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.

-

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 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 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

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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

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.

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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 5608353 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

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

Open Product/Process CR PC073101-7 Detail

Description Of Change

Granted the process of the 48 pre-testing will catch most of these ahead of cut date, things happen on cut date that cannot be prevented. Allegiance wants the decision to bring the lines over or not to be the CLEC’s call.

Status History

Project Meetings

Action : Linda Hendricks will provide definition of Qwest 'flexibility' on cut date. Allegiance will submit a new CR to clarify the Qwest process when dial tone problems are on the Qwest side.

August 23rd, 2001 Clarification Meeting 1-866-289-7092 PC 741-1286 # PCCR073101-7

Terry Wicks/Allegiance Patrick Weston/Allegiance Doug Barman/Allegiance Linda Hendricks/Qwest Todd Mead/Qwest Introduction of Attendees Terry, Patrick, Doug, Linda and Todd Review Qwest Response Linda’s response to the original CR (PCCR073101-7) was discussed. Essentially Qwest will not hand over bad circuits to a CLEC. In mitigation, Qwest has implemented the 48/1 hour DT test on July 29, 2001 to resolve this issue. There is also the opportunity for the CLEC to split the order and have the bad circuits moved to another LSR. CLEC Response Allegiance accepted that when there is no DT on the Qwest side, Qwest should not hand over circuits until the problem has been resolved. Allegiance’s position is that they would still like to be able to take the circuit. If Qwest is consistently pre-testing on their side at least 48 hours prior to cut date, then the number of incidents of bad facilities on the Qwest side on cut date should be minimal. Allegiance will track and report accordingly. Allegiance will not pursue the issue at this point when the circuit is “bad” on the Qwest side. However, they will be pursuing to take the circuit when the problem is on Allegiance’s side. Allegiance agreed that the 48/1 hour DT test implemented on July 29 should substantially reduce the number of occurrences related to this issue on the Allegiance side. However, when the “no DT” is on the CLEC side, Allegiance wants to have the circuits passed over “as is”, and do not want to split the order. Allegiance has options to get the end user service on any “broken” line when the NDT is on their side. Once the TN is activated and Allegiance has the number in their switch, they can call forward the line to another line or to cell phones they supply to the end user. Allegiance has processes in place that they use daily with this type of situation when dealing with the other LECs. Allegiance would like to be able to use their processes in this situation with Qwest as well. Allegiance is prepared to escalate as needed if this cannot be resolved at this level. Confirm Right Personnel Involved Scott Simanson, VP and Fred Aesquivel Director (Qwest) need to be involved to make the final determination on Qwest’s position with respect to this issue. An internal meeting involving these people needs to take place. Todd will organize. Identify/Confirm CLEC’s Expectation Allegiance wants Qwest to hand over good circuits if the “no DT” is on the CLEC side. Allegiance stated every other ILEC they deal with (including PacBell, SW Bell, Bell North and South, Verizon and Ameritech) do this, as part of their normal business. Establish Action Plan (Resolution Time Frame) Review these minutes as an accurate account of this mornings discussion Set up a meeting with Scott, Fred and Linda to discuss Qwest’s position and draft a response. Set up a walk-through meeting with Allegiance to discuss the Qwest final response.

08/23/01 - Clarification Meeting Allegiance - Terry Wicks, Patrick Western, Doug Baram Qwest - Linda Hendricks, Todd Mead

Allegiance accepted that when there is no DT on the Qwest side, Qwest should not hand over circuits until the problem has been resolved. Allegiance agreed that the 48/1 hour DT test implemented on July 29 should substantially reduce the number of occurrences related to this issue. However, when the “no DT” is on the CLEC side, Allegiance wants to have the circuits passed over “as is”, and do not want to split the order.

08/09/01 - Alignment Meeting Terry Wicks/Allegiance Qwest - Scott Simanson, James Mackie,Dana Frenking, Linda Hendricks, John Moore, Cindy Buckmaster, Nancy Hoag, Lisa Schuzer

Turning up loops that do not meet Qwest test requirements or do not have CLEC DT on them. Their example was if they send in an LSR with 10 loops and 2 do not have CLEC DT on them or if Qwest has a facility problem, Qwest should allow Allegiance to make the decision to accept all of the orders even if problems exist. They want Qwest to close the order and open a repair ticket to provision the loops with the problems. No CLEC DT concern: Turning up loops that do not meet requirements will leave Qwest and the end user in a vulnerable position. If the CLEC decides they can't get DT working after we have closed the order and (if applicable had the translations ran), the end user customer could be out of service. Qwest wouldn't be able to work the order back, because it is closed. In order for the end user to get back to Qwest they would need to issue a WINBACK order and the CLEC would need to issue a disconnect order on the "BAD circuit/loop turned up". Qwest's facilities concern: If Qwest has the problem and our facilities are bad or maybe in some cases won't be built out at all, the following could occur if loop is turned up bad: mask facility issues on Qwest side (or perceive that is what we are doing) open the door for repair PID issues open our selves up to many issues from provisioning to repair PID measurement accuracy billing on a bad loop

CenturyLink Response

Wholesale Product Marketing

This letter is in response to the following CLEC Change Request Form PC073101-7 dated 07/30/2001. The Change Request related to Qwest’s current practice to not complete all circuits and/or orders on a given LSR, when there is known trouble either in the Qwest or CLEC network on one or more of the circuits being turned up.

In an effort to minimize the risk of the of an out of service condition during a migration, and to ensure the readiness of all parties to maximize success, Qwest has put the following process improvements in place:

48-Hour Dial Tone Check – Qwest Central Office Technician (COT) tests for Dial Tone at the CLEC CFA on the ICDF 48 hours prior to the scheduled cut. If Dial Tone is not present, the COT notifies the Qwest QCCC Coordinator, who in turn notifies the CLEC. This gives the CLEC 48 hours to correct the no dial tone condition.

1 Hour Dial Tone Check – Qwest COT tests for Dial Tone at the CLEC CFA on the ICDF 1 hour prior to the scheduled cut. If Dial Tone is not present, the COT notifies the Qwest QCCC Coordinator, who in turn notifies the CLEC. This second notification gives the CLEC an hour to correct the no dial tone condition.

Field Pre-Survey - Qwest Field Technicians Pre Survey outside plant facilities to identify any before due date. If Field Technicians determine that facilities are not available or acceptable for the service ordered, the Technician invokes an internal Qwest process to search for other facilities or place the order in a held status if suitable facilities are unavailable. The CLEC is then notified of the Held status.

Order Splitting – Qwest has offered to “split” orders on an LSR and “supp” the order with the circuit with the trouble condition at the time of the cut, allowing the CLEC the necessary time to correct the known condition.

After considerable deliberation and reconsideration, Qwest will continue to follow its practice to not turn over circuits that do not meet all defined standards at the time of the migration. CLEC’s retain the right to escalate and to petition through the Bona Fide Request (BFR) process.

Respectfully,

Frederick M Aesquivel III Director – Local Network Operations Support

CC: Scott Simanson Linda Hendricks Dana Filip

Open Product/Process CR 5548229 Detail

Description Of Change

Status History

Project Meetings

Allegiance (Wicks) agreed this CR could be moved to “Completed” status. Allegiance did indicate they would like to see a higher level of compliance in this area. Currently they are still not receiving updated FOC’s 30% of the time.

-

"'Russ Urveig'" cc: "'Kit Thomte'"

Subject: Allegiance - Same Day CFA Changes - No Updated FOCs Week of 7/15 - 7/19

Here is the last spreadsheet that I will send to you for updates. Beginning 7/22 we are using the new process to release busy CFAs should the situation arise.

There was only one PON that we did not get an updated FOC on last week. Please confirm the CFA change was corrected on you records for PON 1388133-LP and return the updated spreadsheet to me. Thanks.

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

07/17/02 - July CMP Meeting Minutes: Qwest (Buck) provided the following status. Qwest had provided information back to Allegiance on the spreadsheet they have been tracking from. Allegiance agreed that they would begin using the escalation process on July 22. Qwest indicated that in the interim the escalation information has been provided to the CLECs to allow everyone to use the process. Worldcom inquired how someone that did not attend CMP could get the information. Qwest responded that the information was updated in the Qwest Raw Loop Data Qualification Tool Job Aid. This CR will remain in "CLEC Test" until the next CMP meeting to determine if the process is working properly and can be closed.

"Cheri Hurless" , "Wicks, Terry" cc: kthomte@qwest.com

Subject: Spreadsheets

Here is the completed spreadsheet for the CFA changes and no FOC sent, if you have any question please get with Cheri. There was only one request for CFA change where as the records were incorrect, I had a service order issue to correct the problem and it was due dated today. Just to clarify the spread sheet, in the column for NO FOC if the correct CFA was applied in TIRKS and the service order, I place an OK next you your N indicator. In the Comment section I just stated CFA verified. (See attached file: Same Day CFA Spreadsheet No FOC Master.xls)

I believe we have made great improvements on the FOC during the last several week and in all but 1 case the CFA had been correctly changed. I feel that this spread sheet should be discontinued and any concerns for CFA changes should move to the BUSY CFA activity, but only after the CFA query function had been performed on both the old CFA to make sure it is vacant and against the new CFA tom make sure it is busy. Any time we take activities out of the normal process flow and I an referring to requesting a CFA change without documentation there are extra steps we both must take to work together. Thanks for all your feed back on this matter Terry, and I look forward to closing this CR. Russ,

Here are my latest examples of not receiving updated FOCs on same day CFA changes.

5/20/02 thru 5/24/02

1268042-LP Received Updated FOC 1253525-LP Did Not receive updated FOC 1275739-LP Did Not receive updated FOC 1273724-LP Received Updated FOC 1272870-LP Received Updated FOC 1265872-LP Received Updated FOC 1277072-LP Received Updated FOC 1270017-LP Received Updated FOC 1276114-LP Received Updated FOC 1153382-LP Received Updated FOC

5/28/02 thru 5/31/02

1296008-LP 303-706-9024 Did Not receive updated FOC

1284062-L 480-237-0350 Did Not receive updated FOC 1308512-L1 480-966-8198 Did Not receive updated FOC 1295225-LP 303-781-8307 Received Updated FOC Received Updated FOC

1287395-L 303-771-0816 Received Updated FOC 1301207-LP Did Not receive updated FOC

1301991-LP Did Not receive updated FOC 303-762-9176 1278540-LP Received Updated FOC

1303185-L Received Updated FOC 1307043-L Did Not receive updated FOC 1303880-LP Received Updated FOC

1309037-LP Received Updated FOC 1309503-LP Did Not receive updated FOC 1292144-L Did Not receive updated FOC 1301212-LP Received Updated FOC

1285714-LP Received Updated FOC

Terry Wicks LEC Account Manager allegiancetelecom, inc 469-259-4438

Subject: CFA'S FOR 5/13/02 THRU 5/17/02

FOC 1242682-LP TN 720-932-8789 NEW 1263 OLD 1299

FOC 1257259-LP TN 303-755-3199 NEW 829 OLD 814

FOC 1284374-LP TN 206-323-1751 NEW 1279 OLD 1259 AND 1341 SHOWS WORKING IMA

NO FOC 1211795-LP2 TN 752-888-7554 NEW 247 OLD 276

FOC 1261532-LP TN 623-931-8086 NEW 808 OLD 768

FOC 1265023-L TN 303-991-0119 NEW 696 OLD 1183

FOC 1280325-MVL TN 763-576-6636-1 NEW 152 OLD 161

Thank you and have a good day,

Tasha Nichols/Supervisor Qwest/Verizon West 469-259-4823 fax 469-259-9051 tasha.nichols@algx.com

CenturyLink Response

Terry Wicks LEC Account Manager Allegiance Telecom

SUBJECT: Qwest’s Change Request Response - CR 5548229 Same Day Pair Change

This letter is in response to your recent request regarding the Escalation process associated with busy CFA. A subsequent request was made to include information to the CLECs regarding how they should initiate an escalation for busy CFA.

Below is the information that is necessary to initiate an Escalation for busy CFA.

Busy Connecting Facility Assignment (CFA) is defined as; When validating the CFA the slot shows that it is currently in use by a circuit in the Trunk Integrated Record Keeping System (TIRKS). The busy CFA can be the result of several different reasons: normal activity, pending service order activity, pending Inventory Availability Date (IAD) issues, and canceled service orders that have not cleared in TIRKS. Should you receive an indicator that the CFA is currently in use, however you records indicate the CFA is NOT in use, an Escalation ticket may be opened.

Information that is required for an Escalation ticket will be for BUSY CFA problems.

1. TERM Z TYPE LONG CLLI (ex.ALBONMNEHG1)

2. TERM A TYPE SHORT TYPE CLLI (e.g., ALBQNMNE)

3. CABLE TYPE (e.g., alt01)

4. UNIT NUMBER (e.g., 086)

5. Was there a disconnect request submitted to free CFA location. (EX. Yes, a disconnect request was submitted and an FOC was received. The PON number for the disconnect was AAA121211-MA)

6. Was the Slot changed during installation? If so what was the old slot and what should the current slot be? (EX. Yes, we changed the CFA during test and turn-up the previous CFA was ALT01 slot 89 TCANAZMAHG1 and slot changed to slot 91. The PON number associated to this change was AAA121211-MA)

7. Was there any migration activity on this CFA? (EX. Yes, we should that a migration to another Provider on 06/17/2002)

8. Want type of request were you attempting when you encounter the busy CFA problem? (EX. We were attempting to request a new loop and utilize this CFA, or we were attempting a change activity against circuit 99.LXFU.000111.nw.)

9. Were there any change activity against the circuit, if so PON number for activities. (EX. Our records show a change activity should have taken place on 06/17/2002 from PON AAA121211-MA to free this CFA. Or our records indicate a disconnect request on 06/17/2002 on PON AAA121211-MA which should have freed the CFA.)

If you have any questions regarding this information please feel free to contact me.

Sincerely,

Russ Urevig Senior Process Analyst

01/07/02 Response to Allegiance e-mail dated 12/28/01 January 7, 2002

Terry Wicks LEC Account Manager Allegiance Telecom

CC: Catherine Garcia

This letter is in response to your e-mail dated Friday, December 28th, 2001 – Allegiance – Same Day CFA Change – No Updated FOC Received.

Response: Since we have received examples of FOC’s not being sent to the CLEC’s when a CFA has been changed, new focus on this process has been brought forward. The QCCC have put the following procedures in place to insure that the CFA process is followed.

- All testers have been re-trained on the CFA Change Process.

- Four compliance reviews, for each tester, are completed every month focusing on compliance to the CFA Change Process.

- Performance managing is being done to insure the CFA Change Process is being complied with. If a tester fails their compliance review, there is documented discussion around the issue.

- Weekly Leadership meeting are held to discuss issues for the center. The CFA Change Process has been brought forward during these meetings to insure that the process is understood and followed.

Sincerely,

Deni Toye Network Unbundled Loop Process

October 10, 2001 Terry Wicks, Allegiance

This letter is in response to your CLEC Change Request Form CR5548229 dated August 30, 2001, Request:

Allegiance has sent Qwest examples of orders when Allegiance had problems on same day CFA changes. Allegiance was not receiving FOC’s back specifying that a CFA had been changed. Allegiance would like to know that there is a process for a CFA change on test and turn up for the same day.

Qwest Response: There was a process put into place to allow the CLEC to have a CFA change before or on the due date. On August 9, 2001 a process was put in place to allow this activity to happen. Terry Wicks sent some examples to show that the process is not working. After investigation of these orders, it was determined that a process is in place and does work, however, there are isolated cases of non-compliance issues. The orders that Terry sent to us did have the CFA changed the day of the due date, however, non-compliance to the process did not produce a call to the SDC, therefore, a FOC was not sent to the CLEC. These examples have been forwarded to the centers for process compliance verification.

Sincerely,

Deni Toye Network Unbundled Loop Process

Open Product/Process CR PC092701-1 Detail

Description Of Change

These DID numbers were for the local police and fire station in this city. Due to the inaccurate CSR we left a two-way trunk with Qwest which disrupted the hunting (this line had a DPA on it that the customer wanted to keep). There were two sets of DIDs that were not addressed so when the TFD trunk they were riding on was ported the DIDs went down. The only way we were able to find the additional DIDs was by call Qwest for assistance.

Status History

Project Meetings

Name/Company: Terry Wicks, terry.wicks@algx.com, Allegiance Monica Manning, mxmanni@qwest.com, Qwest Susie Wells, sdwell2@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest

Introduction of Attendees Terry, Monica, Susie, and Kate Review Requested (Description of) Change Develop a process for CLECs to get a “full” CSRs on DID numbers. Confirm Areas & Products Impacted Areas: Pre-Ordering / Ordering Products: Resale Confirm Right Personnel Involved Monica Manning is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. Susie would like to stay informed as to response and is available for questions pertaining to her area. Terry Wicks would like to stay informed as to response. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and send information to Mike Keegan and Matt Rossi to store to database. Identify/Confirm CLEC’s Expectation Allegiance is requesting that a process be developed by Qwest to allow CLECs to be able to retrieve a full and complete CSR for all DID numbers for a specific End User at a specific location. Currently Allegiance is not confident that the information received through IMA is accurate. We have had several instances of End Users going down after conversion due to DIDs not being addressed. The reason for this is that not all DIDs are showing up on the CSRs. One example is for City of Tukwila BTN 206-433-1800. The CSR we pulled in IMA only shows the block 206-433-1844 to 1851 when in actuality the range goes to 1871. Qwest also advised us the DID 206-433-1856 did not exist. This meant that there was a break in the range of 206-433-1844 to 1855 then 206-433-1857 to 1871. DID range 206-433-7140 to 7199 is totally unaccounted for on the CSR.

These DID numbers were for the local police and fire station in this city. Due to the inaccurate CSR we left a two-way trunk with Qwest which disrupted the hunting (this line had a DPA on it that the customer wanted to keep). There were two sets of DIDs that were not addressed so when the TFD trunk they were riding on was ported the DIDs went down. The only way we were able to find the additional DIDs was by call Qwest for assistance. To clarify, two points are being addressed: ? When you pull a CSR and submit a request, the phone numbers aren’t on the CSR in the LSR. Is it then rejected? If so, why don’t they show up in the CSR if they are rejected? Terry gave the following examples: Here are the PONs where we ported these DID ranges: PON 699510-NP 206-431-3650 thru 3689 699510-NP1 206-431-3890 thru 3899 699510-NP2 206-433-1804 thru 1843

We have not completed the porting of these PONs: PON 860171-NP1 206-433-1844 thru 1855 PON 860171-NP2 206-433-1857 thru 1871 PON 860171-NP3 206-433-7140 thru 7199

The following TNs were on our CSR but we were told by Qwest there were additional TNs not showing up: 206-433-1844 thru 1851

The following TNs were not on our CSR we pulled from IMA for BTN 206-433-1800 206-433-1852 thru 1855 206-433-1857 thru 1871 206-433-7140 thru 7199

? Additional DIB ranges need to be addressed.

Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Monica will clarify process via a written formal response draft. After clarification is received regarding possible system changes. She will forward this documentation to Kate by 10/18/01. Kate will review and forward the response draft to Mike Keegan and Matt Rossi to store in the CR database by 10/19/01 for CLEC review. The web location will be noted in Matt Rossi’s email regarding the response document by 10/22/01. This information can then be reviewed and discussed by the CLEC Community at the following CMP Meeting. Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the following CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

November 8, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc

This letter is being sent in response to CLEC Change Request Form # PC092701-1. PC092701-1 pertains to a request for a process to get a full CSR on DID numbers.

We have reviewed the list of LSRs and associated CSR you provided to QWEST for this Change Request. While it may have appeared that a Full CSR was provided to you by IMA, the Review Full CSR Response displayed a message indicating that only 52 of 61 pages were returned. This would explain why only a portion of the DID numbers for the account appeared.

The IMA User Guide provides instructions on how to retrieve additional CSR data, when the complete CSR is not displayed. This information can be found in Chapter 1 of the User Guide, under Reviewing Customer Service Records. As long as a Full CSR request does not exceed the page number limitation (300 pages in the IMA GUI, 450 pages in IMA EDI) and the CLEC is authorized, all of the CSR pages should be returned. If the instructions in the User Guide are followed, all of the CSR pages can be retrieved.

If you should encounter this trouble again while trying to retrieve a full CSR and have followed the steps outlined in the User Guide, please contact the Wholesale Systems Help Desk at (888) 796-9102 immediately. If we receive a trouble report regarding CSR retrieval "as it is occurring", we will be able to determine the root cause and correct the problem.

Sincerely,

Monica Manning IMA Process Specialist

Open Product/Process CR PC092701-2 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

Terry Wicks LEC Manager Allegiance Telecom, Inc.

This letter is being issued to revise Qwest’s response dated November 8, 2001 to Change Request PC092701-2 requesting confirmation of all WTNs for a particular End User at a specific address for a Centrex Resale Customer. Qwest is prepared to implement the attached process to accommodate the CLECs request of confirming an End User WTNs.

Sincerely,

Susie Wells Sr. Process Analyst

(See Supplemental Information following detail report for Process)

December 4, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc. And, Kathy Stichter ILEC Relations Manager Eschelon Telecom, Inc.

This letter is in response to questions/concerns generated at the November CMP Meeting regarding Qwest’s response dated November 8, 2001 to Change Request PC092701-2.

Question: Is there a manual process available to Qwest retail that was not available to CLECs?

Answer: No. Qwest retail only retrieves CSRs for the WTNS provided by their customer .

Question: Does Qwest Retail have to get all WTN Numbers from new customers?

Answer: Yes. Qwest retail has to obtain all WTNs from their customer.

Sincerely,

Carolyn Brown Director Process Management

Cc: Monica Manning

--

DRAFT RESPONSE For Review By CLEC Community and Discussion at November CMP Meeting

Wholesale Product Marketing

November 8, 2001

Terry Wicks LEC Manager Allegiance Telecom, Inc

This letter is being sent in response to CLEC Change Request Form # PCR092701-2. PCR092701-2 pertains to a request for a process to get Full CSRs on Resale Centrex lines.

An IMA System Change would be required, in order to allow CLECs to request a Full CSR for all telephone numbers for a specific end user at a specific location. For the Resale Centrex account, DPA or DEPT and LOCN selection criteria might be added to the Review/Retrieve CSR functionality in IMA. However, a Systems Change Request would need to be created for these enhancements.

Until the IMA system changes can be deployed, you had requested that QWEST develop an interim process for obtaining end user specific Resale Centrex CSRs. Because a mechanized process does not exist, our service center personnel would have to gather this information manually. Unfortunately, QWEST does not have the resources to devote to these kinds of special requests. As long as a CLEC has the appropriate authorization, full CSRs can be retrieved through IMA. In lieu of the full CSR, partial CSRs by WTN can be retrieved. When a CLEC is unable to identify all WTNs associated with a request, the end user customer will have to be the provider of the information.

Sincerely,

Monica Manning IMA Process Specialist

Open Product/Process CR PC092701-3 Detail

Description Of Change

The most recent example happened today. PON 806241-HDSL1 – The FOC date to put in the circuit for this client is 09/25/01. Qwest was at the customer premises on 09/24/01 at 5:10 p.m. to do some work. The Qwest tech who went out was extremely rude to the customer. The Tech stated he has come several times, always after closing (5p.m.) and was not happy that he did not have access to the MPOE. The tech did not identify himself until the owner mentioned another company. The owner asked the tech if he worked for End 2 End Communications and the tech got upset and simply left. Several times the Qwest techs have told the customers that they would go down if they proceeded with converting to Allegiance.

Allegiance is requesting that an improved process be put in place that the CLECs can report these occurrences of anti-competitive behavior when they happen. This process should include a single point of contact , a thorough investigation with an appropriate response to the CLECs in a timely manner. The process should also include the proper training of Qwest personnel to prevent future occurrences

Status History

Project Meetings

Open Product/Process CR PC091201-1 Detail

Description Of Change

Also what is the process to negate the charges for these cuts and how is this tracked to insure the CLEC is not billed?

Status History

Project Meetings

Introduction of Attendees Terry Wicks, terry.wicks@algx.com, Allegiance Gary Stacy, gstacy@qwest.com, Qwest W. Rob Tomlinson, wtomlin@qwest.com, Qwest Linda Hendricks, lkhendr@qwest.com, Qwest Russ Urevig, rurevig@qwest.com, Qwest Joan Wells, jmwell2@qwest.com, Qwest Deni Toye, dtoye@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest Ric Martin, rhmart2@qwest.com, Qwest

Terry, Gary, Rob, Linda, Russ, Joan, Deni, Kate, and Ric Review Requested (Description of) Change Clarify and document process for when orders are held on cut date, when Qwest has no facilities. Confirm Areas & Products Impacted Areas: Ordering and Day of Cut Products: UNE Confirm Right Personnel Involved Linda is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. Russ will forward necessary SCAT documentation to Kate. After the clarification meeting, it was determined that Gary, Rob, Joan, and Deni will not need to be involved in this CR. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and store necessary documentation to database. Identify/Confirm CLEC’s Expectation Per Allegiance, “Allegiance wants clarification about the process when the problem is on Qwest’s side – Qwest should not have to SUP orders for no facilities on cut date. Allegiance provided an example of this happening (PON 824041-LP); Qwest should investigate this example and provide a documented process and reason why this happens on cut date. Also, what is the process to negate the charges for these cuts and how is this tracked to insure the CLEC is not billed?” Per Linda, there are no non-reoccurring charges. Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Linda will clarify this process via a written formal response draft. She will forward this documentation to Kate by 9/27/01. Russ will forward the necessary SCAT documentation to Kate by 9/26/01. Kate will review and forward this information to Michael Belt and Matt Rossi to store in the CR database by 9/28/01 for CLEC review. The web location will be noted in Matt Rossi’s email regarding the response document on 9/28/01. This information can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

Terry Wicks LEC Manager, Allegiance Telcom Inc.

CC: Scott Simanson Fred Aesquivel

Re: DRAFT RESPONSE for PCCR 091201-1 For Review By CLEC Community and Discussion at October CMP Meeting" Topic: Provide the standard, documented process for when orders are held on cut date, when Qwest has no facilities Dated: 09/12/01

Dear Terry:

This letter is in response to the following CLEC Change Request Form PCCR 091201-1, dated 09-12-2001. The Change Request pertains to the Clarification and documented process for when orders are held on cut date, when Qwest has no facilities.

Qwest has a Pre Survey procedure in place to identify facility issues before due date. When it is discovered that facilities are not available or good an internal Qwest process looks for other facilities or place the order in a held status if no facilities can be located. The CLEC is then notified of the held status. The Cheyenne Held Order group notifies the CLEC after the order is placed in held. If the facility problem is found on test and turn up the CLEC is notified verbally at that time.

The orders that Allegiance inquired about on PON 824041-LP were held for facility problems on the due date, 8-29-01. The problem was discovered while trying to turn up the orders. The orders were all on Integrated Pair Gain and the process for handling Integrated Pair Gain orders was followed. A problem was discovered between the D4 channel and the SLC equipment in the Central Office. Qwest did not know of this problem until they tried to turn up the loops. The orders are being worked on to discover how to fix the problem and get the service provisioned. According to the WFA/C OSSLOG the CLEC has been advised of the progress.

Waiving the Non Recurring Charge does not apply to these orders because Qwest did meet the appointment time. The negating of Non Recurring Charge applies when Qwest does not meet the appointment time as specified on the CLEC’s LSR. MC The Missed Commitment should be applied only on Coordinated Orders (new and reuse) when Qwest misses the CLEC requested appointment time by 30 minutes or more. This MC=Y or MC causes a billing error to make the billing “fall-out” so the installation charges are dropped. This is placed on the OSSOI Cmnt/Rmk line in WFA/C. Systems captures and passes on to the billing CRIS system. When the billing error falls out, the SDC (service delivery coordinator) negates the nonrecurring charge on the customer's bill. This is how they receive their negated charges. The CLEC approved the start of the cut at 1007 on 8-29-01 by Scott at Allegiance.

Sincerely

Linda K. Hendricks Lead Project Analyst

Open Product/Process CR PC102517-1 Detail

Description Of Change

Allstream is requesting that CenturyLink automatically set up new BANs on the Bill Media requested on the CLEC questionnaire and that CenturyLink notify the CLEC when a new BAN starts billing.

Expected Deliverables:

CenturyLink will automatically set up new BANs on the Bill Media requested on the CLEC questionnaire and CenturyLink notify the CLEC when a new BAN starts billing.

Status History

Project Meetings

01-17-18 Product Process CMP Meeting Mark Coyne – CenturyLink stated that the Level 4 initial notice was sent on December 18, 2017. No CLEC comments were received during the comment cycle. The update is to the CABS Business Procedure to advise customers that, in addition to including the new BAN on the FOC that is returned, CenturyLink will also send an email to the Customer contact as listed on their current Questionnaire to provide the newly assigned BAN. The Final notice will be sent today with an effective date of February 1, 2018. The CR will be considered for Closure in the February meeting.

12-13-17 Product Process CMP Meeting Mark Coyne – CenturyLink stated that this Allstream CR was presented by Kim Isaacs last month and that a clarification call was conducted on November 6, 2017. A CenturyLink response was sent on December 6, 2017 to advise that the CR was accepted. Mark then reviewed the CenturyLink response that is included on pages 12 and 13 of the CMP package. He said a Level 4 notice will be sent on December 18, 2017 with an effective date now of February 1, 2018. Mark asked if there were any questions. There were none.

11-15-17 Product Process CMP Meeting Mark Coyne – CenturyLink stated that a new CR had been submitted by Allstream and asked Kim Isaacs to present.

Kim Isaacs – Allstream presented the CR stating that Allstream recently experienced CenturyLink establishing a new CABS BAN that was never added to its electronic transmissions or to the CABS E-bill tool as requested on our CLEC questionnaire. As a result, Allstream was not aware of the new BAN until it received an aging from CenturyLink. Allstream is requesting that CenturyLink automatically set up new BANs on the Bill Media requested on the CLEC questionnaire and that CenturyLink notify the CLEC when a new BAN starts billing.

Mark Coyne – CenturyLink added that a Clarification call was conducted on November 6, 2017 and the Meeting minutes are available. The new BAN process for CABS has not changed from IABS but there are a few new employees performing the tasks. There was a glitch in the current process and folks have been retrained. The process is for CenturyLink to send an email to all customers when a new BAN is established and to state that we will follow current media designations for electronic media, etc. CenturyLink will send a response that we will accept this CR. Mark asked if there were any questions. There were none. Mark asked Kim if that was acceptable.

Kim Isaacs – Allstream responded yes.

11-06-17 Clarification Call meeting minutes Attendees: Kim Isaacs – Allstream Rita Urevig – CenturyLink Sue Gilbert – CenturyLink Sue Kriebel – CenturyLink Ryan Gfeller – CenturyLink Mark Coyne – CenturyLink John Hansen – CenturyLink Susan Lorence – CenturyLink

Susan Lorence – CenturyLink relayed the purpose of a Clarification call for the Change Request (CR) and reviewed a high level agenda.

Kim Isaacs – Allstream said the CR was due to a recent experience in conjunction with the establishment of a new BAN for Allstream. Kim said they were not aware of the new BAN until it was on an aging report. Allstream is requesting that when a new CABS BAN is established, that it be added to the Bill Media requested on their CLEC questionnaire and that CenturyLink notify the CLEC when a new BAN starts billing. Susan Lorence – CenturyLink said the SME team has done some preliminary investigation.

Sue Kriebel – CenturyLink said the “new BAN” process has not changed when we went from IABS to CABS. Sue said some new employees were trained on the process following the Access consolidation but that the select group has been retrained. Sue said she wanted to nr sure she understands the request. The CR states that Allstream wants to be notified when a new BAN starts billing but Sue said the process is to notify when the BAN is created by the service order team vs. when it starts billing. Sue asked if that made sense. She said CenturyLink used to have a process that the BAN might be established and not bill for awhile which is not the case now. Kim Isaacs – Allstream said yes that made sense to notify when the BAN is established. Sue Kriebel – CenturyLink asked who the notification would go to for Allstream so we insure that the notification is sent to the correct person.

Kim Isaacs – Allstream provided the name as listed on their current Questionnaire but said that person was out on leave and provided the backup name that would be included in the out of office message.

Susan Lorence – CenturyLink reviewed the next steps for the CR which was to have Allstream present the CR in the Product Process monthly meeting on Wednesday, November 15. We will follow-up with a CMP response to accept the CR and relay that CenturyLink believes it was a one time training situation which has been addressed. Susan said she was not sure a notice was required to the full CLEC community since it was a one off.

Mark Coyne – CenturyLink said that this resolves the problem for Allstream but asked if it addressed the problem for all customers.

Susan Lorence – CenturyLink said the process would be followed for all customers. CenturyLink is confirming that the additional training will resolve this and that no other internal process changes will be required. We will provide that as part of the CR response

Kim Isaacs – Allstream said that was fine and she will present the CR in the monthly meeting. Susan Lorence – CenturyLink asked if there were any questions. There were none.

The Clarification call ended at 1:20 PM MT.

CenturyLink Response

Kim Isaacs, Allstream

SUBJECT: Allstream Product Process Change Request PC102517-1, CenturyLink Response for Review

This letter is in response to Allstream Change Request PC102517-1, entitled “New BAN Establishment Process and Notification”

CR Description: Allstream recently experienced CenturyLink establishing a new CABS BAN that was never added to its electronic transmissions or to the CABS E-bill tool as requested on our CLEC questionnaire. As a result, Allstream was not aware of the new BAN until it received an aging from CenturyLink.

Allstream is requesting that CenturyLink automatically set up new BANs on the Bill Media requested on the CLEC questionnaire and that CenturyLink notify the CLEC when a new BAN starts billing.

History: The CR was received on October 25, 2017. A Clarification call was held on November 6, 2017 with Allstream and CenturyLink representatives present. During the Clarification call, CenturyLink relayed that the new BAN process for CABS had not changed from IABS but there were some additional employees performing the task. This small number of additional CenturyLink employees have been retrained on the current process which is for the newly established BAN to be set up to follow current media designations for electronic media, etc.

CenturyLink Response: CenturyLink is accepting this CR and is proposing that a Level 4 CMP notification be sent to communicate an additional step that CenturyLink will take to provide the new BAN to customers. An update will be made to the CABS Business Procedure to relay that in addition to including the new BAN on the FOC that is returned, CenturyLink will also send an email to the Customer contact as listed on their current Questionnaire to provide the newly assigned BAN. The proposed effective date will be in late January 2018.

Sincerely,

Susan Lorence CenturyLink Wholesale CR Project Manager

Open Product/Process CR PC021318-1 Detail

Description Of Change

Allstream is requesting that CenturyLink include this USOC information on the PROD:Rate notices. UPDATE: 4/18/18: Allstream is also requesting that CenturyLink included the existing rate and proposed rates along with the USOCs on rate notifications.

Expected Deliverables/Proposed Implementation Date (if applicable):

CenturyLink will include USOCs [4/18/18 Update existing rates and proposed rates] impacted by rate changes on the PROD:Rate notifications.

Status History

Project Meetings

Nancy Taylor – Allstream said she agreed.

05/16/18 Product Process CMP Meeting Mark Coyne – CenturyLink advised that this Allstream CR was presented by Kim Isaacs in the April meeting. He told callers that the CenturyLink draft response is included on page 15 of the package. He advised that CenturyLink accepts the original CR. CenturyLink proposes that a Level 1 notification be sent to communicate that: • The rate change notifications will include Reseller intrastate USOCs in the legacy Qwest 14-state region. • This change is temporary as long as USOCs are used in the local service request ordering and billing process. Product Codes and Price Plans associated with products and services ordered via EASE and billed in Ensemble are not considered part of this change request. • In the event the complete list of the affected USOCs may not be available at the time the rate notice is required to be distributed, CenturyLink will provide the tariff reference and location. Mark Coyne – CenturyLink stated that the Allstream revision to the CR that requested existing and proposed rates is still under review and will be reviewed and discussed in the June meeting.

Kim Isaacs – Allstream asked when the situation regarding the USOCs not being available would apply.

Mark Coyne – CenturyLink stated that he did not think it would occur often but, to his understanding, it would all revolve around the timing of the notification and perhaps the SME team would not have a complete list.

Lee Brummett – CenturyLink concurred.

Kim Isaacs – Allstream asked if, in that case, could the notice include a description of the product from the tariff.

Lee Brummett – CenturyLink stated that we would investigate to see if that could be spelled out on the notice.

Kim Isaacs – Allstream asked for confirmation that the request for rate information was still under review.

Mark Coyne – CenturyLink confirmed.

Kim Isaacs – Allstream asked if they would have to submit a new CR when the billing system migrated to the new platform.

Mark Coyne – CenturyLink said yes. He asked if there were any other questions. There were none.

04/18/18 Product Process CMP Meeting Mark Coyne – CenturyLink advised that this is a new Allstream CR. The Clarification call was held March 14, 2018. The meeting minutes are available on the calendar and in the CR. Mark asked Kim to present.

Kim Isaacs – Allstream explained the purpose of the CR and explained that she also wants rates included as a new requirement for the CR. Kim said this is similar to the information they receive from other ILECs and she believes CenturyLink has the information available. She said providing the information would save her from asking for the information from her Service Manager.

Susan Lorence – CenturyLink asked Kim to send an email and update the CR to add this new requirement.

Kim Isaacs – Allstream advised that she would.

Mark Coyne – CenturyLink stated that CenturyLink has held several meetings and that internal discussions would continue and a draft response would be sent out prior to the May CMP meeting.

03/22/18 Product Process CMP Meeting Mark Coyne – CenturyLink advised that this is a new Allstream CR. The Clarification call was held March 14, 2018. The meeting minutes are available on the calendar and in the CR. Kim Isaacs – Allstream advised that she would like to present this CR in the April meeting.

03/14/18 Clarification Call meeting minutes

Attendees: Kim Isaacs – Allstream Rita Urevig – CenturyLink Lee Brummett – CenturyLink Robyn Crichton – CenturyLink Mark Coyne – CenturyLink Susan Lorence – CenturyLink John Hansen – CenturyLink

John Hansen – CenturyLink opened the call, announced the attendees, and explained the purpose of a Clarification call for the Change Request (CR) and reviewed a high-level agenda.

Kim Isaacs – Allstream said the CR was a request for CenturyLink to include impacted USOCs and rates whenever it sends out rate change notifications. If the USOCs are not included, she has to contact Rita Urevig to have someone internally provide them so that Allstream can update their data accordingly. She stated that other ILECs had been including this information for some time now. Kim said providing the USOCs on the notice would be more efficient and easier for both CenturyLink and customers. Mark Coyne – CenturyLink asked if she was expecting only data from the 14-state region (CenturyLink QC) or from all regions of the company.

Kim Isaacs – Allstream stated that if data was available from Legacy EQ and Legacy CenturyLink, that would be great, but definitely CenturyLink QC.

Susan Lorence – CenturyLink asked if CenturyLink could provide the first three letters of the USOC if there was an extensive list.

Kim Isaacs – Allstream stated that was acceptable and gave the example of 1RZxx indicating that the xx was the wildcard portion. Kim said if there was no specific USOC, she would like that noted also and where they would find the info in the OC&C section of the bill

John Hansen – CenturyLink reviewed the next steps for the CR and asked if Allstream was prepared to present the CR in the Product Process monthly meeting on Wednesday, March 21, 2018.

Kim Isaacs – Allstream stated that she would not be able to attend the March meeting, but would present the CR in the April meeting.

John Hansen – CenturyLink advised that the meeting minutes would be posted to the Wholesale Calendar prior to the CMP meeting and would advise via email to Allstream that they were posted.

John Hansen – CenturyLink asked if there were any questions. There were none.

The Clarification call ended at 9:41 AM MT.

02/21/18 Product/Process CMP Meeting Walk on Items (Attachment F)

Mark Coyne – CenturyLink advised callers that a new CLEC CR was received from Allstream and would be presented in the March CMP meeting. This CR is titled Include Impacted USOCs on Rate Notifications. A clarification call has been scheduled for Wednesday, March 7, 2018 at 9:00 AM MT/10:00 AM CT. The CR and information about the clarification call is posted to the Wholesale calendar and is open to the full CMP Customer community to attend.

CenturyLink Response

Kim Isaacs Allstream

SUBJECT: Allstream Product Process Change Request PC021318-1, CenturyLink Response for Review - REVISED

This letter is a revised response to Allstream Change Request PC021318-1, entitled “Include Impacted USOCs on Rate Notifications”

CR Description: Currently, CenturyLink sends rate change notifications with a general description of the product impacted by the rate increase. To implement the rate change in its billing system(s), CenturyLink identifies the USOCs impacted.

Allstream is requesting that CenturyLink include this USOC information on the PROD:Rate notices.

On April 18, 2018, Allstream updated the CR to request that CenturyLink include the existing rate and proposed rate along with the USOC on rate notifications.

History: The CR was received on February 13, 2018. A Clarification call was held on March 14, 2018 with Allstream and CenturyLink representatives present. During the Clarification call, Allstream stated that if the USOCs are not included, they have to contact their Service Manager to provide the information and that it would be more efficient if CenturyLink provided this information upfront.

On May 16, 2018, during the monthly CMP meeting, CenturyLink reviewed the draft response indicating this CR is accepted. The CenturyLink Response is being revised (in bold/caps below) to address the April 18, 2018 Allstream update to the CR.

CenturyLink Response REVISED: CenturyLink is accepting this CR and is proposing that a Level 1 CMP notification be sent to communicate the following: • The rate change notifications will include Reseller intrastate USOCs/RATES (5-30-18) in the legacy Qwest 14-state region. • This change would be temporary as long as USOCs/RATES (5-30-18) are used in the local service request ordering and billing process. Product Codes and Price Plans associated with products and services ordered via EASE and billed in Ensemble are not considered part of this change request. • In the event the complete list of the affected USOCs/RATES (5-30-18) may not be available at the time the rate notice is required to be distributed, CenturyLink will provide the tariff reference and location.

Sincerely,

Susan Lorence CenturyLink Wholesale CR Project Manager

May 9, 2018

Kim Isaacs, Allstream

SUBJECT: Allstream Product Process Change Request PC021318-1, CenturyLink Response for Review

This letter is in response to Allstream Change Request PC021318-1, entitled “Include Impacted USOCs on Rate Notifications”

CR Description: Currently, CenturyLink sends rate change notifications with a general description of the product impacted by the rate increase. To implement the rate change in its billing system(s), CenturyLink identifies the USOCs impacted.

Allstream is requesting that CenturyLink include this USOC information on the PROD:Rate notices.

On April 18, 2018, Allstream updated the CR to request that CenturyLink include the existing rate and proposed rates along with the USOCs on rate notifications.

History: The CR was received on February 13, 2018. A Clarification call was held on March 14, 2018 with Allstream and CenturyLink representatives present. During the Clarification call, Allstream stated that if the USOCs are not included, they have to contact their Service Manager to provide the information and that it would be more efficient if CenturyLink provided this information upfront.

CenturyLink Response: CenturyLink is accepting this CR and is proposing that a Level 1 CMP notification be sent to communicate the following: • The rate change notifications will include Reseller intrastate USOCs in the legacy Qwest 14-state region. • This change would be temporary as long as USOCs are used in the local service request ordering and billing process. Product Codes and Price Plans associated with products and services ordered via EASE and billed in Ensemble are not considered part of this change request. • In the event the complete list of the affected USOCs may not be available at the time the rate notice is required to be distributed, CenturyLink will provide the tariff reference and location.

Sincerely,

John Hansen CenturyLink Wholesale CR Project Manager

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.

-

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 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 PC040501-1 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR PC120301-6 Detail

Description Of Change

Here is the industry documentation from the ASOG for two-six code assignment:

53 TSC - Two Six Code

Identifies a code assigned to a trunk group or a CCS link

Set.

NOTE 1: The code set is unique to each established

trunk group or CCS Link Set and is provided to the

customer on the Firm Order Confirmation or Design and

Order Confirmation. The TSC entry may then be

populated by the customer when ordering changes,

additions or deletions to an existing trunk group or CCS

Link Set.

Clearly Qwest is not in compliance with inventorying the two-six code, as the ASOG specifically states the two-six code is provided to the customer on the FOC. In the case where Qwest initiates ASRs, Qwest is the customer and AT&T is the supplier. Consequently, Qwest should be inventorying the two-six code provided by AT&T to Qwest on the FOC.

Expected Deliverables:

AT&T expects that Qwest will comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Status History

Project Meetings

11/20/02 November CMP Meeting Qwest (Thomte) indicated that the trial orders that were established to convert the embedded base trunk groups in Wyoming were successful. The result is that both new trunks and embedded trunk groups appear to process through the systems using the AT&T Two Six code of CC. Qwest recommended that this CR move to CLEC Test and potentially be completed in December.

10/16/02 October CMP Meeting Qwest (Thomte) indicated that the trial was continuing and that two trial groups that are due to complete in early November. This CR to remain in “Develoment”.

08/21/02 - August CMP Meeting Qwest (Thomte) indicated progress had been made on this CR. Back end systems and reporting capability should be capable of accepting non Qwest two six code during September. Qwest and AT&T anticipate having a status meeting in late August. AT&T (Van Meter) concurred with the read out. This CR will remain in "Development" status

02/19/02 E-mail from AT&T with some questions about Qwest's response

Subject: RE: Qwest Response to Change Request PC120301-6 "Two-Six Code Inv entory for Local Interconnection Trunk Groups Ordered by Qwest" Date: Tue, 19 Feb 2002 17:20:24 -0600 From: "Stryczek, Kathleen K (Kathy), BNSVC" To: Michael Keegan CC: "Olsen, Linda Kae" , "Martin, Richard" , "Mead, Todd" , "Adkisson, Ann B, NCAM" , "Feinstein, Philip G (Phil), NNCER" , "Scherer, Esther A, NCAM" Michael, Thank you for your response to request PC120301-6 for Qwest to inventory the two-six code provided by AT&T on local interconnection trunk groups ordered by Qwest. If Qwest used the two-six code as the PON, would AT&T be able to report trouble tickets using the AT&T assigned two-six code? Also, would the Qwest maintenance group be able to locate a trunk group by searching for a PON which would have the two-six code embedded? If Qwest uses the AT&T two-six code only in the PON, but not in other systems, then I am concerned that Qwest may not be able to find the two-six code and associated trunk group when AT&T is reporting a trouble involving trunk groups ordered by Qwest. Kathy Stryczek AT&T 602-277-4527

Clarification Call, December 11, 2001, 11:00 am (MDT)

Attendees: Todd Mead, Qwest Linda Kae Olsen, Qwest Peggy Kilgus, Qwest Ann Adkinisson, AT&T Kathy Stryczek, AT&T Ester Shearer, AT&T

Reviewed description of Change Request.

Products impacted: Local Interconnection Service (LIS) Qwest need to have someone from the repair group who is involved in the management and use of the TIRKS system, involved in preparing the response to this CR. AT&T's expectation: AT&T would like Qwest to use the two-six code provided by AT&T when Qwest places an order for a local trunk group.

Action Plan: - Qwest will evaluate various options. This CR will be clarified with the CLEC Community at the January CMP Meeting. Qwest will provide a draft response for discussion at the February 2002 CMP meeting. - AT&T will provide Qwest with a contact in Ameritech to discuss ordering process and use of two-six codes. - Qwest to identify and involve the appropriate repair/TIRKS person to assist Linda in developing the draft response. An internal meeting will be held by next Wednesday (12/19/01)

CenturyLink Response

September 6, 2002

Kathy Stryczek AT&T

Subject: PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered By Qwest

This is a revised Qwest response to AT&T’s request, that Qwest comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Qwest accepts AT&T’s request regarding complying with industry guidelines and inventory the two six code that is provided to Qwest on the FOC.

Qwest has worked in conjunction with AT&T to provide a trial request that will flow through the various systems and reporting processes. Qwest is currently making the appropriate modifications to support the request for AT&T.

Currently Qwest has one order that is in a trial process. AT&T has advised that they have additional orders expected in the near future. Qwest expects to address AT&T’s additional orders with the revised process.

Sincerely, Qwest

REVISED RESPONSE

September 6, 2002

Kathy Stryczek AT&T

Subject: PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered By Qwest

This is a revised Qwest response to AT&T’s request, that Qwest comply with industry guidelines and change process to begin to inventory the two-six code that AT&T assigns to Qwest-initiated ASRs.

Qwest accepts AT&T’s request regarding complying with industry guidelines and inventory the two six code that is provided to Qwest on the FOC.

Qwest has worked in conjunction with AT&T to provide a trial request that will flow through the various systems and reporting processes. Qwest is currently making the appropriate modifications to support the request for AT&T.

Currently Qwest has one order that is in a trial process. AT&T has advised that they have additional orders expected in the near future. Qwest expects to address AT&T’s additional orders with the revised process.

Sincerely, Qwest

REVISED RESPONSE

April 10, 2002

Ms. Kathy Stryczek Manager AT&T

SUBJECT: Qwest’s Change Request Response - CR # PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered by Qwest

This letter is a follow-up response to AT&T Change Request PC120301-6, requesting Qwest inventory the two-six code that AT&T assigns for Qwest initiated ASRs.

Qwest’s written response dated February 12, 2002 informed the CLEC community that Qwest was willing to perform a detailed economic and technical investigation to evaluate the feasibility of implementing the system changes required to meet the intent of this CR.

Qwest has completed its evaluation and has concluded the cost of changing the myriad of downstream-related systems needed to effect this change is prohibitive. Qwest suggests deferral of this CR until the 2003 fiscal year funding review, planned for later this year.

Therefore Qwest regretfully informs AT&T that this CR cannot be processed this year.

Sincerely,

Susan Bliss Director Process Management Qwest

FORMAL RESPONSE

February 12, 2002

AT&T Ms. Kathy Stryczek Manager

SUBJECT: Qwest’s Change Request Response - CR PC120301-6 Two-Six Code Inventory for Local Interconnection Trunk Groups Ordered by Qwest

This letter is in response to AT&T Change Request PC120301-6, Two-Six Code Inventory For Local Interconnection Trunk Groups Ordered By Qwest. AT&T has requested that Qwest inventory the two-six code that AT&T assigns for Qwest initiated ASRs.

During the CLEC Community clarification meeting held January 16, 2002, AT&T confirmed their desire for Qwest to inventory the TSC provided on the FOC for the order. AT&T agreed that this TSC, along with the TCICs and ACTL information provided today, could be provided during the up-front planning meeting for new markets. Qwest could then use this code as the PON number as well as possibly make program modifications that would allow it to be used as the TSC (TGAC) in the processing and inventory systems used by Qwest (EXACT, IABS, TIRKS, WFA, TRDB, etc.)

Qwest is willing to pursue internal system changes to evaluate the feasibility (technical and economical) of implementing such changes. Qwest can not determine all of the systems that would be impacted, nor what the downstream effects on the process would be until the systems evaluations are performed.

If this approach is acceptable to AT&T, Qwest will initiate the required internal system changes and provide a status update at the March CMP meeting.

Sincerely,

Linda Kae Olsen Process Specialist - LIS 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 PC090401-4 Detail

Description Of Change

Status History

Project Meetings

RE: CR Form #PCCR090401-4

The intent of this change request was to clarify Qwest’s LNP process and to address any discrepancies in the information provided by their Denver Interconnect Center on August 15th, August 17th, August 24th and August 31st to AT&T. Qwest’s Denver Interconnect Center stated on multiple conference calls (to AT&T Broadband and to LNS) that calendar days, instead of business days, would be counted in the LNP process. Discussions with Qwest at the October 17th Product and Process CMP meeting clarified that Qwest uses business days.

AT&T understands this to mean that if a port is scheduled on a Friday or Saturday, Qwest will not jeopardize the end customer by closing the LSR or removing the switch translation any earlier than the next business day. Next business day is defined as the following Monday at 11:59 p.m. AT&T wants to clarify that holidays do not constitute a Qwest business day. Therefore, Friday, Saturday or Sunday ports would not be disconnected out of the switch until the following Tuesday at 11:59 p.m. if Monday is a designated holiday.

Qwest states that their Interconnect Centers have been advised and are aware of this process. The process states that the ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date.

AT&T interprets this to mean Qwest has provided documentation and training to the typists at Sierra Vista, Phoenix, and Duluth Centers, both Interconnect Service Centers, the RCMAC center and any additional Qwest centers directly related to the LNP process. AT&T Broadband will reference Qwest’s letter dated October 29, 2001 to restore loss of dial tone when it is a direct result of non-adherence to Qwest’s LNP process by any Qwest employee of these centers. AT&T further expects the duty supervisors to be well versed in this process and provide consistent action and information based on this process.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

Friday, September 21st, 2001 Alignment/Clarification Meeting

Donna Osborne-Miller, dosborne@att.com,AT&T Terry Bahner, tbahner@att.com, AT&T Kathleen Stichter, klstichter@eschelon.com, Eschelon Telecom Linda Miles, llmiles@qwest.com, Qwest Russ Urevig, rurevig@qwest.com, Qwest Joan Wells, jmwell2@qwest.com, Qwest Kate Spry, kspry@qwest.com, Qwest Ric Martin, rhmart2@qwest.com, Qwest

Introduction of Attendees Donna, Terry, Kathy, Linda, Russ, Joan, Kate, and Ric Review Requested (Description of) Change Clarify process to complete LSRS the day after due date. Confirm Areas & Products Impacted Areas: Ordering and Billing Products: LNP Confirm Right Personnel Involved Joan is the ‘owner’ of this CR and will be the point of contact for future problems of this nature until the root cause is established and draft response issued. After the clarification meeting, it was determined that Linda and Russ will not need to be involved in this CR. Kate will coordinate all necessary clarification meetings, complete meeting minutes, and review, forward, and store necessary documentation to database. Identify/Confirm CLEC’s Expectation AT&T has asked Qwest to clarify the process for completing LSRS the day after due date. Per AT&T, “Qwest notified the CLEC community LSRS would complete orders day after at 11:59 p.m. of install date to coincide with disconnect in switch. Qwest escalation center is stating that orders can start closing as early as 3 p.m. with the possibility of closing even sooner with disconnect to follow. Interconnect has stated that Qwest determines that there is a large volume of orders to close, they can decide a random time to start the process. AT&T would like to understand why this time frame fluctuates if the closing of these orders causes the disconnect in the switch to shift to an earlier time. AT&T is requesting a flow chart or documentation explaining and listing the backend systems for this process.” Identify any Dependent Systems Change Requests No related system CR’s were identified Establish Action Plan (Resolution Time Frame) Joan will clarify this process via a flowchart and written formal response draft. She will forward this documentation to Kate by the morning of 10/5/01. Kate will review and forward this information to Michael Belt to store in the CR database by 10/8/01 for CLEC review. This information can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Donna and Terry can view this information on the CR database and this CR can then be reviewed and discussed by the CLEC Community at the October CMP Meeting. Corrections/updates can then be made at that time.

CenturyLink Response

November 6, 2001

Ms. Terry Bahner Ms. Donna Osborne-Miller AT&T Communications

This letter is in response to CLEC Change Request PCR090401-4, dated September 4th, 2001, title of change: Clarify Qwest’s process on completing LSR’s day after due date. This Change Request pertains to the implementation of the new LNP process involving stand alone LNP port out service order requests.

Description of Change as noted in CR: QWEST notified CLEC community LSRS would complete orders day after at 11:59 pm of install date to coincide with disconnects in switch.. Qwest escalation center is stating that orders can start closing as early as 3pm with the possibility of closing even sooner with disconnect to follow. Interconnect has stated that if Qwest determines that there is a large volume of orders to close, they can decide a random time to start the process. AT&T would like to understand why this time frame fluctuates if the closing of these orders causes the disconnect in the switch to shift to an earlier time. AT& T is requesting a flow chart or documentation explaining and listing the backend systems for this process.

Implementation of this Qwest business process change was included in the IMA 8.0 release and was deployed effective August 20th, 2001.

The change is as stated: The ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date. Internal Qwest systems have been adjusted to accommodate this process change.

* Order completion and disconnect of translation’s will not occur prior to 11:59 p.m. the next business day following the due date.

* The subscription date to ASMS is sent to match the CLEC requested due date as available per the standard interval guide.

* The FOC is sent and matches the ASMS subscription date requested by the CLEC as available per the standard interval guide.

* An effective billing date to discontinue account billing is added to the order to match the actual port subscription date as requested by the CLEC and as available per the standard interval guide.

* Additional notification and a reminder of this current process was sent to the Interconnect Center’s through an internal communicator dated 10/29/01. The title was “Qwest response to CLEC questions concerning the current LNP Port Out process of holding switch translations and order completion until the next business day at 11:59pm.” * The process agreement is as stated: The ten (10) digit unconditional trigger and switch translations associated with the end user customer’s telephone number will not be removed, nor will Qwest disconnect the customer’s billing and account information, until 11:59p.m. (local time) of the next business day after the due date.

For due date changes or cancellation’s on existing LSR’s the following process should be followed:

Due Date Changes * You must notify Qwest via LSR supplement or notification to the ISC if you require a DD change for your port activity * Notifications of DD changes via a LSR supplement should be made as soon as possible on the DD and prior to 8:00 PM Mountain Time. * Late notification of DD changes will require that you call the ISC prior to 12:00 noon on the day after the DD (in the end-users' time zone) and issue a LSR supplement via IMA or IIS to confirm the request. If the port due date falls on a Saturday, the CLEC should notify the ISC no later than the following Monday by noon of the DD change. * Late DD change notifications after 12:00 noon the day after the DD, will require you to contact the Call Center Representative at 888-796-9087 to initiate an escalation ticket for these late changes. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request.

Cancels * You must notify Qwest via LSR supplement or notification to the ISC if you require a cancel of the port activity. ? Notifications of DD cancels via a LSR supplement should be made as soon as possible on the DD and prior to 8:00 PM Mountain Time. * Late notification of DD cancels will require that you call the ISC prior to 12:00 noon on the day after the DD (in the end-users time zone) and issue a LSR supplement via IMA or IIS to confirm the request. . If the port due date falls on a Saturday, the CLEC should notify Qwest no later than the following Monday by noon of the cancellation. * Late cancel notifications after 12:00 noon the day after the DD will require you to contact the Call Center Representative at 888-796-9087 to initiate an escalation ticket for these late cancels. The CLEC should also issue a LSR supplement via IMA or IIS to confirm the request.

Qwest Interconnect Service Center hours of operation to support the functions described above are: 6 AM to 8 PM Mountain Time, Monday-Friday 7 AM to 5 PM Mountain Time on Saturday

With the implementation of this new process, the CLEC is still responsible for notifying Qwest if they are unable to meet their requested port due date. Service order completion and disconnect of switch translation’s are not scheduled to occur anytime prior to the 11:59 p.m. time frame the next business day following the due date. However, the port subscription message was sent for the initial CLEC desired due date and changes or cancellation’s must occur as outlined above or as noted in the supplement information listed in the Product catalog.

Sincerely,

Joan Wells Process Manager Local Number Portability

CC: Margaret Bumgarner Lorna Dubose Constance Overly Kate Spry

Open Product/Process CR PC110201-2 Detail

Description Of Change

Modification - 11/27-01:

The CR will focus on accepting partial LSRs that are related to multiple LSRs and will also evaluate any differences on managed cuts versus coordinated cuts.

Status History

Project Meetings

CenturyLink Response

December 27, 2001

Jonathon Spangler ILEC Relations Manager AT&T

This letter is being sent in response to CLEC Change Request Form # PC110201-2. PC110201-2 pertains to a request to change the due date on one or more LSRs that were previously submitted in a group of related PONs. This response addresses the current IMA process for changing the due date on one or more LSRs within a group of related PONs allowing the remaining PONs to be processed.

IMA Process:

A supplemental LSR should be issued for the PON requiring the due date change. The value entered in LSOG field 25 SUP should be “3” because there will be other changes on the LSR in addition to the due date change.

The value entered in LSOG field 51 RPON should be blank to indicate that this PON is no longer part of a related group.

The value of LSOG field 14 DDD should contain the new desired due date.

The value of LSOG field 10 PGofPageof should follow the LSOG business rules for the product specified on the LSR.

The LSOG business rules are documented on the Qwest website http://www.qwest.com/wholesale/clecs/lsog.html.

Sincerely, Deborah Osborne Process Specialist

Open Product/Process CR PC110201-1 Detail

Description Of Change

Status History

Project Meetings

Subject: RE: Clarification on Rate Maps/document to determine zones for lo op rates Date: Fri, 18 Jan 2002 17:13:09 -0600 From: "Clauson, Karen L." To: Todd Mead CC: Kathleen Stichter , "Morrisette, Garth M." , Susan Travis Todd: Garth has indicated that we also need the rate center maps as well. Please send copies to Kathy Stichter. Thanks.

01/18/02 Clarification e-mail from Eschelon

Subject: RE: Clarification on Rate Maps/document to determine zones for lo op rates Date: Fri, 18 Jan 2002 17:12:04 -0600 From: "Clauson, Karen L." To: Todd Mead CC: Kathleen Stichter , "Morrisette, Garth M." , Susan Travis I will be in Denver for the CMP Re-design meeting on Tuesday-Thursday. We can discuss on a break, if you would like. Otherwise, you can arrange a call with Kathy Stichter and Garth Morrisette while I am out, if Kathy can find a suitable time for you. Essentially, we are simply asking for the documentation that allows us to determine where our lines (and future lines) fall within the zones that have been established for geographically deaveraged loop rates. For example, a newspaper article in Denver said that Zone 1 (the most dense zone) covered most of the city of Denver. What are the boundaries of that Zone? Do you have a list of wire centers/CLLI code by zone (where the zone is defined by wire centers) or a map that shows these zones? We need this information for AZ and CO. I am copying Susan Travis of WCOM, because she had this same request, and she may have other states.

01/18/02 E-mail with AT&T mailing address

Subject: RE: Your Address Date: Fri, 18 Jan 2002 12:50:10 -0500 From: "Van Meter, Sharon K, NCAM" To: "Todd Mead" CC: "Saunders, Craig" Todd, Thanks for the reminder. 1875 Lawrence St. Room 8-15 Denver, CO 80205 Thanks for your help. Sharon Van Meter Western Region LSAM 303-298-6041 303-540-1637 (pager)

--Original Message-- From: Todd Mead [mailto:tmead@qwest.com] Sent: Friday, January 18, 2002 10:42 AM To: Van Meter, Sharon K, NCAM Cc: Saunders, Craig Subject: Your Address Sharon, Please send me you mailing address and we will send you a copy of the map you requested. Thanks Todd

01/09/02 E-mail from Qwest responding to Eschelon e-mail on Qwest response content

Subject: Re: Qwest Rate Center Maps Date: Wed, 09 Jan 2002 16:09:55 -0700 From: Todd Mead Organization: Qwest Communications International, Inc. To: "Clauson, Karen L." CC: "Van Meter, Sharon K, NCAM" , jmschu4@qwest.com, susan.a.travis@wcom.com, "Saunders, Craig" , "Stichter, Kathleen L." Karen, Yes! The Qwest response presented at next week's CMP meeting will encompass the information you refer to below. Thanks Todd

01/09/02 E-mail from Qwest asking for AT&T address to forward map example.

Subject: Re: Qwest Rate Center Maps Date: Wed, 09 Jan 2002 16:07:41 -0700 From: Todd Mead Organization: Qwest Communications International, Inc. To: "Van Meter, Sharon K, NCAM" CC: jmschu4@qwest.com, susan.a.travis@wcom.com, klclauson@eschelon.com, "Saunders, Craig" Sharon, The map the Qwest individual referred to in the CMP meeting is the same as the example Worldcom sent us. Sharon, if you can send me your address I will make sure a copy is sent to you for your review. Thanks Todd

01/04/02 E-mail from Eschelon requesting additional information on Qwest response content

Subject: RE: Qwest Rate Center Maps Date: Fri, 4 Jan 2002 11:26:00 -0600 From: "Clauson, Karen L." To: Todd Mead , "Van Meter, Sharon K, NCAM" CC: jmschu4@qwest.com, susan.a.travis@wcom.com, klclauson@eschelon.com, "Saunders, Craig" , "Stichter, Kathleen L." Todd: Thanks for the helpful response. Since Sharon asked specifically about the rate center maps, I wasn't sure that your response below deals with the Distribution Area (DA) maps requested by Eschelon. Will we be getting the DA maps at the January meeting? Also, at the meeting in December, we discussed whether the CLECs were actually requesting the correct items to meet their objectives (e.g., being able to identify customers in zones for geographically deaveraged rates). I believe this caem up because Qwest said that it didn't know if it had maps of the type requested. If not, then Qwest must look at something else to make these determinations. We asked that, if we had not requested the documentation used by Qwest for this purpose, that such documentation also be produced. Have you determined yet whether Qwest has different documents/maps and, if so, will that be provided at the January meeting? Thanks, Karen

01/04/02 E-mail response to AT&T

From: Todd Mead [SMTP:tmead@qwest.com] Sent: Friday, January 04, 2002 11:14 AM To: Van Meter, Sharon K, NCAM Cc: jmschu4@qwest.com; susan.a.travis@wcom.com; klclauson@eschelon.com; Saunders, Craig Subject: Re: Qwest Rate Center Maps Sharon, Thanks for your e-mail. At the December CMP meeting, we had a general clarification on this CR where you presented the business reasons for submitting this CR and then the Qwest SME's asked you several questions pertaining to the exact nature of information you were after with these rate center maps. The following are notes I documented from the December CMP clarification meeting: - What states you wanted maps for (Washington, Utah, Colorado, Oregon, Minnesota, Arizona & New Mexico) - What level of detail (you want to be able to see what rate center a specific address is located in) - What format you are after (CLECs prefer electronic, however hard copy would do) - Whether you wanted to only see major metro areas i.e.. Denver, Aurora, Smokey Hills etc. CLECs agreed to this - Eschelon wanted to know if these maps would show how each customer is being served i.e. RSU (Qwest responded they would not and Eschelon responded that they may submit a separate CR). - Worldcom wanted to know if the maps show the CILLI detail (they had some examples from previous USWest maps). We have since contacted LeiLani and she has forwarded a copy of these old maps to the Qwest SME to review to help their response preparation. - You also want the response to include the process for getting these maps updated At the January CMP meeting (01/16/02) Qwest will present their response to your CR. The Qwest team is currently working on this response and I will e-mail it to you (plus Eschelon and Worldcom) as soon as I receive it from the Qwest SME. The response will also be posted to the CMP database and published on the web no later than next Friday (01/11/02). If I have missed something here, I would be more than happy to discuss this with you. You can call me anytime today to discuss this. Regards Todd

01/04/02 E-mail from AT&T requesting map examples

Subject: Qwest Rate Center Maps Date: Fri, 4 Jan 2002 10:49:43 -0500 From: "Van Meter, Sharon K, NCAM" To: CC: , , Todd, I haven't heard anything about the deliver of the Rate Center Maps. It was my understanding that you would contact me and deliver some maps for my review. Please advise. Sharon Van Meter Western Region LSAM 303-298-6041 303-540-1637 (pager)

12/18/01 e-mail from Worldcom to Qwest

Todd, Sure, I will put one in the mail today. LeiLani Hines Worldcom Carrier Management

12/18/01 e-mail from Qwest to Worldcom

Leilani, The Qwest SME would like to see the copy of the map you have. Could you please send him one? Thanks, Todd

> From: Stichter, Kathleen L. > Sent: Friday, November 16, 2001 3:18 PM > To: 'mbelt@qwest.com' > Subject: PC110201-1 > > Mike, > Qwest has a web site http://www.qwest.com/iconn/ that a CLEC can go to and > click on Outside Plant Jobs Greater than $100K to get information on the > build jobs Qwest is planning. Once at this web page the details Qwest > gives are: > State, WireCenter, Job #, Fiber/Cooper, Quantity, Location i.e. DA/CLLI, > Ready for Service and Completion Date. The information populated in the > Location field is either CLLI or DA (Distribution Area). The DA data is a > number i.e. 310211. This number, for the distribution, means nothing to > Eschelon without a map detailing the bounderies down to street level > detail of the specific distribution area. > Thanks > > Kathy Stichter > ILEC Relations Manager > Eschelon Telecom Inc

3:00 p.m. (MDT) / Thursday 16th Nov 2001 Clarification Meeting Conference Call

Attendees: Sharon Van Meter / AT&T Matt Kruzic / Qwest Jacob Barlow / Qwest Jan Attebarry / Qwest Craig Saunders / Qwest Mary Anderson / Qwest Michael Belt / Qwest Kathy Stichter / Eschelon (called later) Tom Dixon / Worldcom (called later)

Review Requested (Description of) Change: AT&T – Qwest Rate Center maps to be public information to the CLEC Community Eschelon & Worldcom would like the DA and CLLI Maps also included with this CR.

Products Impacted - LNP

Identify/Confirm CLEC’s Expectation - Yes the expectations of the CR are understood, need to clarify the issue of Proprietry Qwest information.

CenturyLink Response

Sharon Van Meter Manager AT&T 1875 Lawrence St. Denver, CO 80205

SUBJECT: Qwest’s Change Request Response - CR # PC110201-1 Qwest Rate Center Maps

REQUEST: Qwest determines the Rate Centers. AT&T needs to mirror the Rate Center areas for residential LNP. What is the process for obtaining Rate Center Maps from Qwest?

Additional clarifications/requests: Requested maps at a street level detail. Requested maps for MSA’s in Arizona, Colorado, Washington, Utah, Oregon, Minnesota, & New Mexico Prefer electronic, however paper will do. Requested maps at a level to determine DA areas. Requested maps at a CLLI level detail. Requested a process to update maps.

RESPONSE: Qwest has provided, on the Qwest Wholesale web site, the same rate center maps that Qwest uses and updates on a quarterly basis. The URL is:

www.qwest.com/wholesale/network/ratecentermaps.html

Qwest does not solely rely upon rate center maps to determine number portability. Qwest, as well as other companies, relies upon the Local Exchange Routing Guide (LERG) as the official guide to determine the portability of a number. Qwest determines whether a number is available for porting by looking at the customers switch information, both from and to, which reflects the serving rate center. As determined by the FCC, Qwest does not permit the porting of the numbers between two different rate centers.

Currently the Rate Center maps used by Qwest and provided on the wholesale website do not have the capability to provide wire center street level detail. Maps of DA’s are available through the Qwest Wholesale web site by following the process outlined under the URL:

www.qwest.com/wholesale/pcat/remotecollocation.html

Requesting multiple DA’s in a particular wire center will enable CLEC’s to ascertain the description of the wire center boundary.

In regard to the request for maps where Qwest plans fiber and copper jobs greater than $100,000, Qwest has plot maps that are available for review as outlined in SGAT section 10.8.2.4. Qwest agrees to provide CLEC access to relevant plats upon receiving a bona fide request for such information as stated in the SGAT.

Sincerely,

Craig Saunders Staff Advocate Policy & Law Qwest

CC: Barry Orrel, Director Legal Issues, Qwest Jim Eitel, Director Legal Issues, Qwest Lydia Eiguren, Senior Director Business Development, Qwest John Hayat, Staff Advocate Policy & Law, Qwest Mary Retka, Director Legal Issues, Qwest

Open Product/Process CR PC102601-1 Detail

Description Of Change

Status History

Project Meetings

CenturyLink Response

December 28, 2001

Carla Dickinson Pardee LSAM Manager AT&T

This letter is in response to the CLEC Change Request Form #PC102601-1 regarding RSID/ZCID Assignment for UNE-P. Qwest would like to close this Product/Process CR and open a new Systems CR to properly consider the best way of meeting this business need.

Today, the assignment of an RSID/ZCID value drives a lot of business processes in Qwest. USOC rates are maintained for each RSID/ZCID, Loss/Completion reports are generated for each RSID/ZCID, separate bills are generated, security and authorizations are specific per RSID/ZCID, etc. To assign multiple RSID/ZCID values per CLEC would create potential issues with contract updates, authorizations, etc. Qwest would prefer to create another mechanism for CLECs to tell Qwest how to segment customers for purposes of Loss/Completion reports, Daily Usage Feeds and any other system interfaces CLECs desire to have segmented.

This new separation mechanism would need to be accomodated on the LSR and IMA, as well as the other systems involved. A Systems CR would be required to accomplish this. Qwest will open the Systems CR on AT&T’s behalf.

If you have any questions, feel free to e-mail me or call me. Happy New Year!

Sincerely,

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

Open Product/Process CR 5579296 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR PC090401-1 Detail

Description Of Change

Request for Qwest to separate daily usage files by separating category 01 and 010 from category 011. Categories 01 and 010 separate daily usage records for end users while category 011 tracks billing for other carriers. AT&T separates billing entities by these functions. AT&T believes that other carriers utilize this same process. AT&T believes would be more efficient if the daily usage files were separate in this manner.

Status History

Project Meetings

Alan indicated that he was familiar with this subject. He believed it had been submitted once before but did not have the support of the other CLECs at that time. Alan indicated that he thought some of the CLECs might see the need for this now.

Alan stated the issue: In the current environment two usage files containing the same data are sent to two locations. ATT would like to have the file containing message types 01 and 10 split out on one file. The other file should contain message type 11, to be distributed separately.

Carla indicated she would take this CR to the next community meeting to propose this change to other CLECs.

CenturyLink Response

November 6, 2001

This letter is in response to the CLEC Change Request Form #PC090401-1. This Change Request requests that the Daily Usage Feed (DUF) be split into two pieces - with local usage (generally Category 1 & 10 EMI records) on one file, and access usage (Category 11 records) on a separate file.

Today, both local usage and access usage is sent on a single DUF file for each CLEC. It is fairly straight-forward to separate this usage into two files. To do so requires some small programming changes, as well as some JCL and NDM/Connect: Direct changes for every CLEC that chooses to have their DUF split into two pieces. This would be a medium-sized effort. This CR will be moved to the Systems CMP process in order to prioritize this system work.

Qwest would implement this CR in such a way that those CLECs that wish to continue to receive their DUF file as one file (like today) would be able to continue with that implementation. Those that wish to receive two separate files would be able to do so, having those two files sent to two different destinations (assuming connections exist) or to the same destination as the CLEC desires.

Any CLEC who would like to have their DUF split in two as this CR requests may send an e-mail to me at azimmer@qwest.com to be included in the deployment of this functionality. If you have any questions, feel free to e-mail me or call me at the number below.

Sincerely,

Alan Zimmerman (303)896-8346

Open Product/Process CR PC090401-2 Detail

Description Of Change

The process would include a minimum of the following steps:

- CLEC will provide prior notification of intent to convert via a list (spreadsheet?) identifying the LSO and number of TNs

- CLEC will provide ONE LSR PER CUSTOMER LOCATION for conversion.

- Qwest will provide a SPOC for each LSO conversion on the same due date.

- Qwest will perform a Loop Qualification for each LSR.

- Qwest will provide Loop Qualification results to CLEC.

- CLEC will have option to make supplemental changes or cancel LSRs per results of loop qualification.

- CLEC will schedule conversion to begin on Due Date no earlier than 4:00 PM. All conversions within the LSO will be completed by 12:00 Midnight.

Time Intervals for conversions shall be monitored and shall conform to the existing performance standards set in the current Qwest hot cut agreement.

Status History

Project Meetings

Qwest held a community meeting with AT&T regarding two questions that came up during the October CMP meeting. Other CLECs were invited and several participated.

Jonathan Spangler from AT&T had inquired if the orders would go through the QCCC. Russ Urevig stepped through the process. In the process he identified that in fact the QCCC will be the point of contact for the coordinated after hours cut. Jonathan indicated he had received some push back when trying to schedule other projects.

The second question was regarding charges associated with the after hours cut. Russ explained that the normal after hours charges would apply.

Jonathan brought up an additional issue. He wanted to know what the impacts would be to these projects when the 9.0 IMA Release goes in and the CLECs are required to use Appointment Scheduler. Russ indicated he was not sure that these types of cuts were included in the 9.0 release for Appointment Scheduler. Qwest to follow up with system SME’s regarding the System Change Request.

-

09/17/01 - Introduction of Attendees Jonathan Spangler Carla Dickinson Pardee Russ Urevig Kit Thomte

Kit made introductions of people that were in attendance on the conference call Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} AT&T would like Qwest to develop a process that would allow for the conversion of customers residing on UNE P to UNE L. CLECs will identify specific TN’s within the CO that need to be converted. This would occur initially via a spreadsheet with LSR’s to follow. The spreadsheet would be used by Qwest to determine if the line actually could be converted. Prior to this the CLECs will use the raw loop pre qualification tool to verify TN’s of end users being converted. The CLECs want to minimize the amount of down time for the customers so the cuts should be performed between 4 PM and 12:00 Midnight. The volumes anticipated are not very precise yet. AT&T will provide more information as it becomes available. Russ inquired how AT&T would like to handle a scenario where the end user has multiple lines and only a portion of the lines are being migrated. Would they set up separate accounts?? Jonathan said he would need to check that out. Confirm Areas & Products Impacted {read from change request, modify if needed} At this point only 1FR’s will be submitted, at some point this process might include DSL.

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} At this point Russ believes a person from network should be involved, this probably would be Deni Toye. A process person for UNE P should either be involved or review the process that is established. Eventually a SME from Retail should be aware of the process.

Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measurable terms i.e. provide a documented process, change a process to include training etc)} Qwest needs to provide a process that will address this type of migration. This process needs to be put in place quickly with the worst case scenario being implementation in December of 2001.

Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} An existing CR would resolve the necessity of this CR. Russ Urevig agreed to identify this CR and let us know the status.

Establish Action Plan (Resolution Time Frame) {state action required, who will be responsible and by when) Russ will run this CR past his supervisor and the migration team that works on these issues. Russ should have a response by close of business on Monday Sept. 24th The detailed action plan will be provided after the session on the Sept. 24th.

09/12/01 - Susie Bliss is the Director 402-422-8006 Kit Thomte is the Project Mgr. 303 896-6776 Russ Urevig is the Owner 218 723-5800 Donna Osborne Miller gave me has provided the name of an individual to participate in a clarification meeting. Have not heard from the individual yet.

CenturyLink Response

Jonathan Spangler, LSAM Supervisor Donna Osborne-Miller, LSAM Manager AT&T Local Services

CC:Russ Urevig Susie Bliss Linda Miles Kit Thomte

This letter is in response to your CLEC Change Request Form PCCR090401-2 dated August 30, 2001.

Request:

AT&T would like to establish an efficient process with Qwest to convert AT&T customers residing on the Qwest UNE-P platform to the Qwest UNE-L platform on a Bulk LSO basis. The process would include a minimum of the following steps: CLEC will provide prior notification of intent to convert via a list (spreadsheet?) identifying the LSO and number of TNs CLEC will provide ONE LSR PER CUSTOMER LOCATION for conversion. Qwest will provide a SPOC for each LSO conversion on the same due date. Qwest will perform a Loop Qualification for each LSR. Qwest will provide Loop Qualification results to CLEC. CLEC will have option to make supplemental changes or cancel LSR's per results of loop qualification. CLEC will schedule conversion to begin on Due Date no earlier than 4:00 PM. All conversions within the LSO will be completed by 12:00 Midnight. Time Intervals for conversions shall be monitored and shall conform to the existing performance standards set in the current Qwest hot cut agreement

Qwest Response:

Conversion from UNE P to UNE L on a Bulk LSO basis can be handled as a project. The CLEC can contact their Account Service Manager to advise of the intent to Bulk convert on an LSO basis. By the conversion being handled as a project, the specifics such as due dates and individual tester, SPOC can be coordinated.

The CLEC can request raw loop data for an entire wire center. The RLD tool provides data in bulk format to the Co-Providers about loop make-up characteristics at the wire center level. The data includes CLLI code, load coil, bridged tap, wire gauge, cable and pair make-up, and similar information on a loop-by-loop basis.

There is a web-site maintained by Qwest where Co-Providers may access the RLD tool. To gain access to the web-site, Co-Providers must obtain a digital certificate from Qwest. The RLD tool is presented in an ASCII text file and can be downloaded to an Excel format or database built by the Co-Provider. The web-site address is http://ecom.uswest.com.

CLEC’s are encouraged to use the Pre-order function in IMA for Loop Qualifications. The results of the Loop Qualification are given to the CLEC. If an LSR is submitted and the loop does not qualify then the LSR would be rejected. A CLEC has the option to make supplemental changes or to cancel an LSR. For any due date requests outside the normal business hours appropriate charges would be billed.

Sincerely,

Russell Urevig Wholesale Service Delivery Process Team

Open Product/Process CR 5579794 Detail

Description Of Change

Status History

Project Meetings

Open Product/Process CR 5548341 Detail

Description Of Change

8-01 AT&T request add’l testing documents in regards to end to end testing.

Status History

Project Meetings

CenturyLink Response

Memorandum To: Central Office Directors

September 21, 2001

LX - - DVA (48 Hour) DIAL TONE TESTING REQUIREMENTS

There has been some confusion about the requirement, documented in the CO DVA PROCESS, for the CO to perform a Dial Tone test on DVA for Unbundled Dial Tone Capable Loops (NC Code LX - -). The requirements are:

1. ALL orders provisioning LX - - circuits MUST be checked for Dial Tone at the ICDF CFA. This includes both HOT CUT (Reuse of Facility) and Basic New (Vacant Facility) orders. 2. If the CO performs this test prior to the DVA and: A. Dial Tone is present the results must be logged in the order OSSLOG, using the OSSRMK screen in WFA-C. B. Dial Tone is NOT present the CO personnel MUST arrange to retest for Dial Tone on the DVA Critical Date by either: - Completing the DVA step partially and reloading the step to the DVA date. - Completing the DVA step and manually handling the order for retest (Manual holding bin) - Completing the DVA step and creating their own work request to retest on the DVA, loading this item to themselves or someone else. If someone else is loaded, the person loading the request must check to ensure that person is scheduled to work and that they know the item is loaded to them. 3. If the test is performed on the DVA and: A. Dial Tone is present the results must be logged in the order OSSLOG, using the OSSRMK screen in WFA-C. B. Dial Tone is NOT present, the testing CO personnel MUST contact the Implementer or Coordinator assigned to work the order (check the OSSOI screen in WFA-C). If none is assigned them must call the toll free number for the Design Service Center handling the order and give the trouble condition to the first implementer or coordinator they reach. Any Center personnel receiving this call SHOULD take the report and initiate Center activity for CLEC notification. This test failure MUST be logged in the OSSLOG. 4. If the time between DVA critical date and Due Date commitment time is greater that two (2) business days, the DSC/QCCC Implementer or Coordinator will determine this and hand off an SPL48 ticket requesting a Dial Tone retest two business day before commitment date. This should be the only time the CO would expect such a handoff.

The important points to remember are: - The CO is ultimately responsible for ensuring this Dial Tone test is peformed. - The CO must arrange their own retest if working DVA steps prior to DVA and NO DIAL TONE is found. - SPL48 tickets will only be generated by the DSC/QCCC under the situation stated in item (4.) above.

Please cascade this memo through your organizations. If you have any questions or comments, please contact me.

Cc: Central Office Senior Directors Deborah Heckart Fred Aesquivel

Open Product/Process CR 5582078 Detail

Description Of Change

Status History

Project Meetings

To discuss order processing or status, including Firm Order Confirmation (FOC) and Service Order Confirmation (SOC) Notice, or to send associated information to the appropriate Center for processing, contact our Customer Service Centers. Based on the location of your end-user and the type of service you requested, Local or Access Services, our Service Center numbers are:

LSRs for Interconnect Resale Services, Asynchronous Transfer Mode (ATM) Services, Resale Frame Relay, Complex Resale, Centrex, Local Number Portability (LNP), Interim Number Portability (INP), Unbundled Local Loops and Elements: Location Contact Fax Hours of Operation Interconnect Service Center (ISC) 888-796-9087 888-796-9089 - FAX Monday-Friday 6:00 AM - 10:00 PM Mountain Time Saturday 7:00 AM - 6:00 PM Mountain Time

Qwest's Service Center is available to assist with your needs and, if additional assistance is required you will be transferred to the Customer Service Inquiry and Education (CSIE) Center until 8:00 PM MTN Time Monday – Friday. If additional assistance is required after 8:00 PM or on Saturday, Qwest will coordinate a call back or provide additional assistance as needed.

November 6, 2001

Joan Wells Qwest LNP Process Manager

RE: CR Form #5582078

AT&T understands Qwest has denied its request to expand Qwest’s Interconnect Centers hours as stated at the October 17, 2001 monthly CMP meeting. Qwest has agreed to change the CR status to “deferred” until the May 2002 Product and Process CMP meeting. AT&T has three areas of concern with Qwest’s response:

AT&T recognizes NeuStar’s standard hours of operation do not include Saturday or Sunday; however, Qwest’s own action of providing support on Saturday acknowledges Saturday as an important port day for AT&T Broadband regardless of NeuStar’s hours of operation. Therefore, AT&T believes NeuStar’s standard hours of operation is not a determining factor for Qwest in regards to expanding its hours of support for Saturday or specifically, Sunday.

Although “port activity may currently be scheduled for any desired frame due time”, there are switches within Qwest’s network that cannot be set mechanically. Does Qwest have edits built into its systems to reject or defer LSRs in this scenario? How can these switches be identified?

The last concern centers on the 24-hour AMSC level of support that Qwest has offered. In the October 17 Product and Process CMP meeting, Qwest stated that the technicians at the AMSC center do not have access to Qwest’s provisioning systems for LNP. Offering this center as an alternative to expanding the Interconnect Centers hours only delays and provides a false expectation to CLECS trying to resolve outstanding porting issues. Therefore, AT&T does not believe this as an acceptable alternative to our change request.

AT&T believes continued discussions need to take place as AT&T’s business volumes continue to grow with Sunday porting activity.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Qwest clarified some information regarding the forecast information provided by AT&T on 9/5; the forecast information provided is a projection of daily volume in all markets within Qwest territory

Action Items: - Lorna Dubose (Qwest) to communicate forecast information to Ken Beck and Toni Dubuque (9/10) - Lorna Dubose (Qwest) to provide Qwest response (9/14/)

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T) Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry explained that AT&T is interested in a window of Qwest support for LNP on Sundays after NPAC comes up. There is also a desire for Qwest support into the evening hours during the week. As an example, Terry cited the fact that AT&T gets orders until 10 p.m. (daylight time) in Salt Lake City. Lorna explained that Qwest center management could evaluate the possibility of expanded hours once the appropriate forecasting information is provided. The information to be included in the forecast: Expected volume by day and hour; any fluctuations expected (e.g. due to daylight savings time). Terry explained that she expected to be able to provide Qwest with forecast data by September 4. Lorna indicated that Qwest would attempt to examine forecast data prior to the September CMP meeting. Qwest will aim to provide a response prior to the September CMP meeting, but the formulation of a response might not be possible. Action Items: - Terry Bahner (AT&T) to provide Qwest with forecast volumes by 9/4/01 - Lorna Dubose (Qwest) to provide Qwest center management with forecast by 9/5/01 - Lorna Dubose (Qwest) to develop Qwest response by working with center management (tentative target: 9/7/01; with Michael Buck to organize walk-through meeting with AT&T during early week of 9/10/01)

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LNP Meeting Notes 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller CR #5582078 – Expand Qwest’s interconnect center’s hours - Lorna currently waiting on response from the Qwest Interconnect Hours - Terry to give estimate to Lorna on call volume to expect

CenturyLink Response

Ms.Terry Bahner, Ms. Donna Osborne-Miller, AT&T

This letter is in response to CLEC Change Request Form #5582078, dated June 6, 2001. This Change Request pertains to a request by AT&T to Expand Qwest’s Interconnect Center hours to include a window of 6am MST to 10pm MST, Sunday through Saturday.

At this time, Qwest has no plans to expand the Interconnect Center hours. The following are some of the reasons that Qwest has made this decision: Currently, Qwest’s published normal hours of work are Monday – Friday 7am MST to 7pm MST. These hours are in parity in both Qwest Wholesale and Qwest Retail. Qwest Interconnect Center’s hours have already been previously expanded to 6am MST to 8pm MST Monday-Friday and 7am – 5pm MST on Saturday’s. NeuStar’s standard hours of Operation for the NPAC are Monday – Friday 7am – 7pm CST/CDT. The Qwest Interconnect Center hours currently exceeds this standard. Economic conditions currently do not facilitate an increase in head count to support the proposed increase in order activity and expansion. Lack of support from downstream systems, currently operating under the standard business hours. System maintenance necessities (i.e. scheduled down time) do not support expansion. Access to automated systems for order input is already available. Port activity may currently be scheduled for any desired frame due time in those switches where the ten digit triggers are set mechanically. 24-hour support is currently available through the Account Maintenance Support Center (AMSC) in handling repair issues that are a result of number portability.

At this time, Qwest will not expand its Interconnect Center hours further. Qwest had originally proposed that we review the expansion request again in one year, but at Clec request, Qwest has agreed to review again in six months.

Sincerely, Joan Wells Qwest LNP Process Manager

September 20, 2001

DRAFT RESPONSE For Review By CLEC Community and Discussion at October CMP Meeting Wholesale Product/Process Ms.Terry Bahner, Ms. Donna Osborne-Miller, AT&T

This letter is in response to CLEC Change Request Form #5582078, dated June 6, 2001. This Change Request pertains to a request by AT&T to Expand Qwest’s Interconnect Center hours to include a window of 6am MST to 10pm MST, Sunday through Saturday. At this time, Qwest has no plans to expand the Interconnect Center hours. The following are some of the reasons that Qwest has made this decision: Currently, Qwest’s published normal hours of work are Monday – Friday 7am MST to 7pm MST. These hours are in parity in both Qwest Wholesale and Qwest Retail. Qwest Interconnect Center’s hours have already been previously expanded to 6am MST to 8pm MST Monday-Friday and 7am – 5pm MST on Saturday’s. NeuStar’s standard hours of Operation for the NPAC are Monday – Friday 7am – 7pm CST/CDT. The Qwest Interconnect Center hours currently exceeds this standard. Economic conditions currently do not facilitate an increase in head count to support the proposed increase in order activity and expansion. Lack of support from downstream systems, currently operating under the standard business hours. System maintenance necessities (i.e. scheduled down time) do not support expansion. Access to automated systems for order input is already available. Port activity may currently be scheduled for any desired frame due time in those switches where the ten digit triggers are set mechanically. 24-hour support is currently available through the Account Maintenance Support Center (AMSC). At this time, Qwest will not expand its Interconnect Center hours further. Qwest will review this expansion request again in one year.

Sincerely,

Joan Wells Qwest LNP Process Manager

CC: Lorna Dubose Judy Schultz Margaret Bumgarner Michael Buck Todd Mead

Open Product/Process CR 5582099 Detail

Description Of Change

Status History

Project Meetings

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller

November 14 - CMP Meeting Callan-Qwest described the CR and the Qwest response. Bahner-AT&T stated that she did not want the CR to be closed as she had just received the response. She also noted that Qwest has not shared its PID data with AT&T. Clausen-Eschelon stated that this CR should not be in CLEC test. Bahner-AT&T stated that she was under the impression that Qwest was moving toward a solution to the CR, but that the recent response was a denial. Callan-Qwest stated that Qwest had evaluated the potential solution and was not prepared to accept the risk of changing a stable system platform, which would be the result of moving forward with a solution to the CR. Dixon-Worldcom asked if this measure was in the PAP. Callan-Qwest stated that it is a PID and it is also a PAP, except in Arizona. Dixon-Worldcom stated that this was inconsistent with his understanding of the Qwest agreements. He understood that Qwest would automatically incorporate all of the ROC measures into the Arizona filing. Callan-Qwest stated that it was her understanding that this had not been requested as a PAP in Arizona. Schultz-Qwest stated that Qwest would take an action item and report at the next meeting. She stated that the CR is denied and asked what status AT&T wanted to leave it in. Bahner-AT&T stated that she would like it left as Presented until next month.

November 6, 2001 AT&T Response to our final position on the CR. Lorna Dubose Qwest LNP Wholesale Product Manager

RE: CR Form #5582099 This letter is in response to the status you provided at the October 17, 2001 Product and Process CMP meeting. We look forward to Qwest implementing a system change that would disconnect the TN out of the switch immediately after AT&T Broadband activates the number. This change would eliminate unnecessary loss of dial tone between Qwest and AT&T Broadband, reduce the number of work backs and snap backs and in general, provide continuity to the LNP process. In the interim, AT&T Broadband will continue to operate under the process formally introduced on August 20th, 2001.

We look forward to the next status in November and a possible implementation date in 2002.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

Internal Status Update Meeting (9/18/01 4:30 p.m.) Attendees: Michael Buck (Qwest), Lorna Dubose (Qwest) Internal cost analysis still on track for 9/28/01 completion. Lorna updated target date for formal AT&T response to 10/12/01.

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September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Qwest provided a status update on this CR. Qwest has received time and cost estimates from 2 vendors to date. Qwest will be seeking a time and cost estimate from a third vendor. The addition of a third vendor is not expected to adjust the dates communicated in the August 27, 2001 Clarification Meeting. AT&T asked whether Qwest has yet committed to performing the change requested in this request. In response to a question from Sharon, Lorna indicated that Qwest has not yet committed to doing the work requested in this CR. The decision whether or not do the work is dependent upon the cost analysis scheduled for completion by 9/28/01.

Action Items:

- Lorna Dubose (Qwest) to create cost analysis based upon vendor time and costs by 9/28/01 - Lorna Dubose (Qwest) to develop Qwest response based upon cost analysis (tentative target: 10/5/01)

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry confirmed that the goal of this CR is to have Qwest provide a response regarding AT&T’s desire that LNP disconnects not be released until a corresponding activate transaction is received from NPAC indicating that AT&T service is operational.

Terry indicated that previous action taken by Qwest (i.e. delayed posting of disconnects until due date plus 1 day) is helpful, but does not address the core of this request. Lorna reiterated that Qwest is still seeking vendor time and cost estimates to provide the functionality requested by AT&T.

Lorna expects to develop a cost analysis based upon vendor responses by the end of September. At that time Qwest will make a decision whether or not to pursue the vendor proposals.

Lorna does expect to be able to provide an interim status update at the September CMP meeting. As of August 29, 2001 time and cost bids have been received from both vendors involved in this CR.

Action Items: - Lorna Dubose (Qwest) to create cost analysis based upon vendor time and costs by 9/28/01 - Lorna Dubose (Qwest) to develop Qwest response based upon cost analysis (tentative target: 10/5/01)

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LNP Meeting Notes - 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- Qwest looking at long term solution - Price bid expected from Telcordia by 8/27 - Price bid expected from another vendor 08/30 - Cost analysis and internal analysis to be conducted by Qwest 09/28 - Estimated implementation date set for no earlier than Q1 2002

CenturyLink Response

Ms. Terry Bahner Ms. Donna Osborne-Miller

AT&T

This letter is in response to your CLEC Change Request Form, number 5582099 dated June 6, 2001 – LNP Switch Disconnect Timing.

Request: Change current switch disconnect process to where disconnect occurs immediately after AT&T Broadband activates the number.

Response: Qwest understands the goal is to eliminate disconnection of customers in error. Qwest has agreed to Performance Measurement OP-17 - Timeliness of Disconnects Associated with LNP Orders with a standard of 98.25%. Qwest is in full support of this measure and has committed to this standard.

In August, Qwest completed the mechanization of the solution to hold the switch translations and the service orders until 11:59 P.M. of the next business day after the port due date. Initial analysis of internal data from before and after the implementation indicates a 73% reduction in loss of dial tone and an 84% reduction in workbacks.

Qwest did evaluate several vendor proposals outlining a system solution to time the switch disconnect with the port activation. Qwest believes that our current process and recent system mechanization has provided a reliable and stable platform for the completion of port orders. As a result of the analysis of the vendor proposals, and the service improvements from our own internal system changes; we will not be pursuing any additional system enhancements. No further action is planned. Sincerely,

Maureen Callan Group Product Manager

Open Product/Process CR 5582212 Detail

Description Of Change

Status History

Project Meetings

Joan Wells Process Manager Local Number Portability

RE: CR Form #5582212 AT&T has submitted LSRs requesting the new 3-day service interval for Megabit service established after April 4th, 2001. At this point in time, only a small number of orders have been pushed out to the previous 5-day interval. AT&T considers this a coaching issue within Qwest and has socialized it with the typing centers and the Denver Interconnect center during our weekly conference calls. We will close this CR at the November 14th, 2001 Process and Product CMP meeting. Thank you for providing AT&T Broadband the tools to identify the appropriate USOCS. Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582212 – 3-day interval Megabit Line

Dear Lorna:

AT&T believes Qwest has, in part, addressed CR 5582212. Going forward, any local service request to port an end-user’s telephone number that Qwest currently lists as a Megabit service qualifies for the 3-day interval if the Megabit service was installed with Qwest after April 4, 2001. AT&T would prefer this 3-day interval apply to all Megabit services regardless of the April 4th date.

Qwest has indicated AT&T Broadband can determine this date by reviewing the customer service record. AT&T Broadband has yet to determine if a Qwest install timestamp is present next to the USOC. AT&T would like Qwest to issue a unique USOC to help identify Megabit services installed after April 4th to assist in acquiring the 3-day interval. Your consideration to this request would be appreciated.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

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September 7, 2001 2:15 p.m.

Attendees:

Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

The Qwest response to this CR was presented; multiple clarification questions were asked and answered:

Q: Why is April 4, 2001 date important? A: This is the date when the process change for engineering megabit requests as non-design took place

Q: So the service offered did not change after April 4? A: Correct. Only an internal process was changed. The megabit service offered did not change.

Q: How should CLEC determine the customers’ install date? A: The necessary information should be available in the CSR (Customer Service Record). In Qwest internal systems both the USOC and the date are visible. Also, another option is to ask the customer when their service began.

Action Items:

- Terry Bahner (AT&T) to confirm that necessary information is available in the CSR visible to AT&T (9/13) - Terry Bahner (AT&T) to take Qwest response to AT&T stakeholders (9/13)

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Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter(AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest)

Terry clarified that the request for a reduced interval for LNP of megabit lines applies only to the ported number NOT the facilities. Terry indicated that AT&T had put in place procedures to inform customers of the impact to megabit facilities when AT&T ports only the number. Lorna indicated that she was working with appropriate product and process groups to address this request.

Action Items: - Lorna Dubose (Qwest) to formulate Qwest response by 9/5/01 - Michael Buck (Qwest) to organize a walk-through meeting with AT&T during late week of 9/3/01.

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LNP Meeting Notes – 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- Lorna scheduled meeting with Megabit Product Manager on 8/16 - Status update will be given to Terry Bahner after that meeting

CenturyLink Response

This letter is in response to CLEC Change Request Form, number 5582212 – 3 day LNP LSR interval for Megabit Line, dated June 6, 2001.

Request: Qwest considers a megabit line as a complex and requires a 5-day interval. Since LNP is porting a number only and does not need the special facilities, it should be treated as a ported number and have a 3 day interval.

Response: After meeting with the Megabit Product Manager and the Interconnect Service Centers, it has been determined that as of April 4, 2001, Qwest implemented a new process for engineering Megabit service and it is now considered a non-design/simple service. Therefore, end-user customers that ordered Megabit service after April 4, 2001 had their service installed as non-design/simple service. This type of Megabit service can have a 3-day interval, which is the same as simple LNP orders today. However, if the Megabit end-user service was installed prior to April 4, 2001, the service is still considered a design/complex service. This requires service interval timeframes that allow Qwest systems to accurately remove the switch translations and process the order completion. Appropriate intervals for the Complex Product type will continue to apply. These intervals are shown in the LNP Product Catalog under Standard Intervals for LNP or the Service Intervals for Interconnection & Resale located at Qwest.com.

New USOC’s were developed for this network platform change. Effective 04-04-01, the Basic and Pro Services using the HRL++ USOCs will be grandparented and may not be used for ordering new services. The new Qwest DSL basic line 1FB/1FR, AFK/AFH Usoc’s are GRL++ and will be used after the 04-01-01 date.

The Select Service using HRC++ USOCs also, are no longer available for use.

Grandparented USOC’s are as follows: HRCA1, HRCA3, HRCA5, HRCWM & HRL51, HRL53, HRL55, HRL5M, HRLA1, HRLA3, HRLA5, HRLAM, HRLB3, HRLB5, HRLBM, HRLC1, HRLC3, HRLC5, HRLCM, HRLD1, HRLD3, HRLD5, HRLDM, HRLE1, HRLE3, HRLE5, HRLEM, HRLF1, HRLF3, HRLF5, HRLFM, HRLG1, HRLG3, HRLG5, HRLGM, HRLW1, HRLW3, HRLW5, HRLWM

New USOC’s are as follows: GRLA1, GRLA3, GRLA5, GRLAM, GRLB1, GRLB3, GRLB5, GRLBM, GRLC1, GRLC3, GRLC5, GRLCM, GRLD1, GRLD3, GRLD5, GRLDM, GRLE1, GRLE3, GRLE5, GRLEM, GRLF1, GRLF3,GRLF5, GRLFM, GRLG1, GRLG3, GRLG5, GRLGM, GRLSM, GRLW1, GRLW3, GRLW5, GRLWM, GRLYM.

This list in not inclusive of all products provisioned with DSL. If further information is needed, please consult your Service Manager or a USOC guide.

In conclusion: In order to qualify for the 3-day interval, it will be necessary for the CLEC to know when Qwest installed the end-user’s Megabit service (before or after April 4, 2001) and whether the account meets the required criteria for requesting a 3-day interval. If the CLEC is unable to obtain the date of the installation information from the CSR or is unable to determine by the USOC, then additional consultation with the end user by the CLEC may be needed to find out when their Megabit service was installed, prior to or after the April 4th, 2001 date. Should the CLEC submit an LSR with a 3-day interval request and Qwest determines that the Megabit service does not qualify for the simple interval, then the FOC would be sent to the CLEC with the appropriate Design/Complex interval due date.

Discussion has occurred with the Interconnect Service Centers to reinforce this change that was previously documented, and sent out to the Centers, when the change occurred in April. Qwest will continue to follow the service interval guidelines for simple and complex services as outlined in the Product Catalog (PCAT).

Sincerely, Joan Wells Process Manager Local Number Portability

Open Product/Process CR 5582288 Detail

Description Of Change

Description changed resulting from 8/27/01 meeting.

The app date calculation for all LNP requests will reflect a 7 p.m. daily cut-off time rather than the 3 p.m. cut-off currently in place. Any LNP request received prior to 7 p.m. will receive an app date of the current date. Any LNP request received after 7 p.m. will receive an app date of the next business day.

Status History

Project Meetings

RE: CR Form #5582288 AT&T understands Qwest is denying our request to include Saturday as a business day in the SIG. In addition, Qwest is denying our request to manually change orders submitted prior to 7 p.m. MST on Wednesday to reflect a Saturday install date in lieu of a system change.

AT&T appreciates Qwest expanding the LSR submission deadline from 3 p.m. to 7 p.m. MST with the IMA 8.0 release. We are disappointed at the restriction placed on Saturday ports which Qwest had previously honored under the 3-day SIG (submissions of LSRs on Wednesday). Any additional action concerning this change request will be handled in a different venue when prudent. Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582288 - Saturday as a business date

Dear Lorna:

It was not the intention of AT&T to worsen the service delivery to our customers by accepting the LNP Service Intervals in the State 271 Workshops. Section 10.2.5.2 LNP Standard Intervals has been reviewed and AT&T does not believe this section prevents Qwest from processing the change request to include Saturday as a business date for the LNP product. In fact, AT&T can find no dialogue from the 271 workshops which addressed omitting Saturday as a business day when determining LNP intervals.

Before the IMA 8.0 upgrade the weekend of August 18th, Qwest honored a 3-day interval for a Saturday install as long as AT&T Broadband submitted the LSR prior to 3 p.m. MST on Wednesday. Qwest’s typing center set expectations that AT&T passed on to its customers by providing a FOC with the 3-day interval.

Qwest has stated Saturday cannot be counted in the standard interval. Per Qwest, all local service requests must be submitted prior to 3pm MST on Tuesday to receive the Saturday install date. While AT&T understands Qwest has implemented and updated their systems to reflect its intervals, AT&T believes changes to the same system including Saturday as a business day can also be accomplished in an upcoming release. Though AT&T realizes Qwest is extending its business day from 3:00 p.m. to 7:00 p.m. MST, it does not satisfy the CR5582288 AT&T submitted. Saturday is a critical install day for AT&T Broadband. Qwest’s shift in process and the failure to inform AT&T of this change created an undue and sudden burden for AT&T Broadband’s customers.

Therefore, AT&T would like to partner with Qwest to implement a change as previously practiced by Qwest which includes Saturday. In the interim, AT&T is requesting Qwest to manually change orders submitted prior to 3:00 p.m. MST on Wednesday to reflect a Saturday install date. Thank you for your consideration.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

###

September 7, 2001 2:15 p.m. Attendees:Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) The Qwest response to this CR was presented. AT&T reiterated concerns presented in an e-mail from August 30, 2001. The concerns centered on the fact that from June 1 until August 20 Qwest had used a process that allowed for a 3-day interval. After August 20 Qwest adjusted its process, requiring that requests be received by 3 p.m. Tuesday to qualify for a Saturday install. AT&T understands Qwest’s position that the process in place from June 1 through August 20 was incorrect. Furthermore, AT&T understands Qwest’s position that a reversion of process is necessary to remain compliant with guidelines decided in 271 Workshops. However, AT&T believes that Qwest should have been more effective in communicating the process change which resulted in an increase in the necessary interval to support a Saturday install. Qwest indicated that effective communication is a key element to implementing changes that affect CLECs.

Action Items: - Terry Bahner (AT&T) to provide confirmation of response acceptance (9/13)

### E-Mail from Terry Bahner (AT&T) to Qwest Thursday, August 30, 2001 12:15 p.m.

It's clear from the Qwest-Broadband call I facilitated this morning that Qwest has changed their process regarding the 3 day interval proces+U3when it pertains to a Saturday install date. From June 1st (PCNRN051601-1) to August 18, Qwest FOC'd a Saturday install date using the 3 day interval guide. As long as the LSR was sent prior to 3pm mst on Wednesday, Qwest gave the Saturday install date. On August 20th, Qwest changed its process. The LSR must be submitted on Tuesday before 3pm to have a Saturday install date. Qwest now states the due date interval guidelines do not include Saturday. Qwest has indicated the process was always in place and it was incorrectly interpreted by Qwest Escalations and typists and was therefore granted in error. AT&T reviewed the RN on multiple conference calls with Qwest and was told the requested Saturday date would be met. Further more AT&T was never informed the RN was a test/trial subject to change and/or interpretation by Qwest. AT&T considered the notification sent by Qwest on June 1st as a product and process change not a temporary fix as so indicated on this morning's call. While I welcome the extension of 3pm mst to the tentative 7pm mst, it no longer meets the intent of the CR. Therefore, please pursue with AT&T's request to include Saturday in Qwest's due date interval guidelines.

Thank you. Terry L. Bahner AT&T LSAM

###

Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry re-confirmed AT&T understands CR scope resulting from 8/14/01 meeting. To wit, the app date calculation for all LNP requests will reflect a 7 p.m. daily cut-off time rather than the 3 p.m. cut-off currently in place. Any LNP request received prior to 7 p.m. will receive an app date of the current date. Any LNP request received after 7 p.m. will receive an app date of the next business day.

In follow-up, Terry clarified: This is separate from agreeing to the current app date calculation Qwest has adopted August 20 (IMA 8.0 release) for LNP orders which now negatively impacts AT&T Broadband’s provisioning process and directly affects our market entry. AT&T will submit a separate change request to Qwest to resolve the additional day added to the LNP service interval if Qwest continues the new app date calculation process. This change request’s intent was to further extend the timeframe in submitting LSRs to facilitate a 3-day install; however, Qwest’s new app date calculation has negated this. Lorna indicated that a new Qwest User Request (UR # 2491) has been created to support the requested change. Work is underway to prioritize the request and determine when it will be implemented. This information will be provided in the Qwest response for this CR.

Lorna indicated that efforts had been underway to (piggyback) this CR on an existing user request in an attempt to complete the change sooner. However, that effort failed and new UR (2491) was issued.

Action Items: - Lorna Dubose (Qwest) to formulate Qwest response by 8/31/01 - Michael Buck (Qwest) to organize a walk-through meeting with AT&T during week of 9/3/01.

###

LNP Meeting Notes 08/13/01 Attendees: Lorna Dubaose Matt Rossi Terry Bahner Donna Osborne-Miller

NPAC does not currently consider Saturday as a business day AT&T gave an example: if LSR submitted 3:01 pm on Friday - Monday is day 1, AT&T would like Saturday as day 1 Joan Wells mentioned at last CICMP that hours might be expanded to 7pm MST AT&T said that 7pm wold be sufficient and CR could be closed

CenturyLink Response

Wholesale Product Marketing Ms. Terry Bahner and Ms. Donna Osborne, AT&T

This letter is in response to your letter dated September 14, 2001, regarding Change Request 5582288 – Saturday as a business day.

Qwest acknowledges AT&T’s acceptance of the agreed upon 271 Workshop LNP Service Intervals.

As stated in your letter, before the IMA 8.0 release, Qwest would honor a three day interval for a Saturday install for LSR’s submitted prior to 3:00 p.m. Mountain Time on Wednesdays. However, after the IMA 8.0 release each CLEC, will need to submit its LSR for flow-through LNP orders on Tuesday by 7:00 p.m., Mountain Time, in order to have a Saturday due date.

Qwest identified the need to implement system logic to obtain parity between our manual and mechanized processes, company policies, as well as documentation. As a result, IMA was upgraded to support the company Service Interval Guide (SIG), which excludes the calculation of Saturdays, Sundays, and Holidays.

Qwest recognizes Saturday is a critical install day for AT&T Broadband and will continue to offer Saturdays, Sundays, and Holidays as due dates in our switches where the 10-digit unconditional LNP trigger can be set automatically. However, the CLEC will need to submit the LSR within the appropriate interval timeframe as far as business days.

At this time, Qwest appreciates AT&T offer to partner with us to include Saturday as a business day, however, Qwest declines, and will continue to support the agreed upon 271 Workshop intervals and existing company practice for the use of Business days. Thank you for your request.

Sincerely,

Lorna Dubose LNP Product Manager

Open Product/Process CR 5582295 Detail

Description Of Change

Status History

Project Meetings

Subject: CR # 5582295 Update Date: Thu, 11 Apr 2002 09:15:41 -0600 From: "Todd Mead" Organization: Qwest Communications International, Inc. To: Terry Bahner

Terry, Please see below in response to your question about PCAT update:

"The LEFV fid alone is not necessarily cause for the CLEC to be sent a jeopardy notification. Only if the FOC has been sent to the CLEC would we send a jeopardy notification. And the current process of jeopardy after FOC states that in all conditions where an FOC is sent and Qwest has found a problem with the request, we will follow the jeopardy after FOC process. No matter what, if it has been FOC'd and Qwest finds a problem with the LSR, we will follow the jeopardy after FOC process.

Thanks

Todd

03/06/02 Letter from AT&T offering a counter proposal to the matrix Qwest has presented for CR5582295

1875 Lawrence St. Denver, CO 80202-1847

March 6, 2002

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

RE: CR5582295, SCR092601, & Matrix

Dear Todd:

AT&T still has concerns surrounding the interim manual process of how and when Qwest issues a jeopardy after sending the CLEC a FOC for an LSR. We have two specific concerns. This first is the introduction of the Application Date (APP) as a tool to determine AT&T Broadband’s due date when orders are issued a jeopardy condition. And the second is the subjective use of the term "renegotiated".

AT&T believes Qwest could proactively minimize disruption to the customer if Qwest would maintain the CLEC ordered due date more frequently than is possible with the Qwest proposal.

AT&T proposes the following changes to achieve this objective:

1. Jeopardy Condition identified within 24 hours then original FOC’d due date will be maintained - Identified within 24 hours after LSR submission by CLEC - CLEC notified within 24 hours after LSR submission by CLEC - Jeopardy cleared within 4 business hours

Jeopardy Condition identified within 24 hours then original FOC’d due date will be renegotiated - Jeopardy not cleared within 4 business hours

2. Jeopardy Condition identified more than 24 hours then original FOC’d due date will be maintained - Identified more than 24 hours after LSR submission by CLEC but before the due date - CLEC notified more than 24 hours after LSR submission by CLEC but before the due date - Jeopardy condition is Qwest’s fault and CLEC clears the condition within 4 business hours

Jeopardy Condition identified more than 24 hours then original FOC’d due date will be renegotiated - Jeopardy condition is CLEC’s fault and CLEC clears the condition within 4 business hours - Jeopardy condition is not cleared within 4 business hours

3. Jeopardy condition identified on or after the due date - Qwest will immediately work with CLEC to resolve end user customer impact. No negotiated due date

AT&T would like written rules about the meaning of “renegotiated”. AT&T believes the renegotiated interval should have minimal customer impact and never exceed the standard service interval for LNP.

AT&T believes Qwest has reasonable time to identify all errors during the first 24 hours. If an error is discovered and the error is related to a Qwest CSR, a pending retail order or any error Qwest fails to identify, AT&T believes the FOC’d due date should be maintained. Our proposed changes define and clarify the process. We believe this will reduce misinterpretation of the process and provide a consistent response from Qwest during the escalation process.

AT&T appreciates Qwest extending the courtesy call to a third week. This allowed sufficient time for AT&T to verify the jeopardy was being received via EDI. It also provided sufficient time for AT&T to provide Qwest examples of when the process broke.

Sincerely,

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

Cc: Tim Boykin Sharon Van Meter Donna Osborne-Miller

02/22/02 Response e-mail from Qwest clarifying AT&T question on jeopardy and DD process for LNP

Subject: Re: CMP 2/20/2002: Action Item & Clarification Date: Fri, 22 Feb 2002 16:45:31 -0700 From: "Joan Wells" To: "Bahner, Teresa L (Terry), NCAM" CC: "Jill Martain" , Jill"

02:00 p.m. (MDT) / Friday 08 February 2002

Followup meeting to Investigate top reasons for error condition after FOC

Terry Bahner, AT&T Jonathan Spangler, AT&T Sharon Van Meter, AT&T Donna Osborne-Miller, AT&T Jill Martain, Qwest Joan Wells, Qwest Ric Martin, Qwest Michael Keegan, Qwest Christine Quinn-Struck, Qwest

Jill Martain presented the following historical values : Total LSRs submitted for AT&T in December for LNP was 15,121. Total Non-Fatal errors issued after FOC , 28. Of those 28, 13 were identified on the same day, 7 next day but within 24-hours, 8 after 24-hours.

Joan Wells discussed: The Service Interval Guide for Resale and Interconnection Services The Matrix for resolving Jeopardy Conditions and Effect on the DDD. The Qwest Ordering Screening Process The root cause for PON ZXDNV25275001 TN 303 463-0715 See attached PDF file "CR5582295 Interval Guide & jep matrix" which documents the above.

Joan Wells will revise the Qwest response to reference the discussion outlined in 2.2. The Qwest response will also indicate the desire by Qwest to work with AT&T to minimize changes to the AT&T FOC’d DD.

-

02:00 p.m. (MDT) / Thursday 31 January 2002

Investigate top reasons for error condition after FOC

Terry Bahner, AT&T Jonathan Spangler, AT&T Sharon Van Meter, AT&T Donna Osborne-Miller, AT&T Tim Boykin, AT&T Vernise York, AT&T Cynthia Linenberger, AT&T Ed Longstreet, AT&T Kerri Burke, AT&T Cheryl Moilanen, AT&T Scott Eicher, AT&T Jill Martain, Qwest Joan Wells, Qwest Ric Martin, Qwest Michael Keegan, Qwest Brandi Bentley, AT&T

Jill Martain provided a recap on the progress of CR 5582295 and Systems CR SCR 092601-1 stating we are still moving forward with a February 18 implementation. The process change will discontinue sending a non-fatal error notice after a FOC if an error condition is identified, and will send a jeopardy notice instead. If the error condition is identified within 24-hours, only a jeopardy notice will be sent. If it is after the 24th hour, a courtesy call (for LNP only) will also be made to notify the CLEC of the error condition. Clarification was made it is a courtesy call and the jeopardy notice is the official notification of the jeopardy condition. Jill further explained that if the jeopardy condition was responded to within 4-hours the orders would remain in the system and if no response was received the service orders would be canceled but the LSR would remain in a jeopardy condition for 30-business days. If at the end of 30-business days the LSR is still in a jeopardy status, the LSR would be rejected back to the CLEC..

Jill explained that the error report indentified several types of rejects. AT&T asked if Qwest had an idea of what the numbers were. Jill advised that she did not have time to review the details. AT&T asked for a listing of the areas of the error and the numbers. Jill explained that some problems came about when the order was pending disconnect then the Quality Checkers would notice a retail dissconnect that came through. She also indicated that some problems occur when there is a dfferent address then the one on the LSR.

AT&T asked if Qwest would honor the due date if AT&T issued their Sup. Qwest indicated that it was dependent on the time the Sup came in. Qwest clarified the process advising that when an error condition occurs after an FOC, Qwest will send a Jep notice, not a non-fatal error. The Jep would be sent back the same way the request was received (i.e. EDI, fax, etc.). Qwest explained that the LSR Order will stay in Jep status for 30 days. Qwest will only Jep the order in the first 24 hrs. On the 25th hour, Qwest will send the Jep and place a call. Qwest needs the Sup turnaround within 4 hrs and Qwest will respond in 24 hours after receipt of Sup. Qwest would issue an FOC, which would start the calculation over. AT&T advised that Qwest should still honor the due date if the Sup was issued within the time interval, especially if the Jep was due to a Qwest error. AT&T suggested that we have another meeting to address this question.

Joan Wells discussed the quality check process. A quality check typically takes place within the first day after the FOC. Qwest cannot commit to this timeframe due to potential volume and resource issues.

A question was raised on whether AT&T could have the Due Date. It was clarified that this would be only for LNP. Joan Wells indicated that she would have to go back to the team.

Qwest provided the root cause for the TN example that AT&T provided . The initial reject was due to a wrong address; however, that was corrected by AT&T Broadband. All following actions were the result of a Qwest agent mishandling this order after that FOC was sent. Joan Wells said this person was individually coached.

Action Plan Qwest will review the due date issue and revise its response to CR 5582295 as required. Qwest will pull historical data to identify the percentage of AT&T LSRs that are receiving an error condition after a FOC.. Qwest will set-up another meeting for Friday, February 8, 2002, from 2:00 PM to 4:00 PM. The manual process for all products associated with SCR 092601-1 is scheduled for implementation on 2/18

--

November 6, 2001 AT&T Reply to Final Response dated 10-24-01 Joan Wells Qwest LNP Process Manager

RE: CR Form #5582295

AT&T has stated in previous correspondence to Qwest and at the monthly CMP Product and Process forum the seriousness surrounding Qwest’s process to send a FOC then fatal reject it without notification to the CLECS. AT&T understands Qwest’s current process providing a 4-hour window for response to a non-fatal error notice. However, examples have been shared with Qwest on weekly calls where this process continues to fail. Therefore, AT&T expects Qwest to adhere to its commitment to allow a jeopardy notification after a FOC instead of a non-fatal error after a FOC as submitted under SCR092601-1. This was presented as a walk on at the October 18 Systems CMP meeting by Jill Martain as a candidate for the IMA 10.0 release scheduled for 2002. The CLEC community unanimously agreed to include the LNP product for this CR. Jill Martain concurred.

In regards to AT&T system changes, AT&T anticipated the need to update their IBICS system only after Qwest discounted the use of jeopardy codes on previous calls. When Qwest announced they would pursue using jeopardy codes (Loretta Huff calls August 31, 2001 and September 5th respectively) and informed AT&T that system changes were not required, AT&T did not pursue modifying IBICS since it is currently capable of handling jeopardy codes. AT&T OSS anticipates the upgrade to IMA 10.0 with SCR092601-1 to resolve this issue.

In the interim, AT&T expects Qwest to continue to follow its current 4-hour window process and make every effort to call AT&T Broadband before issuing a fatal reject. AT&T also expects Qwest to socialize this process with all centers directly involved with the LNP process with special emphasis on the Sierra Vista and Phoenix Centers and the duty supervisor in any Qwest Interconnect Center which provisions AT&T Broadband LSRs.

AT&T does not believe this CR has been fully addressed until SCR092601-1 can be implemented or Qwest discontinues its process of fatal rejecting an LSR without CLEC notification.

Sincerely, Terry Bahner AT&T Local Services – LSAM Western Region

CC: Sharon Van Meter Tim Boykin Donna Osborne-Miller Mitch Menezes

September 14, 2001

Lorna Dubose LNP Wholesale Product Manager Qwest Communications 1801 California Street Denver, Colorado 80202

RE: Your letter dated September 5, 2001 regarding change request 5582295 – Cancel after the FOC

Dear Lorna:

Qwest has forwarded two proposals to AT&T. The first was discussed with Loretta Huff from Qwest on Friday, August 31st. The second proposal, Qwest letter sent September 5th, was based on Qwest changing its process and AT&T making changes to IBICS. Ms. Huff, in a conference call, indicated to the CLEC community that Qwest would utilize jeopardy codes on local service requests to alert the CLEC community when an LSR is rejected.

Qwest has taken an action item to internally review which process will be the final resolution to CR 5582295. AT&T has stopped all plans to augment its EDI system based on Ms. Huff’s proposal. AT&T believes the CR has not been sufficiently addressed. Please let me know when Qwest would like to schedule a conference call to discuss the final resolution for CR 5582295.

Sincerely,

Terry Bahner Supervisor Local Services Access Management Western Region

CC: Tim Boykin Sharon Van Meter Mitchell Menezes

Internal Response Clarification Meeting (9/10/01 3:30 p.m.)

Attendees: Joan Wells, Mark Coyne, Jill Martain, Todd Mead, Michael Buck

Mark and Jill explained the context of the Loretta Huff process. Joan provided information regarding Qwest response provided to AT&T. It was determined that the already provided Qwest response was probably accurate and not affected by the Loretta Huff response. However, Joan took an action item to review the Loretta Huff process. Following the review, Joan will update the CR response as necessary.

Action Items:

- Jill Martain to provide Joan Wells with the Loretta Huff process given to the CLECs - Joan Wells to review process and update CR response as necessary (target due date: 9/26/01)

September 7, 2001 2:15 p.m. Attendees: Terry Bahner (AT&T), Donna Osborne-Miller (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Joan Wells (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Before the Qwest response was presented AT&T indicated that the information contained in the response was contrary to information presented in another meeting held on September 6. Because of this inconsistency, AT&T requested that Qwest clarify the response before AT&T would accept it. Terry Bahner did confirm that the incidence of this situation (i.e. rejection of LSRs after FOC) had been much reduced since installation of IMA 8.0. However, Terry indicated that she was aware of a few situations where an LSR was rejected after FOC. Joan Wells and Lorna Dubose both reiterated that according to guidelines in the PCAT there were some situations in which rejects might occur after an FOC. To rule out system bugs or non-compliance with process Terry will provide examples to Lorna for investigation

Action Items: - Mike Buck (Qwest) to gather additional data from Judy Schultz (9/7) -- completed 9/7/01 - Mike Buck (Qwest) to schedule meeting with Loretta Huff (Qwest), Mark Coyne (Qwest), Joan Wells, and Lorna Dubose (9/10) -- completed 9/10/01 - Qwest to formalize single consistent response to this request (9/12) - Terry Bahner (Qwest) to provide Lorna Dubose (Qwest) examples of rejected requests after FOC (9/14)

Monday, August 27, 2001 1 p.m. Attendees: Terry Bahner (AT&T), Sharon Van Meter (AT&T), Lorna Dubose (Qwest), Michael Buck (Qwest), Todd Mead (Qwest) Terry confirmed that initial indications are that IMA 8.0 fix seems to be working; original problem has occurred only once since IMA 8.0 release. Further testing is still required, but Terry is please with the results. Terry will continue her efforts to confirm/test recent change and report to Lorna as necessary. Terry also provided further information on a second aspect for this CR. Concurrent with the change to IMA, another change was made to AT&T’s IBICS system. The IBICS system change required some coordination with Qwest systems that resulted in the involvement of Cim Chambers (among others). At this point, AT&T recognizes a system change is required in order to receive the final reject from Qwest. AT&T has asked its vendor to supply the patch. The estimated time the patch will be ready is within 30 days. No systems changes have been made at this point in time to recognize a final reject after a FOC. Evaluation will begin once the patch has been installed. Like the changes to IMA 8.0, AT&T needs to evaluate the fix for its efficacy. Terry does not anticipate any further action needed by Qwest to support either the Qwest IMA changes or the AT&T IBICS changes. But until AT&T installs patch and completes confirmation testing Terry would like this CR to remain open. The time frame for observation is dependent on the system patch and Qwest’s newly adopted process to consistently call the Broadband centers prior to the final reject. Allowing AT&T Broadband a four hour window to change or cancel the LSR. Terry also expressed concern that AT&T’s new system, Launch Now, might have the same limitation that resulted in the changes to IBICS. However, Terry agreed that should problems be identified with Launch Now, she would open a new CR to address any Qwest involvement that might be required to support AT&T’s modifications to their system. Action Items: - Terry Bahner (AT&T) to provide Michael Buck with e-mail of Qwest contacts involved with IBICS issue (completed 8/28/2001) - Michael Buck (Qwest) to contact Qwest contacts involved with IBICS issue to confirm no further Qwest involvement needed (completed 8/30/01) - Terry Bahner (AT&T) to provide Lorna with any additional feedback on the results of AT&T confirmation testing for recent IMA changes. Terry to provide confirmation testing results feedback based on when the patch has been installed by AT&T’s vendor. The estimate is 30 days. Terry will provide Qwest a tentative date no later than September 19th CMP if patch has not already been installed. If no issues are identified as part of AT&T confirmation testing, CR to be subsequently closed.

LNP Meeting Notes - 8/13/01

Attendees: Lorna Dubose Matt Rossi Terry Bahner Donna Osborne-Miller

- AT&T getting rejects after FOC - They are not seeing the cancel notification/no phone call – cannot act on 4 hr interval for action - AT&T report that they are still receiving rejects - Terry to get examples of rejected LSRs from the Denver Center (PON numbers) to Lorna and Joan

CenturyLink Response

October 24, 2001 Wholesale Product/Process Ms. Terry Bahner AT&T Communications

This letter is in response to CLEC Change Request Form #5582295, dated June 6, 2001, title of change: Qwest does not cancel LSR after confirming FOC via pending “C’ order. This Change Request pertains to CLEC receipt of an order request cancellation, after having already received a Firm Order Confirmation (FOC). One resolution of this Change Request is specific to LNP Port Out and involved an update to a Qwest internal system. Qwest business process in the IMA 8.0 release was deployed effective August 20th, 2001. A check for pending orders on LNP Port Out requests will now be made, before the FOC is issued. If a pending order exists, the order is placed for manual review.

Additionally, Qwest examined our exception handling processes, including the notifications issued by Qwest in exception situations. The analysis revealed that current Qwest processes sometimes resulted in a non-standard series of notifications, such as an FOC after a reject notice or an FOC after an LSR completion.

To address concerns about exception handling processes, a call was held with a small number of CLEC’s on 8/31/01 to solicit their input on Qwest’s current process. After considering the input that was provided, Qwest is taking the following current actions:

In those cases where an error is discovered after an FOC is sent, Qwest will continue to follow its current process of following the non-fatal reject process. This process was documented in a notice issued on 7/26/01. The process was also documented in IMA EDI 7.0 Disclosure, Addendum #6, released on 8/30/01 and in IMA EDI 8.0 Disclosure, Addendum #1, released on 9/04/01. The current versions of the disclosure documentation states that the CLEC has 2 hours to respond to the non-fatal error notice.

A documentation notice will be sent 9/24/01 indicating that in the situation where an FOC has been sent in error, a 4-hour window will be given for responding to the non-fatal error notice. The EDI Disclosure document will be updated following resolution of the Change Management Process (CMP) Change Request (CR) described below. (Product Specific to LNP, Qwest will allow a 4-hour window for response to a non-fatal error notice, whether or not the FOC has been previously sent.)

Due to CLEC input during the 8/31/01 call requesting a different process be followed, Qwest has opened a CR through the Change Management Process (CMP) for CLEC consideration. The purpose of SCR092601-1 will be to address the process of sending jeopardy notifications instead of following the non-fatal reject process, once the FOC has been sent to the CLEC.

Currently there are internal system limitation’s involving the inability to send jeopardy notification’s in association with Local Number Portability service order requests. This system change is being looked into with completion of the change request SCR092601-1. There is no time frame available for this system change at this time.

Local Number Portability Service Order requests will continue to follow the non-fatal reject process until such time that a system change can be implemented.

Related to this Change Request, AT&T had anticipated the need to update their IBICS system. In response to this perceived need Qwest previously provided systems expertise and answers to questions in support of AT&T planning efforts for intended modifications to their IBICS system. In a status update meeting held on August 27, 2001 AT&T indicated that no further Qwest support was likely to be needed in support of AT&T’s IBICS system modifications. Furthermore, in a letter dated September 14, 2001, AT&T has indicated that all plans to augment its EDI systems have been halted. Should AT&T elect to make IBICS system modifications, Qwest believes that the necessary information has already been provided. The change to Qwest process (via IMA) and the potential change to AT&T’s IBICS system will need to be evaluated to ensure their effectiveness. This confirmation testing effort is the responsibility of AT&T. Qwest understands that AT&T will notify Qwest of any issues that arise during testing of these changes, should they occur. However, it is noted that upon implementation of the new jeopardy process after FOC, that AT&T system changes may no longer be necessary.

It is anticipated that no further Qwest involvement is necessary with regard to this Change Request and that further involvement will center around SCR092601-1.

Sincerely,

Joan Wells Process Manager Local Number Portability

CC: Mark Coyne Loretta Huff Michael Belt Jill Martain Lorna Dubose Margaret Bumgarner Michael Buck Todd Mead

Open Product/Process CR 5582318 Detail

Description Of Change

·1: A certified letter - stating that either no customers were ever installed in the collo or if customers were installed, AT&T has notified them their service will be disconnected or moved - and a copy of the decommission application must to be sent to the Account Team Representative. Prior to this process change, AT&T was not required to do this. We have processed approximately 10 decommission applications so far this year and have not sent a certified letter for any of them.

Resolution: AT&T wants to send the application via email only as before.

2. The decommission process reads "The completion of a decommission request and 100% payment of any outstanding financial obligation, will terminate the billing of recurring charges for the site." What this means to AT&T is that we should be current on any bills for the collocation we are decommissioning. What this means to Qwest is that if there is any outstanding bills - either non recurring or recurring - due for any collocation in Qwest territory, they will NOT process the decommission application until all bills for all sites are paid. AT&T may incur additional monthly charges for the collocation being decommissioned since the application is on hold.

Resolution: It is AT&T’s request that only the non recurring and recurring bills for the collocation being decommissioned be subject to scrutiny.

3. Since Qwest charges AT&T a flat fee to decommission a site, AT&T has inquired about the possibility of conducting a site visit to ensure that Qwest has completed the decommissioning of the site. Qwest has denied AT&T this final site visit. Although Qwest may disconnect power cables, conduct a site visit and complete database work, they do not actually tear down the actual site. Qwest is hoping to lease the space to another CLEC and will not have to rebuild the space. Qwest assures AT&T that if the space is leased within a year of the decommissioning, AT&T will reimbursed some monies for the collo space.

Resolution: AT&T would like proof that the work has been completed.

Status History

Project Meetings

As a result of your feedback concerning Qwest’s recently issued Decommission procedures for existing Collocation sites, Qwest is adopting an interim plan for 90 days. During this interim 90-day period, Qwest will hold a series of meetings and conference calls with the industry to develop mutually acceptable procedures to follow concerning this issue. Please review the interim changes and the calendar of meetings below. We sincerely hope that you will participate.

Interim Changes Effective August 9, 2001 • Qwest will no longer issue a Quote of $3455 for each decommission before monthly recurring billing stops.

Qwest is waiving the Decommission Quote charges effective immediately with issuance of this announcement. Future pricing will be reviewed as part of the “Future Procedures Modifications Process” as described below.

• Qwest will credit past decommission quotes paid and any monthly charges paid past the date of acceptance of the valid application. CLECs can contact their Wholesale Project Manager regarding past decommissions processed or currently being processed.

• The vacating CLEC submitting the “Collocation Application for Cancel, Decommission, or Change of Responsibility” will no longer be required to be current on all billing for all collocation sites, including both monthly and non-recurring quotes before Qwest will process a decommission request.

• The interim requirement will state that a CLEC must be current on “all billing for the specific site for which the decommission application is submitted” for Qwest to decommission a site.

• Qwest will no longer require receipt of the quote charges to stop billing. Monthly billing will stop effective with the valid receipt of a decommission application.

• Applications will no longer need to be sent via certified mail for processing. “Electronic submission of requests to decommission a site can be sent to colo@qwest.com”

Future Procedures Modifications Process Qwest intends to issue future procedures that are acceptable to those parties concerned. For Qwest to implement satisfactory procedures, CLEC feedback is needed and valued. At the completion of this joint 90-day effort, the revised product procedures will be priced, and if appropriate, a template offered by Qwest for an amendment to the CLEC/Qwest

Interconnection Agreements. Please join Qwest in participating in the following calendar of meetings. These meetings will be chaired by Steve Nelson, Group Product Manager Collocation. He can be reached on 303-896-6357. Interested CLECs are encouraged to participate.

Kick-off meeting

August 9th, from 9am to 3pm, 1801 California, Executive Conference room, 23rd floor. Conference bridge: 877-542-1778, pass code 6904985.

1. Review existing product offerings and proposed changes, gather information on additional proposed changes, understand all concerns. Here is a brief outline of the discussion: 2. Agree to as many items as possible initially, table for future review those items requiring detailed response, and respond to disputed items by next meeting for resolution. 3. Capture voting record of participants on each issue, and dissenting opinion as agreed to by the team. 4. Prioritization of changes and timelines. 5. Review costing of current products. Items included in the costing model. 6. Discuss how other ILECs handle cancellation, decommission, change of responsibility or network transfer.

CenturyLink Response

October 31, 2001 Sharon Van Meter Manager, AT&T 1875 Lawrence St., 10th floor Denver, Colorado 80202

CC: William Campbell Steve Nelson Jane Lacy

This letter is in response to CLEC Change Request Form #5582318, dated June 25, 2001. This Change Request pertains to several issues regarding the Decommission product offering. On July 9th Qwest committed to partnering with the CLEC industry to resolve the issues identified in the Change Request Form specifically referring to decommission procedures. In addition, Qwest expanded this effort to review the product offerings for Cancellation, and Change of Responsibility. Throughout the month of August, September and October representatives from Qwest and the CLEC industry met to review the procedures for administering a Cancellation and Decommission request. The Qwest/CLEC Forum meetings will continue as we work together to revamp the Change of Responsibility product offering procedures. Successful resolution was achieved for those items addressed in the Decommission Change Request Form. Your efforts were instrumental in this partnership effort.

The following is a summary of the issues identified in the Decommission Change Request Form and the resolution for each: AT&T objected to process changes unilaterally without input from AT&T. Qwest committed to participate in a joint effort to review the Cancel, Decommission, and Change of Responsibility product offerings with CLEC industry and met that commitment. AT&T objected to the requirement to submit a certified letter stating that AT&T customers were notified of the disconnect or move. Qwest agreed to modify the process and allow both the application and confirmation notice to be sent electronically to the rfsmet@qwest.com mailbox. AT&T objected to the requirement that 100% payment of any outstanding financial obligation must be met in order to terminate billing of recurring charges. Qwest modified the procedures to state that financial obligations must be met with respect to the collocation site that is being decommissioned only. We further defined the financial obligations to include all non-recurring and monthly recurring charges must not be greater than thirty (30) days past due. AT&T objected to when the monthly recurring charges would cease. Qwest agreed that the billing end date will coincide with the date of a valid Decommission Application submit date. AT&T felt that they should be entitled to some monies for reimbursable elements at the Decommission site. Qwest agreed that a CLEC would be eligible for reimbursement on the re-usable elements for up to one (1) year from the Decommission Application submit date.

The following is the implementation schedule for the revised Cancellation and Decommission procedures: 11/15/01 - CMP Notification 12/01/01 - CLEC Review Period 12/15/01 - Revised Cancellation and Decommission procedures posted on the Collocation PCAT 01/01/02 - Effective date for the revised Cancellation and Decommission procedures

In summary, Qwest believes that we have satisfied your concerns regarding the Decommission and Cancellation procedures and therefore are considering this Change Request closed.

Sincerely,

Steve Nelson Group Collocation Product Manager

Open Product/Process CR PC021903-1CM Detail

Description Of Change

Status History

Project Meetings

White-Qwest stated that the change was implemented on 5/30. Quintana-CPUC asked if the new language was in the PCAT. White-Qwest stated that he would find out and send Quintana an e-mail. ======================================= 05-21-03 CMP Meeting

White-Qwest provided a status.

======================================== Ad Hoc – Vote Meeting Minutes 05-27-03

Attendees Matt White – Qwest Rene Albersheim – Qwest Wendy Green – Qwest Lori Mendoza - Allegiance Liz Balvin – MCI Mike Zulevic - Covad Sharon Van Meter – AT&T

White-Qwest described the purpose of the meeting, explained that the standard for quorum was 6 carriers and stated that the voting standard was unanimity. He stated that Qwest had received Eschelon’s vote ahead of time and that with it, quorum had been established. He asked if there were any questions. There were none.

White-Qwest opened the balloting. The carriers on the line all cast their vote by voice as follows:

Qwest – Yes Allegiance – Yes Covad – Yes MCI – Yes AT&T – Yes

White-Qwest stated that Eschelon’s e-mail vote was ‘Yes’ the CR had passed by unanimous vote. He asked how the change should be implemented. Van Meter-AT&T stated that AT&T would like it implemented with a Level 1 Notification. There were no objections. White-Qwest thanked the attendees and adjourned the call.

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Ad Hoc Meeting Minutes 05-15-03

Attendees Wendy Green – Qwest Matt White – Qwest John Finnegan – AT&T Lori Mendoza – Allegiance Liz Balvin – MCI Stephanie Prull – McLeod Bonnie Johnson – Eschelon Monica Avila – Vartec

White-Qwest welcomed the attendees and describes the purpose of the meeting. He asked if any of the participants had comments about the proposed language.

Balvin-MCI stated that her concern is that the way the language is written, Qwest can mess up the migration immediately before the sunset date and the CLEC can be left high and dry. Green-Qwest stated that by the time the release sunsets, Qwest will have migrated many CLECs. Similarly, Qwest tries not to schedule any migratations on the last weekend to allow for a week of cushion. Balvin-MCI stated that the possibility still exists for Qwest to require a CLEC to use the GUI. Finnegan-AT&T stated that MCI’s issue is that they may not be up and running on the new release in time. He stated that the language that was added addresses the possibility of stopping earlier than the 60th day. Balvin-MCI stated that her biggest concern is that there is nothing in the language that covers the CLECs if Qwest has any fault in the reason that the CLEC hasn’t successfully migrated. She asked what would happen if MCI realizes that, after migration, there are issues that are Qwest’s fault. She asked what the CLEC’s recourse was at that time. White-Qwest stated that Balvin’s concern was not within the scope of this CR. He stated that this CR was originated by AT&T to allow CLECs to skip releases, not to discuss the finer points of migration difficulties. Balvin-MCI stated that this doesn’t get to the point of telling the CLECs that they would need to get the GUI if they failed to migrate to the new release. Finnegan-AT&T stated that it sounded like MCI’s preference would be to extend the release a little further. Balvin-MCI stated that was what she was after if it is a Qwest issue that has fouled up the migration. Finnegan-AT&T asked if MCI was concerned about not being able to get onto the newest release. Balvin-MCI stated that the language as it stands has a hole in it. There is no guarantee that the CLECs will not get high and dry if Qwest messes up the migration. White-Qwest stated that this problem would apply to all situations when a release is sunsetting. He explained that was why it is necessary to do a new CR to address this issue. Finnegan-AT&T stated that the proposed language was originally set up to allow CLECs to skip releases. He stated that MCI is bringing up an additional issue to address what happens if a CLEC cannot get on a release. Balvin-MCI asked if AT&T was comfortable with the language as it sits. Finnegan-AT&T stated that he was comfortable that the language allows AT&T to skip releases. He explained that he shared the concern about the successful migration, but could see that being in a new CR. Balvin-MCI stated that her issue is outside the scope of this CR. She stated that she would want to add new language for normal and extended sunsets. Finnegan-AT&T asked if the team could include language that allowed the release to be extended further. Green-Qwest asked what happened when Qwest technically cannot extend the release any further, because Qwest can technically only support three releases. Balvin-MCI stated that was a good point. She stated that the 60 day retirement delay is usually bumping up against the forth version. She asked if there were ever periods when Qwest intends to do a migration, and has to postpone it. Green-Qwest stated that she has never seen that happen. Balvin-MCI asked if there had ever been a migration that Qwest has messed up. Green-Qwest stated that there had not. Balvin-MCI stated that she recognized that this would be a rare occurrence. She stated that she felt like this language is to cover Qwest and there is a chance for CLECs to be left high and dry. She stated that she did not want to upset the AT&T change request but did not know how to get around covering CLECs in this instance. She stated that language could read “If Qwest is unable to migrate a company, the 60 day retirement extension will be extended to allow the CLEC to successfully migrate.” Finnegan-AT&T stated that he did not know how to address MCI’s concern and move forward with this CR. Balvin-MCI stated that the language as proposed gets to what the CLECs are after. She stated that the other issue will be a separate CR.

Balvin-MCI stated that she would need to get with her internal contacts to develop a new CR. She stated that she was fine if the group voted on this one as it stands.

White-Qwest stated that Qwest would propose a date to vote on the change and distribute the appropriate notification.

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

Ad Hoc – Vote Meeting Minutes 04-28-03

Attendees Matt White – Qwest Dean Buhler – Qwest Wendy Green - Qwest Bonnie Johnson – Eschelon Liz Balvin – MCI Lori Mendoza – Allegiance Stephanie Prull – McLeod Donna Osborne-Miller – AT&T

White-Qwest described the purpose of the meeting, explained that the standard for quorum was 5 carriers, and that the voting standard was unanimous. He stated that quorum had been established and asked if there were any questions.

Johnson-Eschelon asked how Qwest kept track of who migrated. Green-Qwest stated that Qwest tracked conversions very quickly. She stated that Qwest wouldn’t retire the release until Qwest knew that all CLECs had successfully converted. Balvin-MCI stated that the language permitted Qwest to retire a release after all CLECs had converted without verifying that the conversions had been successful. She recommended that the language include “If all CLECs have successfully converted from the release.” Johnson-Eschelon recommended that the language include the phrase “successfully converted.” White-Qwest stated that Qwest would take the language back and attempt to address the concern. He explained that Qwest would then schedule another Ad Hoc meeting to discuss the additional proposed language. He stated that following that Ad Hoc meeting, Qwest could schedule a second vote meeting. He asked if there were any questions about the next steps. There were none. White-Qwest thanked the attendees and adjourned the meeting.

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

04-16-03 - CMP Meeting

White-Qwest described the CR and noted that the CMP community needed to vote on the proposed language. Menezes-AT&T stated that this proposed language ensured that a CLEC could skip a release. He also noted that the second timeline would be included in the CMP Document. White-Qwest proposed that the vote be held on 4/28.

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

03/19/03 CMP Meeting

Menezes-AT&T stated that because Buhler was not able to join the call AT&T and Qwest would have an off-line conversation about the Qwest proposed language. White-Qwest stated that he would schedule an Ah Hoc meeting to discuss the agreed-to language with the CMP community.

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

Ad Hoc CMP Meeting March 10, 2003

Attendees: Matt White – Qwest Wendy Green – Qwest Beth Foster – Qwest Dean Buhler – Qwest Renee Albersheim - Qwest Sue Stott – Qwest Donna Osborne-Miller – AT&T Mitch Menezes – AT&T John Finnegan – AT&T Carla Pardee – AT&T John Berard – Covad Mike Zulevic - Covad Bonnie Johnson – Eschelon Kim Isaacs – Eschelon Lori Mendoza – Allegiance Becky Quintana – CPUC

White-Qwest started the meeting by welcoming the attendees, explaining the purpose of the meeting, and asking AT&T to describe their CR.

Finnegan-AT&T stated that this CR was submitted so the language in the document allowed CLECs to skip on release if they wished. Quintana-CPUC asked if this impacted PO18 or PO19. Finnegan-AT&T stated that he would investigate if the PID description needed to be changed.

Buhler-Qwest stated that having to extend the old release would cause Qwest additional resource requirements and cost. He continued that Qwest did not disagree with the nature of the request but that Qwest was developing additional language to propose to minimize some of the effects of the change. He stated that Qwest would present these proposed changes at the March 19, 2003, CMP Monthly Meeting. Finnegan-AT&T stated that AT&T had no problem with that.

White-Qwest stated that the vote would not be held at the March 19, 2003, CMP Meeting, but the attendees at that meeting would decide when to hold a vote. Menezes-AT&T asked if the vote could be held between monthly meetings. White-Qwest stated that it could.

The meeting was adjourned.

Open Product/Process CR PC022703-5 Detail

Description Of Change

Expected deliverable: Change the PTA email notification to include the Qwest contact name, phone number and the PON

Status History

Project Meetings

05/21/03 May CMP Meeting Minutes Cindy Macy – Qwest advised this change was made on May 12, 2003. Deni – Qwest has reviewed the change and no problems have been found. Sharon – ATT will check with her team and potentially close in June. This CR will move to CLEC Test.

04/16/03 April CMP Meeting Minutes PC022703-5 Subject Line for PTA email notification changed

Deni Toye – Qwest advised we will accommodate this Request. Deni reviewed the response and advised Qwest will make this change targeting the middle of May. The NDT PTA email subject line will be changed to include PTA, Initiator Name, Initiator Phone Number and the PON. This will be made as a Level 1 change. This CR will move to Development status.

- 03/19/03 March CMP Meeting Minutes Sharon Van Meter – ATT reviewed and clarified the CR with the CLEC Community. She explained this request will impact all CLEC PTA emails. McLeod advised they support the change and would sign up for PTA notification if the subject line contained the tester name, number and PON. This CR will move to Presented status.

Clarification Meeting PC022703-5 2:30- 3:30 March 10, 2003 1-877-572-8687 3393947#

Attendees Deni Toye Qwest Denny Graham Qwest Brett Fesler Qwest Sharon Van Meter ATT Cindy Macy Qwest

Meeting Agenda:

1.0 Introduction of Attendees Attendance notes

2.0 Review Requested (Description of) Change Sharon ATT reviewed the Change Request with the team. Sharon and Deni discussed what information was requested to be in the Subject Line. Sharon advised the Qwest tester contact name and number and the PON from the LSR. Sharon advised this information would help ATT identify who needs to work the email notification at ATT. This will allow ATT to not have to open each email and determine who to assign it to.

Deni explained that the QCCC center does not divide their testing functions between their testers. Each tester can be assigned any testing job. Deni clarified this as Qwest didn’t understand the purpose of having the Qwest tester name and number on the PTA email subject line. Sharon agreed she would verify this information with her peers. (Sharon did reply after the clarification call that ATT would like the ‘ATT Initiator of the PON and his/her phone number).

Sharon advised that Verizon and Southwestern Bell provides this information on their test verification emails.

Deni asked if ATT wanted this change on just the PTA email or also the Test Results email. Sharon advised she would check on that and let us know. (Sharon replied this applies to just the PTA email)

Deni also asked if the words ‘PTA’ could remain on the email subject line. Sharon advised yes, PTA should remain on the subject line. The request would be to add to the PTA email subject line the ATT Initiator name and number and PON. Example: PTA – Initiator name/number/PON.

Deni confirmed if this change is made it would impact all CLECs.

3.0 Confirm Areas & Products Impacted Provisioning area impacted Unbundled Loop 2/4 wire is the product line that is impacted by this request

4.0 Confirm Right Personnel Involved Attendees are the correct personnel

5.0 Identify/Confirm CLEC’s Expectation PTA should remain on the subject line. The request would be to add to the PTA email subject line the ATT Initiator name and number and PON. Example: PTA – Initiator name/number/PON.

6.0 Identify any Dependent Systems Change Requests None

7.0 Establish Action Plan (Resolution Time Frame) Sharon will present this CR at the March CMP Meeting to the CLEC Community Qwest will investigate the request and reply at the April CMP Meeting

CenturyLink Response

April 8, 2003

Sharon Van Meter ATT

SUBJECT: Qwest’s Change Request Response – CR # PC022703-5 AT&T Subject Line Change PTA

This is in response to AT&T’s Change Request CR PC022703-5. This CR requests that Qwest change the subject line of the NDT PTA email notification to include the Initiator Name, Initiator Phone Number and the PON.

Qwest accepts this CR. Qwest will have the subject line contain PTA, Initiator Name, Initiator Phone Number and the PON, in that order. Qwest anticipates this change will be made in the early part of May.

Sincerely,

Deni Toye Process Specialist Qwest

Open Product/Process CR PC022703-1 Detail