Wholesale: Products & Services

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 .

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

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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