Wholesale: Products & Services

Open Product/Process CR PC073007-1 Detail

Description Of Change

Project Meetings

- September 11, 2007 Email Sent to Sprint: Jeff, This email is to provide you with the Qwest response for your submitted Change Request PC073007-1 Reduction in LNP Interval (Simple Port / No Qwest Facilities). The response is located in the Qwest Response portion of the attached document. This CR will be included in the September Product Process CMP Distribution Package. The September CMP Meeting is scheduled to occur on September 19, 2007. Thank you, Peggy Esquibel-Reed Qwest Wholesale CMP

- August 15, 2007 Product Process CMP Meeting Discussion: Jeff Sonnier-Sprint presented the CR and noted that the CR results from their cable partners encouraging Sprint to work with their ILECs for a 1-line residential customer interval from 3-days to 1-day. Jeff stated that this would be when there are no facilities on Sprint new connects that would involve Qwest. Jeff said that he is hoping that Qwest will analyze this request and respond next month. Mark Coyne-Qwest stated that the Clarification Call had been held and that Qwest is meeting internally in order to analyze the request and stated that Qwest would provide status next month. This CR moves to Presented Status.

-- August 13, 2007: No Feedback Received For 8/8/07 Clarification Meeting Minutes.

August 8, 2007 Email Sent to Jeff Sonnier-Sprint and Kim Isaacs-Eschelon: Good Afternoon, I have attached the meeting minutes from the August 6th Clarification Call for PC073007-1 Reduction in LNP Interval (Simple Port/No Qwest Facilities). Please review the document to ensure that your comments were captured accurately. Please provide your proposed changes no later than 9:00 a.m. MT, Friday, August 10, 2007. Please track your changes. Thank you, Peggy Esquibel-Reed Qwest Wholesale CMP

- August 6, 2007 Clarification Meeting PC073007-1 Reduction in LNP Interval (Simple Port / No Qwest Facilities) Introduction of Attendees: Jeff Sonnier-Sprint, Kim Isaacs-Eschelon, Peggy Esquibel Reed-Qwest, Vicki Dryden-Qwest, Susie Wells- Qwest, Connee Moffatt-Qwest, Carol McKenzie-Qwest, Denise Martinez-Qwest, Chuck Anderson-Qwest Review Requested (Description of) Change: Peggy Esquibel Reed-Qwest reviewed the CRs title and description of change Peggy Esquibel Reed-Qwest asked if Sprint had any additional information to share regarding this request. Jeff Sonnier-Sprint noted that his customer’s are pushing for this request from all of the ILECs. Peggy Esquibel Reed-Qwest stated that the Exception Process Requested check box was marked on the submitted CR and asked if there was an exception to the process being requested or if the box was checked in error. Jeff Sonnier-Sprint stated that the box was checked in error. Confirmed Impacted Area(s): Peggy Esquibel Reed-Qwest confirmed that this request is for Provisioning Confirmed Impacted Products: Peggy Esquibel Reed-Qwest confirmed that this request is specifically for LNP / REQTYP = CB, and ACT = V, W, or Z. Confirmed Impacted Interfaces: Peggy Esquibel Reed-Qwest stated that this request was marked as both Product Process and Systems. Peggy stated that it may be only a Product Process change and that no systems work should be required. Jeff Sonnier-Sprint stated that from a systems perspective, if this request is accepted, it would be for orders to be accepted. Kim Isaacs-Eschelon asked Jeff (Sonnier-Sprint) to define a simple port. Kim asked if he was referring to a 1-line residential. Jeff Sonnier-Sprint said yes, with no facilities involved. Peggy Esquibel Reed-Qwest asked if there were any additional questions. There were none brought forward. Peggy Esquibel Reed-Qwest then stated that this CR is scheduled for Sprint to present the CR to the CLEC Community at the August 15th Product Process CMP Meeting. Peggy then noted that Qwest would then provide the response to this request by the September CMP Meeting. The meeting was concluded.

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CenturyLink Response

For Review by the CLEC Community and Discussion at the September 2007 CMP Meeting

To: Jeff Sonnier, Sprint

This letter is in response to CLEC Change Request number PC073007-1 Reduction in LNP Interval (Simple Port / No Qwest Facilities)

CR Description as written by Sprint: Sprint requests that Qwest change their standard interval for LNP (REQTYP=CB) orders from 3 business days to 1 business day. This change would bring the interval in-line with the time frames used for wireless porting. Based on recent determinations that the two processes are very similar for simple ports, and there are no facilities involved with the change, we feel this request is justified. Additionally, OBF/LSOP Issue 3065 was put into final closure at the May OBF meeting to reduce the number of fields required on a simple port order (ELT=A or B).

Qwest Response: Qwest’s three business day interval is currently shorter than the 4 days recommended by the FCC which includes 24 hours for the FOC. Qwest’s three day interval absorbs the FOC interval, whether the request is electronic or manual.

The proposed change to the due date interval would pose potential risks to Qwest and to the customer. Porting triggers must be set by 11:59PM the day before the due date. A shortened interval to 1 day would not allow Qwest sufficient time to correct errors or detect issues when the triggers are not automatically set.

Even with the current 3 day interval today, Qwest is often requested to work back port orders due to out of service conditions. A shortening of the porting interval would most likely increase the number of customer service issues and result in increased work backs for Qwest.

Qwest is therefore denying your request for PC073007-1 for no demonstrable business benefit due to the increased risk of customer service outages, and due to the fact that shortening the interval would increase the risk of the triggers not being set and worked in a timely manner within the NPAC existing interval of 18 business hours.

Sincerely, Qwest Corporation