Qwest/CMP,
McLeodUSA d/b/a PAETEC
Business Services agrees with Integra’s points noted in the objection
below. Consequently, Qwest should immediately retract the Level 1 Product
notice.
Julia
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Julia
Redman-Carter |
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From: Johnson,
Bonnie J.
Sent: Wednesday,
November 19, 2008 8:57 AM
To:
Johnson, Bonnie J.; 'New Cr, Cmp'; Isaacs, Kimberly D.
Cc: 'cmpcr@qwest.com';
jredman-carter@mcleodusa.com; Doug Allen (allendm@att.com); Johnson, Bonnie
J.
Subject: RE: OBJECTION - FW:
Product Notice:GN:
CMP-LNPV56:Effective11-17-08
Adding Qwest response
to email chain.
Susan,
Please respond to this
email.
Thank
you,
Bonnie
Bonnie J.
Johnson| Director Carrier
Relations
direct 612.436.6218 | fax 612.436.6318
From: New Cr,
Cmp [mailto:cmpcr2@qwest.com]
Sent: Wednesday, November 19, 2008 8:24
AM
To:
Cc:
Subject: RE: OBJECTION - FW: Product
Notice:GN: CMP-LNPV56:Effective11-17-08
Bonnie, We
are working with our SME team to discuss the most recent comments and are
determining next steps.
Thank
you,
Susan
Lorence
Qwest CMP
Manager
402
422-4999
From:
Sent: Tuesday, November 18, 2008 2:03
PM
To: 'New Cr, Cmp';
Cc:
Subject: RE:
OBJECTION - FW: Product Notice:GN:
CMP-LNPV56:Effective11-17-08
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.)
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 J.
Johnson| Director Carrier
Relations
direct 612.436.6218 | fax 612.436.6318
From: New Cr,
Cmp [mailto:cmpcr2@qwest.com]
Sent: Tuesday, November 18, 2008 12:45
PM
To: Johnson, Bonnie J.;
Isaacs, Kimberly D.
Cc:
'cmpcr@qwest.com'
Subject: RE:
OBJECTION - FW: Product Notice:GN:
CMP-LNPV56:Effective11-17-08
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.
Thank
you,
Susan
Lorence
Qwest CMP
Manager
402
422-4999
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 J.
Johnson| Director Carrier
Relations
direct 612.436.6218 | fax 612.436.6318
From: New Cr,
Cmp [mailto:cmpcr2@qwest.com]
Sent: Monday, November 17, 2008 4:42
PM
To:
Cc:
Subject: RE: OBJECTION - FW: Product
Notice:GN: CMP-LNPV56: Effective11-17-08
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:
Sent: Monday, November 17, 2008 12:06
PM
To: New Cr, Cmp;
Cc:
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
Bonnie J.
Johnson| Director Carrier
Relations
direct 612.436.6218 | fax 612.436.6318
From: New Cr,
Cmp [mailto:cmpcr2@qwest.com]
Sent: Monday, November 17, 2008 10:49
AM
To:
Cc:
Subject: RE: OBJECTION - FW: Product
Notice:GN: CMP-LNPV56: Effective 11-17-08
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.
Thank you,
Susan Lorence
Qwest CMP Manager
402 422-4999
From:
Sent: Friday, November 14, 2008 4:17
PM
To:
Subject: OBJECTION - FW: Product Notice:GN:
CMP-LNPV56: Effective 11-17-08
Importance:
High
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.
Kim
Isaacs | ILEC
Relations Process Specialist
ph. 612.436.6038 |
fax 612.436.6138
From:
mailouts2@qwest.com [mailto:mailouts2@qwest.com]
Sent: Friday, November 14, 2008 2:15
PM
To:
Subject: Product Notice:GN: CMP-LNPV56:
Effective 11-17-08
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