Adding Qwest response to email chain.

 

Susan,

Please respond to this email.

 

Thank you,

 

Bonnie

 

 

Qwest/CMP,

Qwest is wrong when it states that a CLEC can implement this optional process when ready. There are two parties impacted by Qwest’s optional process. The OLSP and the NLSP. If Integra is the NLSP, Integra will need to react to a OLSP using Qwest’s optional process. This change alters Integra’s operating procedures. Qwest refusing to retract a level one notice when a CLEC identifies it alters operating procedures is not an option under the CMP.

 

Qwest can provide its support for authority when it issues a level 4 CR for this change. Qwest’s confirms in its email that this is not a alternative option to an existing process. Qwest admits the current process is advising the customer to contact the NLSP to cancel the request. This change Qwest is proposing is NOT an alternative process (same process alternate means to effectuate it.)  

 

5.4.2.1       Level 1 Process/Deliverables

For Level 1 changes, Qwest will provide a notification to CLECs.  Level 1 notifications will state the disposition level 1, description of change, that changes are effective immediately, that there is no comment cycle and will advise CLECs to contact the CMP Manager by e-mail at cmpcr@qwest.com immediately if the change alters the CLECs’ operating procedures and requires Qwest’s assistance to resolve. Qwest will respond to the CLEC, within one (1) business day, and work to resolve the issue. Possible resolutions may include withdrawal of the change, re-notification under a different level or creation of a new category of change under a different level.  In addition, Qwest will provide the following for PCAT and Non-FCC Technical Publication (“Tech Pub”) changes:

 

Qwest should retract this level one notice.

 

 

 

Bonnie and Kim,

 

This is in response to your recent emails that include an objection associated with Notification PROD.11.14.08.F.05712.LNP_V56. 

 

The current process, which is still available, requires the existing CLEC to tell its end user to contact the new (alternate) provider to cancel the request.  No other process existed, even though, as discussed below, industry standards supported alternate processes.

 

Qwest is simply providing an alternative to the current process should the existing CLEC choose to use it.

 

There is no restriction that prevents Qwest from implementing this optional process.  The old local service provider has the ability to cancel the port request based on its end user requests. Please refer to The Number Portability Administration Center at the following link http://www.npac.com/cmas/documents.shtml#ProcFlows - specifically the Cancellation Flows for Provisioning Process.  This industry document identifies that either the NLSP or the OLSP can request cancellation of the end user porting request.  

 

This optional process is available to any CLEC who chooses to use it.  However, if a CLEC requires additional time to implement, the process can be implemented at any time that CLEC is ready.   

 

In regard to the point about the CLEC having no indication of why Qwest is rejecting a request, as documented in the PCAT, the jeopardy notice will include either a C05 or SX jeopardy code and will include the following comment:  End User has requested cancellation of the Port request.

 

In addition, as indicated in the PCAT, there is the capability in this optional process that allows the alternate provider to issue a SUP request within four business hours and the CSIE will not cancel the pending port request:

If the LNP provider issues a SUP request within the 4 business hours JEP window, the CSIE will not cancel the pending port request and respond back to the Notification of Cancelled Port e-mail: Due to a more current request we cannot process your cancel.

 

As a result, Qwest does not plan to retract this notification.

From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com]
Sent: Tuesday, November 18, 2008 8:19 AM
To: New Cr, Cmp; Isaacs, Kimberly D.
Cc: 'cmpcr@qwest.com'; Johnson, Bonnie J.
Subject: RE: OBJECTION - FW: Product Notice:GN: CMP-LNPV56: Effective11-17-08

Susan,

Thank you for the response. Integra believes the only acceptable “resolution” is for Qwest to retract the notice. Integra discussed this with other CLECs on our call yesterday, and all CLECs agree that Qwest cannot cancel an LSR at another CLECs request. Please retract the notice today. If Qwest will not be retracting the notice please promptly let Integra know so it can escalate the matter.

 

Thanks,

 

Bonnie

 

 

Bonnie and Kim,

 

Qwest is working with the SME team to resolve this issue.

 

Thank you,

Susan Lorence

Qwest CMP Manager

402 422-4999

 

From: Johnson, Bonnie J. [mailto:bjjohnson@integratelecom.com]
Sent: Monday, November 17, 2008 12:06 PM
To: New Cr, Cmp; Isaacs, Kimberly D.
Cc: 'cmpcr@qwest.com'; Johnson, Bonnie J.
Subject: RE: OBJECTION - FW: Product Notice:GN: CMP-LNPV56: Effective11-17-08
Importance: High

Susan/CMP/Qwest,

Qwest should immediately retract this level one notice that Qwest issued erroneously for the following reasons:

 

Per Qwest, the process is optional for the old local service provider, however, if the old local provider uses the option the result and impact is NOT optional for the new local service provider. Even if the change were appropriate, which Integra does not agree is the case; Qwest has provided no opportunity for Integra to communicate this change to its business units. The business and operational personnel at Integra will have no indication of why Qwest is rejecting a request or how to react to the reject/cancel. If Qwest believes it has the appropriate authority to initiate such a change, it should do so as a level 4 CR.

 

Qwest has not provided the proper state or federal authority that, as the network provider, Qwest has authority to cancel a new provider’s LSR based on a request from the old local service provider. The information Qwest provided below highlighted in yellow is meant for the new local service provider and provides no cites to proper authority. If the End User customer desires to cancel its request to change local service providers, the End User Customer can contact the new local service provider, and the new local service provider can cancel the request to change local service providers. If Qwest can cite the proper authority then Qwest should include that information in its level 4 CR request for change.

 

 

Action Required:

Qwest will confirm that it will retract this level one notice. If Qwest refuses to retract the notice, Qwest will confirm that it will not cancel or reject any LSR Integra or its entities sends to Qwest based on a request from the old local service provider. Integra does not give Qwest authority to cancel any LSR, except for a cancelation initiated by Integra.

 

Thanks,

 

Bonnie

 

 

Kim,

 

The process described in this notice is an option to the existing process which requires the existing (original) provider to have their end user call their alternate provider to cancel the port request.

 

This optional process allows the existing provider to contact Qwest via email to cancel the port request to the alternate provider.

 

This process is not optional for the alternate carrier. It is only an option for the existing provider.

 

In response to the point about Qwest not providing support to cancel the alternate carrier’s port request, the process is only an option if the existing provider of record has a current  POA or LOA that indicates they are acting on behalf of the customer.  This is specified in the NOTE that follows the description of this process in the PCAT :

NOTE: As the service provider of choice, whether to cancel a port request or issue a SUP request to continue with the port, you are responsible for obtaining the most recent Proof of Authorization (POA), either via a LOA or another method. See additional information regarding Proof of Authorization. (Link italicized text to: http://www.qwest.com/wholesale/preorder/index.html)  In accordance with applicable laws and rules, if a dispute or discrepancy arises regarding your authority to act on behalf of the end-user or CLEC, you are responsible for providing Qwest evidence of the authorization within three business days.

Integra does not believe this process is optional for the porting carrier and Qwest has provide no support to indicate they can cancel an alternate carriers port request at an existing carriers request. If this was not Qwest intent with this notice that the notice is unclear. Therefore Integra is requesting that Qwest retract this Level 1 immediately.