Wholesale: Products & Services

Open Product/Process CR PC050409-1CM Detail

Description Of Change

To illustrate, if a CLEC receives notices by category (e.g., product or process), Qwest could make a red lined change as a product notice and another overlapping change to the same PCAT as a process change. Considering that the same CLEC employee may not review both types of notices, an employee would not be aware that one red lined PCAT does not accurately reflect the PCAT as it will appear when the previous change goes in to effect. That could significantly impact how the CLEC may comment on, or react to, the change.

An example occurred with respect to the expedite PCAT. Qwest initiated a series of overlapping proposed PCAT changes that were so complicated that, on Nov. 18, 2005 in PROS.10.19.05.F.03380. ExpeditesEscalationsV30, Qwest had to provide the following timeline, in response to CLEC complaints of confusion: (See attached example)

Naturally, CLECs would like to avoid such confusing and overlapping Qwest changes and proceed in an orderly manner to review and respond to proposed changes. Qwest should not propose additional changes to the same PCAT in a manner that prevents CLECs from readily knowing the full impact and relationship of the changes.

Another example (also involving expedites): Qwest recently indicated it intended to make overlapping PCAT changes (relating to compliance with an Arizona Commission order in the Eschelon Arizona complaint case against Qwest, Docket No. T-03406A-06-0257) with respect to the expedite PCAT. Integra expressed concern in a Nov. 26, 2009 email to Qwest, in which Integra said: “Part of the problem that led to the AZ expedites case was due to Qwest using overlapping notices, causing confusion, and we had hoped that experience would have led to Qwest not issuing notices so close in time.” Qwest has not provided any assurance that it will not make overlapping changes going forward.

Qwest should not send multiple, overlapping notices regarding changes to the same PCAT or Technical Publication. With appropriate planning on Qwest’s part and attention to the CMP deadlines, any instance in which an overlapping change is needed would be rare. In such rare instances, if it is necessary to make additional changes to the same PCAT or Qwest Technical Publication before the previous changes have gone into effect, and a change will not be reflected in the red line, Qwest should communicate in the notice for the additional changes that there is a pending notice/change that is not reflected in the red line associated with the additional changes, and Qwest should provide the notice number and link to the proposed changes in the previous notification, as described in the enclosed proposed redline of Section 2.6 of the CMP Document.

Qwest will make mutually agreeable changes to the CMP Document to implement this CR (such as the proposed changes shown in the enclosed proposed redline of Section 2.6 of the CMP Document). The purpose of the changes will be to ensure that, absent an urgent or critical business need to do so, Qwest will not send notices that overlap, for a single PCAT or Technical Publication (or any document Qwest is red lining as a part of the associated notice of change). Qwest will allow the applicable CMP deadlines to complete before initiating additional proposed changes. In unusual circumstances, due to an urgent or critical business need, Qwest may issue overlapping notices but only if it follows the procedures outlined above (and in the attached proposed changes to the CMP Document) to ensure that CLECs are aware that there are other pending proposed changes to the same document.

Project Meetings

Mark Coyne-Qwest said that this CR is proposing updates to Section 2.5 of the CMP Document to add increased clarity in Qwest-initiated proposed documentation changes, including avoiding overlapping notices and modifying notices if an overlapping change is unavoidable. Mark said that a vote will be conducted today.

Lynn Stecklein-Qwest said the redline is included in the distribution package. Quorum is 7 and has been achieved. In Section 2.1 of the CMP document it states that incorporating a change into the Change Management Process requires unanimous agreement.

A vote of ‘Yes’ will indicate a preference that Section 2.5 of the CMP Document be updated to include clarity in Qwest initiated proposed documentation changes, including avoiding overlapping notices and modifying notices if an overlapping change is unavoidable.

A vote of ‘No’ will indicate a preference that Section 2.5 of the CMP Document not be updated to include clarity in Qwest initiated proposed documentation changes, including avoiding overlapping notices and modifying notices if an overlapping change is unavoidable.

Lynn said Qwest has received 3 ‘Yes’ votes from Qwest, Verizon Business and Comcast via e-mail. One abstain vote was received from Action Communications, Inc. The meeting participants voted as follows: Integra – Yes, PAETEC – Yes, Covad – Yes, TDS Metrocom – Yes, Time Warner Telecom – Yes

The vote was granted with 8 ‘Yes’ votes, 0 ‘No’ votes and 1 ‘Abstain’ vote. A vote disposition notice will be sent and the change will be made to the CMP document.

6/20/09 Product/Process CMP Meeting

Mark Coyne-Qwest said that in the May meeting we had a discussion regarding Integra’s changes to Section 2.5. Mark said that Integra presented their redline changes and Qwest also submitted its proposed changes to that language. Mark said that Integra has reviewed the change and has made additional changes. Mark said that we are in the process of reviewing and hope to bring this to a close in July.

Bonnie Johnson-Integra said that the document on the calendar is the redline that she and Julia used after Qwest redlined their changes. Bonnie said they accepted those changes and what you see is language that is currently not in the CMP document. She said that when we reach consensus there will be a lot more changes than this. She said it easier to accept changes rather than work from the original CMP document.

5/20/09 Product/Process CMP Meeting

Bonnie Johnson-Integra said that this CR was submitted as a joint request by Integra and PAETEC. Bonnie said that it is an ongoing challenge for the CLECs when there are multiple notices issued for one PCAT. She said that one of the problems is that until a proposed change is effective and if another change goes out for the same PCAT; the redline doesn’t include the final result of the notice that is not yet effective. Bonnie said that this could impact the end result and how they view the subsequent changes of the other language being changed. They are proposing that Qwest avoid doing multiple overlapping changes unless it’s required, i.e. a regulatory change or to change a phone number. If for some reason Qwest needs to issue an overlapping notice, Qwest needs to identify there is another pending change to that document that has not yet posted and is not reflected in this redline.

Julia Redman-Carter PAETEC said that the process of having changes that aren’t yet effective is sometimes referred to as stacking. She said that if Qwest does stack they need to let the CLECs know what is being stacked. They need the full picture so that they can make an informed decision (5/28/09 Comments to minutes received from PAETEC in CAPS) AND NOT realize TILL LATER THAT there WERE other pieces they may not HAVE been aware of WHEN ORIGINALLY REVIEWED. Mark Coyne-Qwest said that Qwest can appreciate what the CLECs are saying in this CR. He said that it is a challenge for the documentation team that updates the PCATs when this occurs. Mark said that we do try to keep this to a minimum but based on business needs that come along it does happen. Mark questioned the sentence in the proposal where it states that this needs to happen on rare occasions and asked how the CLECs define rare.

Bonnie Johnson-Integra said some level 1 changes impact the way they do business and those occasions are rare and considered immediate, i.e. correcting a phone number or if you have a regulatory change. Bonnie said that it sounds like this may help Qwest as well.. It appears when Qwest reviews a tech pub or PCAT and makes a change other things are done that need clarity or clean up. She said that it appears that when Qwest identifies changes are needed, they issue level 1, 2, 3 etc. Bonnie said that something to consider is that unless those level 1’s or 2’s are critical business needs or something that impacts the way they do business with Qwest, is to issue those changes in one change rather than issuing separate levels for 1 PCAT. She said that their recommendation is, rather than doing all changes in separate notices, do them at the highest level of change.

Mark Coyne-Qwest said that he realizes these types of changes do present difficulty for the documentation team to track and is a challenge to both Qwest and the CLECs. Mark said we took at look to determine how often this has occurred and found only found 17 occurrences in the past 2 years. Mark said that this is in relation to approximately 977 notices and is less than 1%. He said that these situations will continue to occur on a rare basis as it has in the past. He said that we are in full agreement with the 2nd part of the CM request which is how we relate those changes on the notice to make sure the CLEC are aware of those changes. Mark said that he liked the idea of cross referencing or pointing the CLEC to the notice so the CLECs can determine the impact. He said there is a concern with the statement in the proposal that Qwest will not initiate a proposed change. Mark said we can’t say that we will never initiate a change and that the proposal does include except in certain conditions. He said that we have a counter proposal with language in the 1st piece to accommodate our business needs, but at the same recognizing that this is a rare occasion. Mark said that if this happens we will address it with information on the notice. Bonnie Johnson-Integra said that PAETEC and Integra will look at the counter proposal and is good to hear we are in agreement that we need to care for the issue. Bonnie said that they can’t agree with the change from “will” to “should” because it does not give them any certainty.

Mark Coyne-Qwest asked that the CLECs review the entire counter proposal and let us know what concerns and comments they have and we will go back and take a look at “will” vs. “should”.

Bonnie Johnson-Integra asked Qwest to let them know what they are trying to achieve by changing the language to not having any certainty. She said that “should” won’t work for the CLECs and “will” won’t work for Qwest but until they know what the concern is, she doesn’t know what to propose.

Julia Redman-Carter-PAETEC asked if Qwest would consider the idea when there are previous changes not yet effective, to note in the document that there are changes under review that are not yet effective and in the document redline highlight those changes.

Mark Coyne-Qwest said that we don’t have a problem pointing back to the Document Review site so that you can see the related notice.

Julia Redman-Carter-PAETEC said if there was another solution (5/28/09 Comments to minutes received from PAETEC in CAPS) THAT MIGHT BE EASIER for Qwest other than providing the information in the notice, they will entertain other suggestions. THE PURPOSE OF THE PROPOSED CHANGE IS to be able to identify ALL the APPLICABLE changes in those situations SO WE CAN MAKE INFORMED DECISIONS.

Mark Coyne-Qwest said that he didn’t see a problem on the 2nd piece of providing the notice number and providing a link back to the document review site rather than including the information on the subsequent notice. Mark addressed the comment from Integra on the “will” vs. “should” and it was phrased it in the 1st sentence that Qwest will attempt to avoid issuing or initiating those types of changes.

Bonnie Johnson-Qwest said that if there is an overlap notice it needs to address how you are going to handle and the result if that happens. She said that the 1st part talks about the effort or attempt and the 2nd part should have certainty if unavoidable.