medium and options provided. Eligible for industry prioritization.

02/08/01 Sent email to Lynne Powers and Judy Rixe with updated CR.

08/15/01 Canceled - CLEC


Project Meetings


Open Product/Process CR 5263137 Detail

 
Title: Re use facilities for CLEC CLEC carrier changes
CR Number Current Status
Date
Area Impacted Products Impacted

5263137 Completed
11/14/2001
Ordering Centrex, Resale, Unbundled Loop, UNE-P
Originator: Powers, Lynne
Originator Company Name: Eschelon
Owner: Urevig, Russell
Director:
CR PM: Harlan, Cindy

Description Of Change

Qwest should change its process so that Qwest will re-use facilities for CLEC-to-CLEC carrier changes. When an end-user customer changes carriers from one CLEC to another, Qwest has indicated to Eschelon that CLECs must order new facilities, because Qwest does not allow a CLEC to request re-use of the same facilities used by the other CLEC to serve the same customer. In one situation, for example, Eschelon placed an order to change an end-user customer from the on-net facilities of another CLEC to the on-net facilities of Eschelon. Qwest indicated that Eschelon must order new facilities and, when Eschelon did so, Qwest placed the order in held status. The other CLEC provided its PONs to Eschelon for that CLEC’s disconnect of its loops. Eschelon re-submitted the order, identified the PONs, and requested re-use of those facilities. Qwest responded that CLECs are not allowed to request re-use of CLEC facilities. Eschelon cancelled the order and resubmitted it later. The order again went in held status. The order is still in held status. (Eschelon has provided the specific information for this and other situations to its account manager.) Ordering new facilities, instead of re-using facilities, can result in delay, additional costs, and service disruption or downtime. Please modify Qwest’s processes so that Qwest will re-use facilities for CLEC-to-CLEC carrier changes.


Status History

12/01/00 - Submitted

12/01/00 - New to be validated

12/04/00 - New to be reviewed

12/06/00 - Status changed to Reviewed - under consideration

12/06/00 - Will Discuss during UNE-P discussion marked as agenda item in the Product/Process CICMP Meeting (12/20/00)

12/15/00 - CR still under investigation but will address in the CICMP Meeting (12/20/00)

01/10/01 - Will be addressed during the 1/11 through 1/12 CLEC to CLEC UNE-P meeting and results discussed in the January CICMP Meeting (RU)

02/14/01 - Product Announcement for a formalized process to enable CLEC to CLEC conversions of Unbundled Loop with Re-use of facilities or same loop type services communicated to CICMP team via email and posted on CICMP web site. ( RN # 5393537). (RU – MR)

02/21/01 - Closing CR is dependant on requested revision to RN #5393543 – CLEC Unbundled Loop to CLEC Resale

03/19/01 - Revision to RN #5393543 complete and undergoing internal approval. Date of Release pending approval. (BD)

03/27/01 - Revision to RN #5393537 - CLEC Unbundled Loop to CLEC Unbundled Loop Re-use of Facilities - Revision A sent to CICMP team. BD-MR)

04/18/01 - Additional revision needed to CLEC Unbundled Loop – CLEC Unbundled Loop and CLEC Unbundled Loop – Resale release notifications previously released to incorporate new policy on obtaining Circuit ID from OLSP (MR)

04/30/01 - Revision "B" to RN #5393537, RN #5393543, and RN #5467108 sent to CICMP team incorporating new procedure for obtaining Circuit ID’s. (MR)

05/16/01 - Lynne Powers request to remain open to verify newly implemented circuit attainment process to be put in place on 5/25. (MR)

06/20/01 - Process implementation for enhanced Circuit ID Process to be verified and presented in interim meeting to be scheduled by Qwest prior to the July CICMP Meeting. (MR)

07/10/01 - Interim conference call conducted to discuss CLEC to CLEC conversions – meeting minutes sent to the CICMP team on 7/12/01 (MR)

07/13/01 - Drafted response sent to the CICMP Team via email (MR)

08/07/01 - Qwest response dated 08/07/01presented.

08/28/01 - CR Closed per telecon between R. Martin, Qwest and K. Stichter, Eschelon.

09/19/01 - CMP Meeting - agreed to move CR to CLEC Test Status

10/17/01 - CMP Meeting: No "Current Status" change

11/14/01 - CMP Meeting - it was agreed that the CR could be closed.


Project Meetings

Email 08/28/01 Kathy, This confirms our conversation this morning that Change Request 5263137 can be closed based on Qwest's response dated August 7, 2001 presented at the 8/15/01 meeting. In addition, this is based on Qwest tracking System Action Item 308 as a separate request and addressing the quality issued experienced during cut-over. Thanks for your cooperation. Regards, Ric


CenturyLink Response

August 7, 2001 This letter is in response to the following CLEC Change Request Forms #5263137, dated December 1, 2000 and #5608177 and #5608353, dated June 13, 2001. All of these Change Requests pertain to the CLEC to CLEC Migration process. The revised process was released via the Co-Provider Industry Change Management Process (CICMP) on May 25, 2001.

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

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

Sincerely Nancy J. Hoag Qwest Wholesale Product Team

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

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

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

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

Sincerely Nancy J. Hoag Wholesale Product Manager


Open Product/Process CR 5263637 Detail

 
Title: Installation of adequate facilities and reduction in number of held orders
CR Number Current Status
Date
Area Impacted Products Impacted

5263637 Denied
2/20/2002
Ordering Centrex, Resale, Unbundled Loop, UNE-P
Originator: Powers, Lynne
Originator Company Name: Eschelon
Owner: Buckmaster, Cindy
Director:
CR PM:

Description Of Change

Modify Qwest’s processes to ensure installation of adequate facilities and reduction in the number of held orders. Through recurring rates, Qwest is being compensated for expanding its network to account for new growth. Qwest will build facilities for its own retail customers. (In Arizona arbitration's, for example, Qwest reported that it installs 3 lines per customer to anticipate growth.) However, Qwest will not do so for CLECs in similar situations. Qwest has rejected orders from Eschelon for the stated reason that “no jobs planned in the near future for this area.” (Examples of such rejections were provided to Eschelon’s account team on August 30, 2000.) The orders are placed in held status indefinitely, with no date for completion. When asked about these rejections, Qwest indicated it believes it has no obligation to build. At the last CICMP meeting, Qwest again confirmed that it is Qwest’s policy not to build additional UNE's when Qwest is out of capacity, but Qwest will build for a retail customer’s order. As indicated, however, Qwest is being compensated for such growth and would build for its own retail customer in the same situation. Please modify Qwest’s practices to build in these situations and to provide notice to CLECs as to when held orders will be completed. In the meantime, until such processes are in place, please institute a process to provide to CLECs (perhaps through a website) a list of those areas for which Qwest has jobs planned, a list of areas for which no jobs are planned, and a description of the nature of the jobs planned. Because Qwest has access to this information for its planning purposes, parity requires that CLECs also have access to the same information for their planning purposes.

Modification

08/22/01 - Added Action Item 25, Advance Notification of future builds.

08/22/01 - Added Action Item 28, Resale Orders vs. Unbundled Loop Orders-Held Order Process

08/22/01 - Added Action Item 29, State Specific Rules for future build policy


Status History

12/01/00 - Submitted

12/01/00 - New - to be validated

12/04/00 - Status changed to New – To be reviewed

12/06/00 - Status changed to Reviewed – Under Consideration

12/06/00 – Will Discuss during UNE-P discussion marked as agenda item for 12/20 Product/Process CICMP Meeting

12/15/00 – CR still under investigation but will address at the 12/20 CICMP Meeting (SB - BC)

1/10/01 - Documentation currently being created by Qwest personnel and will be addressed during the January CICMP Meeting (CB).

1/15/00 - The question of whether or not Qwest will build to provide UBL facilities for CLECs is currently under review. Some additional work is necessary to determine if precedent has been set due to past actions or previous sideline agreements. The Product Team is resolving this issue and should have a new policy statement by 1/31/01 (CB).

1/26/01 - Due date changed due to corporate strategy involvement and moved tentatively to 2/28/01 (CB)

3/15/01 - Document complete pending approval by Legal. Expected delivery 3/16/01. (CB)

3/19/01 - Tentative approval date pushed to 3/21/01. Date of document release pending internal approval. (CB)

3/27/01 - RN #5467145 - Qwest Position Statement on Build Requirements for Unbundled Loops released to the CICMP team. Qwest accepts build responsibility for primary analog voice grade circuits. Where facilities don’t exist for these requests, Qwest will initiate an engineering work order to build. (CB)

4/18/01 - Statement regarding advanced notice on future builds required to Complete this CR. (MR)

5/14/01 - Policy statement concerning advance notification of future builds has been drafted and is currently under review by Qwest Legal and Public Policy. Tentatively marked for release on 5/30/01. (NH)

5/30/01 - Policy statement held due to language. Date of Distribution TBD

6/18/01 - Build Policy tentatively scheduled for release on 8/1/01 (DG)

8/09/01 - CR Response distributed to the CICMP Team along with a drafted Response to a supplemental email submitted by Karen Clauson. (MR)

08/15/01 - Eschelon did not accept Qwest's response dated 08/09/01

09/19/01 - CMP Meeting - Qwest advised that they are still evaluating the CR.

09/21/01 - Meeitng held with Eschelon. Matrix developed with list of action items.

10/17/01 - CMP Meeting: Qwest to transmit revised response to Eschelon & notify CLEC community within next few days. No "Current Status" change.

10/18/01 - Issued Qwest Response dated October 15, 2001 with Attachments to the CLEC Community.

10/18/01 - Received e-mail comments from Eschelon on Qwest's 10/15/01 response

10/29/01 - Conducted Clarification meeting with Eschelon to review their e-mail comments to Qwest's 10/15/01 Response.

11/14/01 - CMP Meeting - Qwest advised that PCATs should be published in November. Eschelon requested Qwest explain why rearrangement of the Qwest network requires special construction and that Qwest answer their 11 questions.

11/16/01 - Revised PCAT Language was posted to the WEB for both General Resale and Genera UBL..

12/12/01 - CMP Meeting - Qwest provided an update on the process development on Special Construction. Qwest advised that the process should be completed in January and Qwest will respond to Eschelon's questions after that time. It was agreed that the CR should be placed into Development.

01/16/02 - CMP Meeting - Qwest advised that the document on the Special Construction package was very much in draft form. Qwest reviewed the draft process which is to primarily introduce the process and secondarily answer Eschelon's questions. CLECs are to provide feedback to the document. The CR will remain in Development.

02/01/02 - Posted Updated Special Construction Process with Answers to Eschelon's questions to the database.

02/01/02 - Issued Updated Special Construction Process to Eschelon.

02/20/02 - CMP Meeting - Qwest reviewed the two additional questions raised at last month's CMP meeting that were incorporated into Qwest's Special Construction Process. Qwest advised that the Special Construction PCAT language would be issued April 5, 2002. Qwest requested that the CR be closed. Eschelon advised that they felt the CR should be denied because Qwest isn't reducing the number of held orders, but rather canceling them. It was agreed that the CR would be statused as Denied. Meeting discussions will be set forth in the Product/Process Draft Meeting Minutes contained in the Product/Process CMP Meeting Distribution Package 03/20/02.

03/20/02 - CR Open/Closed Status changed to Closed per agreement at 03/20/02 Monthly CMP Meeting that CRs having Denied status should also reflect Closed Status


Project Meetings

Clarification Meeting

October 29, 2001 Conference Call

866-289-7092 5263637, Installation of Adequate Facilities Attendees: Ric Martin, Qwest Susie Bliss, Qwest Kathleen Stichter, Eschelon

1.0 Purpose Review Qwest’s October 15, 2001 response and Eschelon’s e-mail dated October 18, 2001 2.0 Review Documents and Clarify Requirements 2.1 Ric Martin reviewed Eschelon’s e-mail and clarified that Eschelon wanted to clearly see the written policies and specific exceptions to the policies. 2.2 Susie Bliss explained that, to the maximum extent practical, policies specific to products would be contained in the product PCATs. Susie advised that Qwest agreed to clarify our policies and state any exceptions to the policy. Qwest is in the process of updating the General Unbundled Loop PCAT and the General Resale PCATs. Qwest is clarifying the exceptions under the Tariff, Regulations and Policy section of the above PCATs. Susie advised that within the next couple of weeks the two specific products would be updated in the PCAT to clearly define the policies and ensure that exceptions are clearly stated. 2.3 Kathy Stichter asked if there were any other exceptions like Minnesota. Susie Bliss explained that there were no other current exceptions. 2.4 Susie Bliss advised that as additional rulings get handed down, Qwest would update the PCATs accordingly and issue the requisite notifications. 2.5 Kathy Stichter asked about Qwest’s retail policy. Susie Bliss advised that the Qwest Resale is the Qwest Retail policy. 2.6 Susie Bliss is to provide the approximate timeframe for publishing the General Resale and General Unbundled Loop PCATs. 2.7 Ric Martin will communicate the dates to the CLEC Community via the requisite notifications. 2.8 Ric Martin advised that with the Update of the PCATs, it would be Qwest’s intent to move the CR into a CLEC Test Phase to allow the CLEC’s review the PCAT language. 2.9 Kathy Stichter stated that the above actions should meet their expectations.

--

RE: Response - CR 5263637 - Installation of Adequate Facilities - Fourth Attempt Date: Thu, 18 Oct 2001 13:36:33 -0500 From: Clauson, Karen L. ,klclauson@eschelon.com> To: Matthew Rossi , mrossi@qwest.com CC: Powers, F. Lynne,flpowers@eschelon.com, "Stichter, Kathleen L,. Thank you for the response. We will review it internally. With respect to state-specific issues, we had asked Qwest to identify any state-specific exceptions. Qwest agreed to do so. Eschelon also asked that Qwest modify its written policy to state the exceptions in the policy, instead of using a general footnote that refers to exceptions without stating what those exceptions are. As written, the policy does not reflect those exceptions. The policy has not been modified so that a CLEC reading it would know how the policy applies in each state. The reply refers to the Minnesota merger agreement as "one such exception." This suggests that there are other exceptions, but Eschelon does not know what they are. Please identify the exceptions and modify the written policy to list the exceptions so that CLECs reading the policy can identify how the policy operates in each state. Thank you.


CenturyLink Response

"The below response does not include the attachments referenced in the response field. Please see Supplemental Information following the Detail Report."

October 15, 2001

Lynn Powers Vice President, Eschelon Telecom, Inc.

CC: Matthew Rossi

This letter is issued to amend Qwest’s response letter dated August 9, 2001 and is in response to your CLEC Product & Process Change Request 5263637. Request –

? Modify Qwest’s processes to ensure installation of adequate facilities and reduction in the number of held orders. Through recurring rates, Qwest is being compensated for expanding its network to account for new growth. Qwest will build facilities for its own retail customers. (In Arizona arbitration's, for example, Qwest reported that it installs 3 lines per customer to anticipate growth.) However, Qwest will not do so for CLECs in similar situations. Qwest has rejected orders from Eschelon for the stated reason that “no jobs planned in the near future for this area.” (Examples of such rejections were provided to Eschelon’s account team on August 30, 2000.) The orders are placed in held status indefinitely, with no date for completion. When asked about these rejections, Qwest indicated it believes it has no obligation to build. At the last CICMP meeting, Qwest again confirmed that it is Qwest’s policy not to build additional UNEs when Qwest is out of capacity, but Qwest will build for a retail customer’s order. As indicated, however, Qwest is being compensated for such growth and would build for its own retail customer in the same situation. Please modify Qwest’s practices to build in these situations and to provide notice to CLECs as to when held orders will be completed. In the meantime, until such processes are in place, please institute a process to provide to CLECs (perhaps through a website) a list of those areas for which Qwest has jobs planned, a list of areas for which no jobs are planned, and a description of the nature of the jobs planned. Because Qwest has access to this information for its planning purposes, parity requires that CLECs also have access to the same information for their planning purposes.

Response –

As discussed earlier, currently Qwest has no plans to modify the existing policy or processes regarding Qwest’s obligation to build new facilities. The issues addressed in your CR have been discussed in workshops. Some of the issues have been resolved. Rulings have been received in 10 of the 12 workshops to date. In each ruling, the Commissions support the Qwest position that the ILEC is not required to build additional facilities to deliver to a CLEC.

In order to help identify the current status of the issues we put together a summary outlined in Attachment A. This status was as of October 1, 2001. Attachment B documents our replies to the questions associated with this CR. We appreciate the time you spent clarifying each of your questions. Qwest will review our current PCATs to ensure they reflect the current status of any past rulings and we will continue to do so as states rule on the issues at impasse.

Finally, between the August 7th reply, the August 9th reply, and the attached, Qwest believes we have addressed the issues associated with this CR and we need to let the regulatory process determine the next steps.

Sincerely,

Susie Bliss Qwest Wholesale Process Director

--

August 9, 2001

Lynne Powers Vice President, Customer Operations Eschelon Telecom Inc.

CC:Matthew Rossi Cindy Buckmaster Denny Graham

This letter is in response to your CLEC Change Request Form #5263637 dated December 1, 2000

Change Request: “Installation of Adequate Facilities and Reduction in Number of Held Orders” “Modify Qwest’s processes to ensure installation of adequate facilities and reduction in the number of held orders. Through recurring rates, Qwest is being compensated for expanding its network to account for new growth. Qwest will build facilities for its own retail customers. (In Arizona arbitration, for example, Qwest reported that it installs 3 lines per customer to anticipate growth.) However, Qwest will not do so for CLECs in similar situations. Qwest has rejected orders from Eschelon for the stated reason that “no jobs planned in the near future for this area.” (Examples of such rejections were provided to Eschelon’s account team on August 30, 2000.) The orders are placed in held status indefinitely, with no date for completion. When asked about these rejections, Qwest indicated it believes it has no obligation to build. At the last CICMP meeting, Qwest again confirmed that it is Qwest’s policy not to build additional UNEs when Qwest is out of capacity, but Qwest will build for a retail customer’s order. As indicated, however, Qwest is being compensated for such growth and would build for its own retail customer in the same situation. Please modify Qwest’s practices to build in these situations and to provide notice to CLECs as to when held orders will be completed. In the meantime, until such processes are in place, please institute a process to provide to CLECs (perhaps through a website) a list of those areas for which Qwest has jobs planned, a list of areas for which no jobs are planned, and a description of the nature of the jobs planned. Because Qwest has access to this information for its planning purposes, parity requires that CLECs also have access to the same information for their planning purposes.”

Qwest Response: Qwest interprets both the FCC Telecom Act and subsequent UNE Remand to state that ILECs are obligated to make the existing network available to CLECs via unbundling. Qwest believes that this means that Qwest is not obligated to construct new facilities at its expense at the request of a CLEC.

The first part of this Change Request requires that Qwest ensure installation of adequate facilities. Qwest recognized that holding CLEC requests led to the mis-interpretation that Qwest was willing to construct these UNEs at some point in the future. As this isn’t the case, Qwest issued the Qwest Network Build Position for the Unbundled Loop (UBL) Product and ensured all operational work groups adhered to this practice. In short, the Position statement states,

Qwest will construct facilities for UBL that are in alignment with its Eligible Telecommunications Carrier (ETC) obligation to provide basic local exchange service in the retail markets. This means that Qwest will construct facilities to satisfy the primary DS0 - Analog (voice grade) lines for UBL as Qwest constructs these facilities for it’s own end-users.

The Primary services identified above are specific to the set number of lines per address. Address is defined as the specific Unit (Loc).

When the CLEC submits a request for a Secondary DS0-Analog (voice grade) line, DSL, ISDN, DS1 or DS3 service, the normal assignment process will be followed in its entirety. If no facilities can be found, and there is No Planned Engineering Job, the LSR will be rejected (the CLEC will receive a Reject Notice) and the Order will be cancelled. The CLEC now has the opportunity to request construction by filing the proper request through their Account Team.’

In this Statement, Qwest agrees to ensure adequate facilities to support Primary DS0-Analog (voice grade) requests only.

The second issue in this Change Request deals with Held Orders. In various sections of the Request, Eschelon requires Qwest to reduce the number of held orders, not leave held orders in held status indefinitely, with no date for completion and to provide notice to CLECs as to when held orders will be completed.

As Qwest believes the ILECs are not obligated to provide more than the existing network for the CLECs, it follows that the ILECs are not obligated to hold and review old CLEC requests on a regular basis. Therefore, Qwest’s implementation of the Network Build Position for the Unbundled Loop (UBL) Product ensured that all operational work groups were in alignment not to hold requests where facilities are not currently available.

A third issue in this Change Request indicates that Qwest confirmed its policy not to build additional UNEs when Qwest is out of capacity. This issue is not entirely accurately represented. UNEs and retail services utilize the same physical facilities. Where facilities are exhausted, Qwest retail customers will suffer in the same fashion as CLEC customers. Where facilities are exhausted, Qwest will not have the ability to provide additional lines to any customer, retail or CLEC. In most of these circumstances, Qwest is working to reinforce the availability of facilities in these areas.

The issue here is the availability of compatible facilities. For analog (voice grade) services, many types of facilities can be used. However, for some services, copper facilities are required. If Qwest has facilities that are not compatible for the services the CLEC is intending to deliver, Qwest will not construct compatible facilities for the CLEC.

Finally, this Change Request addresses the availability of information related to plans for Network Builds. In response to this request, Qwest is announcing a Network Build Disclosure Web site.

The Network Build Disclosure will notify the CLEC community of Outside Plant (OSP) growth jobs that exceed $100,000 in expense. The disclosure will consist of number of copper pairs or fiber strands placed per distribution area in wire centers, an estimated ready for service date and the final completion dates when job is complete. NOTE: Qwest will reserve the right to cancel jobs due to business decisions and will not be held liable for cancellations. This disclosure will be made September 30,2001 and will be continued on a monthly basis thereafter. Jobs will be dropped from the list 30 days after actual completion date is announced. Customers will be able to view the latest information regarding Qwest’s growth and major expansions in Qwest local serving area. This will help them to identify areas where additional facilities will be available for growth. This disclosure will be located on the Qwest’s external website located at www.qwest.com/wholesale/iconn/

Denny Graham Qwest Staff Compliance Representative

Cindy Buckmaster Nancy Hoag Qwest Wholesale Products


Open Product/Process CR 5263569 Detail

 
Title: Loop reclamation
CR Number Current Status
Date
Area Impacted Products Impacted

5263569 Completed
12/12/2001
Ordering Centrex, Resale, Unbundled Loop, UNE-P
Originator: Powers, Lynne
Originator Company Name: Eschelon
Owner: Urevig, Russell
Director:
CR PM:

Description Of Change

Perform loop reclamation for CLECs and provide prior notice of Qwest’s loop reclamation. Qwest has indicated that it will not perform loop reclamation to prevent a CLEC order from going into held status. In contrast, when Qwest “wins back” a customer from a CLEC, Qwest will perform loop reclamation and will do so without prior notice to the CLEC. For example, as shown in the example below, when Eschelon has placed a disconnect order on a UNE loop, Eschelon has received a rejection notice from Qwest indicating that Qwest has already disconnected the loop as a result of loop reclamation. Qwest disconnected the loop without prior notice to Eschelon. Because of this practice, an order will be processed (and not go into held status) for a Qwest retail customer, whereas a CLEC order would go into held status. The CLEC end-user customer would experience a delay (and possibly additional costs and service disruption), whereas the Qwest end-user would not. Please modify Qwest’s processes to perform loop reclamation for CLECs and provide prior notice of Qwest’s loop reclamation.


Status History

12/01/00 - Submitted

12/01/00 - New - to be validated

12/04/00 - Status changed to New – To be reviewed

12/06/00 - Status changed to Reviewed – Under Consideration

12/06/00 - Will Discuss during UNE-P discussion marked as agenda item for 12/20 Product/Process CICMP Meeting

12/15/00 - CR still under investigation but will address at the 12/20 CICMP Meeting (SB)

01/10/01 - Will be addressed during the 1/11 – 1/12 CLEC to CLEC UNE-P meeting and results discussed in the January CICMP Meeting (RU)

02/14/01 - Product Announcement for a formalized process to enable CLEC Unbundled loop to CLEC resale communicated to CICMP team via email and posted on CICMP web site. ( RN # 5393543). (RU – MR)

02/21/01 - Closing CR is dependant on requested revision to RN 5393543 – CLEC Unbundled Loop to CLEC Resale

03/19/01 - RN Revision complete and undergoing internal approval. Date of release pending approval. (BD)

03/27/01 - Revision to RN #5393543 - CLEC Unbundled Loop to CLEC Resale - Revision A as well as RN #5467108 - CLEC LNP with Unbundled Loop to CLEC Resale - Revision A released to the CICMP Team. (MR-BD)

04/16/01 - Additional revision needed to CLEC Unbundled Loop – CLEC Unbundled Loop and CLEC Unbundled Loop – Resale release notifications previously released to incorporate new policy on obtaining Circuit ID from OLSP (MR)

04/30/01 - Revision “B” to RN #5393537, RN #5393543, and RN #5467108 sent to CICMP team incorporating new procedure for obtaining Circuit ID’s. (MR)

05/18/01 -CICMP team requests verification of implemented process to close CR

(MR)

06/20/01 - Process implementation for enhanced Circuit ID Process to be verified and presented in interim meeting to be scheduled by Qwest prior to the July CICMP Meeting. (MR)

07/10/01 - Interim conference call conducted to discuss CLEC to CLEC conversions – meeting minutes sent to the CICMP team on 7/12/01 (MR)

08/15/01 - CLEC CMP Meeting Product & Process CR 5263569. Qwest response dated 08/13/01 presented. Eschelon requested process improvement plan.

08/29/01 - Qwest issued revised draft response dated 08/27/01.

08/29/01 - Eschelon indicated that response didn't adequately answer the CR and requested that a clarification meeting be held.

09/04/01 - E-mail sent to Kathy Stichter to verify the question being posed in the CR. Kathy Stichter confirmed via e-mail on 9/6 that Qwest does understand their request.

09/12/01 - Eschelon provided comments.

09/18/01 - Review meeting held with Eschelon

09/19/01 - CMP Meeting - Qwest advised that they were developing an implementation plan and should have a response and plan the week of 10/01/01.

10/09/01 - Russ Urevig (Qwest) reported that all Centers have been trained, to include the three regions of Seattle, Phoenix & Omaha.

10/17/01 - CMP Meeting: Qwest to transmit revised response to Eschelon & notify CLEC community within next few days. No "Current Status" change.

10/19/01 - Revised response posted to web (response dated 09 October 2001).

11/14/01 - CMP Meeting - Qwest provided status of its implementation. It was agreed that the CR could be moved to Development

12/07/01 - Letter (dated 12/04/01) regarding process the CLEC community will need to follow to assist Qwest in Loop Reclamation, and crediting to the CLEC’s received and posted into CMP data base.

12/12/01 - CMP Meeting - Russ Urevig, Qwest presented procedure for CLECs to follow to assist Qwest in Loop reclamation, and crediting to the CLECs. Allegiance and Eschelon indicated that the procedure has been implemented and was satisfied with current results. CR "Present Status" was changed to "Completed." Eschelon requested that the CMP track further progress of actual CLEC loop reclamations in the future.


Project Meetings

11:30 a.m. (MDT) / Tuesday 18th September 2001 Clarification/Walk-through Meeting

Kathy Stichter, Eschelon Jerri Brooks, Qwest Ric Martin, Qwest Russ Urevig, Qwest Nancy Hoag, Qwest Linda Miles, Qwest Carolyn Brown, Qwest

Introduction of Attendees Introduction of participants on the Conference Call was made. The purpose of the call was to discuss Qwest’s Action Plan for CR 5263569 Loop Reclamation, and to share the plan at a high level with Eschelon. Review of Response Russ Urevig reviewed the draft point paper that lays out the tentative Action Plan. R. Urevig stated that Qwest Recognizes there is an issue with Loop Reclamation and that a cross-functional team is looking at improving the process. R. Urevig stated training documentation for order writers is scheduled to be completed by mid September. R. Urevig stated there will be a trial program to test the process within the next 3-5 weeks. R. Urevig stated there is a non-competitive group within Qwest who will do the disconnect/reclamation with side by side training from Regional Support Groups. R. Urevig stated there will be a meeting on Friday 9/21/01 to discuss the Action Plan, Time Estimates and Recommended Changes. R. Urevig will provide the action plan with timeline and recommended changes to CMP group and Kathy Stichter of Eschelon.

09/12/01 - Email Jerri, Bonnie and I talked today. What Eschelon wants Qwest to modify their process to perform Loop Reclamation on all disconnect orders and if that is not possible to at least notify Eschelon when they have performed a Loop Reclamation.

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

From: Jerri Brooks [SMTP:jlbroo2@qwest.com] Sent: Tuesday, September 04, 2001 5:29 PM To: klstichter@eschelon.com Subject: CR 5263569

Kathy, Just a note to clarify that we are still working through the issues concerning this CR and an updated Qwest Response. First of all we want to clarify your Request as - "Eschelon wants Qwest to modify its process to perform loop reclamation for CLEC's and provide prior notice to Qwest's loop reclamation."

If that statement is actually what you are requesting then we agree with you. I believe there is currently an effort underway between Qwest groups to conduct a process gap analysis. Immediately after the gap analysis is completed an Action Plan will be drafted with milestones, commitment dates, etc. I will keep you posted as we make progress on this CR. Please give me a call and we can discuss any other questions you may have. Thanks, Jerri 303-294-1290


CenturyLink Response

Wholesale Product Marketing

December 4, 2001

CC: Russ Urevig

This letter is in response to your CLEC Change Request Form #5263569 dated December 1, 2000. The letter will identify the process the CLEC community will need to follow to assist Qwest in Loop Reclamation, and crediting to the CLEC’s.

We are requesting the CLEC’s to provide to their service manager in spreadsheet form the following information:

- The Qwest circuit ID ie; 3.LXFU.00012..nw - The PON number from which the circuit was established - The port back TN - The port back Date - The state in which the circuit was provided

The service manager will be the interface into Qwest and establish a time line in which the process of clean up will start with the Interconnect service center. The Interconnect center will provide the service manager an estimated completion date for each CLEC. The individual CSR established for circuits will be credited back to the Port Out/Port In date to Qwest of that TN specified. For those circuits that can not be credited through the normal process the service manger will be involved with the billing credit process and assist the Interconnect service center to credit each CLEC.

Sincerley,

Russ Urevig Senior Process Analyst

October 9, 2001 Final Response Lynne Powers Eschelon Telecom Vice President, Customer Operations

CC: Russ Urevig Susie Bliss Jerri Brooks Joan Smith

This letter is in response to your CLEC Change Request Form # 5263569 dated December 1, 2000.

Change Request ? Perform loop reclamation for CLECs and provide prior notice of Qwest’s loop reclamation. Qwest has indicated that it will not perform loop reclamation to prevent a CLEC order from going into held status. In contrast, when Qwest “wingback” a customer from a CLEC, Qwest will perform loop reclamation and will do so without prior notice to the CLEC. For example, as shown in the example below, when Eschelon has placed a disconnect order on a UNE loop, Eschelon has received a rejection notice from Qwest indicating that Qwest has already disconnected the loop as a result of loop reclamation. Qwest disconnected the loop without prior notice to Eschelon. Because of this practice, an order will be processed (and not go into held status) for a Qwest retail customer, whereas a CLEC order would go into held status. The CLEC end-user customer would experience a delay (and possibly additional costs and service disruption), whereas the Qwest end-user would not. Please modify Qwest’s processes to perform loop reclamation for CLECs and provide prior notice of Qwest’s loop reclamation.

Qwest response ? During our investigation we found that at times, the Small Business and Consumer groups were not always doing total loop reclamation on the end-users returning to Qwest for local services. Qwest has escalated this issue and pulled together a team from the Wholesale and Retail organizations to review current process and develop a new process to do full reclamation of facilities to provision loops. Extensive training on the new procedure has started. We are phasing in the new process as training is completed. Retail has made the commitment to perform full loop reclamation of facilities by Nov. 1, 2001. Additionally, we are developing a plan to address prior loops that should have been reclaimed. That plan will be completed by 10/26/01. Finally Qwest is investigating how we would notify customers of loss alerts. The initial project plan should be complete by 11/1.

We are confident that the Retail organization understands the importance of loop reclamation and we will continue to monitor and make improvements on this process.

Sincerely,

Susan Bliss Director – Process Management


Open Product/Process CR 5263671 Detail

 
Title: Legacy CR Facilities and Processes when Qwest uses IDLC
CR Number Current Status
Date
Area Impacted Products Impacted

5263671 Completed
4/18/2001
Ordering
Originator: Powers, Lynne
Originator Company Name: Eschelon
Owner:
Director:
CR PM:

Description Of Change

Modify Qwest’s processes to provide facilities, despite Qwest’s use of integrated pair gain (IDLC). Currently, Qwest’s IRRG states:

Unbundled Loops can only be established on copper or Universal Digital Loop Carrier (UDLC). Integrated Digital Loop Carrier (IDLC) cannot be used for an Unbundled Loop service at this time. Qwest has chosen not to unbundle IDLC because of the expense of providing equipment to "groom" the DS0 lines. During the Unbundled Loop facility assignment, an attempt will be made to Line and Station Transfer (LST) the IDLC loop to UDLC or copper. If there are no facilities available to complete the LST, the Co-Provider will be notified that the order has been placed into a held status. (Emphasis added.)

The FCC has said that "[t]he BOC must provide competitors with access to unbundled loops regardless of whether the BOC uses [IDLC] technology . . ." (BellSouth Second Louisiana 271 Order, 187 and SBC Texas 271 Order, 248.) The processes outlined in Qwest’s IRRG are not consistent with this requirement. In some cases, Qwest does not identify that IDLC is being used until the day of cut. When the discovery is made, Qwest may not dispatch a technician. Instead, Qwest delays the order or places it in held status. Qwest does so for all lines, even though facilities may be available for some of the lines. Please modify Qwest’s processes to be consistent with the FCC’s order. Also, please modify Qwest’s processes to identify earlier (before the day of cut) that IDLC is being used. If use of IDLC is not identified until the day of cut, ensure that a technician is available to resolve the issue that day (rather than delaying the order). If Qwest indicates that it does not have facilities for all lines, change Qwest’s processes so that the lines for which facilities are available may be installed (when the line configuration supports


Status History

12/01/00 New - To be validated. Date Submitted field changed from 11/29/00 to 12/01/00 to match email receipt date.

12/04/00 Status changed to New - To be reviewed. Sent Updated CR to Lynne Powers

12/06/00 Status changed to Reviewed - Under Consideration

4/18/01 - Status changed to Complete

4/23/01 - Updated CR sent to Lynne Powers, Jessica Johnson, Karen Clauson of Eschelon.

3/28/02 - Posted this legacy CR to CMP Database. Completed CR Form had been posted to the Web as part of the "Change Request (CR) Archive - Change Requests statused as Inactive before August 1, 2001"


Project Meetings


Open Product/Process CR 4185985 Detail

 
Title: US West policy on a 2000 circuit limitation per Billing Account Number (BAN)
CR Number Current Status
Date
Area Impacted Products Impacted

4185985 Completed
2/21/2002
BAN Billing Interface
Originator: Rodriguez, Cecilia
Originator Company Name: WorldCom
Owner: Routh, Mark
Director:
CR PM: Routh, Mark

Description Of Change

US West has set a 2000 circuit limitation per Billing Account Number (BAN), for each US West region. This restriction places the burden on MCI Worldcom to develop functionality within it’s facility based systems, in order to maintain and manage multiple BAN’s per end user account for unbundled loops. MCIWORLDCOMs change request will impact unbundled loop orders.


Status History

10/12/99 Received and validated CR. Sent email to Eric Bransky informing him of the CR log#, Status of New – To be industry evaluated, and mentioned to him to be prepared to present the CR at the next industry team meeting for IMA OSS interfaces on 11/11/99. Copied Account Management on email.11/02/99 Updated form to Version 03 and added in CICMP Manager Section “Prioritization Process Category” types and selected Common per Co-Provider Industry Issue/Action #34. Sent email to Carol Beaupre – CR Manager informing her of the addition and attached revised CR.

11/04/99 Eric resubmitted CR with additional information. Request clarification was sent to and responded by Eric Bransky. Status "New - To be industry evaluated"

11/08/99 Sent email to Eric Bransky and Carol Beaupre with CR and status of "New -- To be industry reviewed".11/11/99 CR industry reviewed and prioritized.

11/15/99 CR resubmitted with changes from industry meeting

11/18/99 Status change to “Evaluated – To be reviewed, industry prioritization level and priority number. Sent email to Carol Beaupre on CR changes.

12/03/99 Status update Reviewed – Under consideration and sent email to Carol Beaupre on status.

12/29/99 Received resubmitted CR with new submitter and named products/services. Sent email to Liz Balvin on receipt and updated CR to be web posted on 01/03/00.

11/13/00 Changed priority level. Sent email to Liz Balvin.

01/24/00 T-shirt size and option provided at industry team meeting.

02/01/00 Sent email to Liz on CR form version 04 update.

04/19/00 Status Hold to be reviewed in 6 months (10/00) agreed to by the Co-Provider Industry Team

05/01/00 Sent email to Liz and Scott Sparks on CR status.

10/18/00 Status changed to Reviewed – Under consideration.

11/08/00 Sent email to Liz Balvin with updated CR.

11/15/00 T-Shirt Sizes Medium and Large and Options provided in CICMP meeting. Eligible for industry prioritization.

12/01/00 Sent email to Liz Balvin with the updated CR.


Project Meetings


CenturyLink Response

Option 1: Medium T-Shirt Size, Qwest could provide an email message to the Co-Provider when a BAN is close to reaching the 2000 circuit limitation. The message would be emailed to the same address as the Completion Loss Reports.

Option 2: Large T-Shirt Size, Qwest could provide an electronic transaction to the Co-Provider when a customer's BAN is close to reaching the 2000 circuit limitation.

2/11/02 - The 10K table holds a record of updates (basically service order activity) against an account. When you get more than 2K TNs on a BAN, the likelyhood of having >10K activities against the account go up. The 2K is not a hard limit, it is just a cautious limit. The table can not be expanded so Qwest will provide Option 1 as the solution to this request. Qwest will however provide the CLECs with an e-mail notification when the 2000 TN limit is close to being reached.


Information Current as of 1/11/2021