20110328360networks Comment.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 2D11 ~MR 28 PM 4= 5'
CASE NO. GNRMTM11M01
IN THE MATTER OF AN INVESTIGATION
OF AN APPROPRIATE CERTIFICATION
PROCESS FOR TELECOMMUNICATIONS
COMPANIES THAT DO NOT PROVIDE
BASIC LOCAL EXCHANGE SERVICE
)
)
)
)
)
COMMENTS OF 360NETWORKS (USA) INC.
360networks (USA) inc. (360networks) hereby responds to the Idaho Public Utilties
Commission's (Commission or 10 PUC) Notice of Investigation, Notice of Modified Procedure,
Order No. 32194 requesting comments addressing the need or purpose of a certification for
telecommunications companies that provide local services other than basic local exchange
service in Idaho. Specifically, the Commission solicits responses to the following questions:
1. Is certification by the Commission necessary for companies providing
telecommunications services but not basic local exchange service?
2. If some sort of Commission certification is needed, what form or designation might it
take?
3. What legal authority does the Commission have to issue certification that is not a
Certificate of Public Convenience and Necessity?
4. What can the Commission do to ensure numbers are used efficiently by CLECs and
other telecommunications providers?
DISCUSSION
Question No.1: Is certification by the commission necessary for companies providing
telecommunications services but not basic local exchange service?
In its Notice, the Commission explains that the background for this Investigation is its denial of a
request by Time Warner Cable Information Services, LLC (TWCIS) for a Certificate of Public
Convenience and Necessity (CPCN) authorizing it to provide telecommunications services because
the Company was not planning to offer "basic local exchange service" as defined in Title 61, Idaho
Code. "Basic local Exchange Service" means "the provision of access lines to residential and small
business customers with the associated transmission of two-way interactive switched voice
communication within a local exchange callng area.',i In denying TWCIS' request, the Commission
observed that TWClS advised that it would be operating as a wholesale local telecommunications
provider in Idaho, not a retail provider. Thus, the Commission found that TWciS would not be
providing basic local exchange service itself but would be enabling other providers to do so and
therefore, it was not appropriate under state law to grant its request. Order 31012 at p. 5 and
Order No. 32059 at p. 9.
In the TWCIS orders referenced, the Commission acknowledges the rights of telecommunications
carriers as defined by the 1996 federal Telecommunications Act, 47 USC Section 151 et seq. to
provide telecommunications services in Idaho, including wholesale local telecommunications
services. The denial was specifically based on a determination that under state law, TWClS did not
qualify for a CPCN since the state CPCN process is limited to retail basic local exchange providers.
See Order 32059 at pp. 12-14. 360networks responds to the Notice with this background in mind
and interprets the questions posed to relate to the "certification" of wholesale local exchange
providers in Idaho.
In order to enter into interconnection agreements with Qwest, Verizon and CenturyTel, a CLEC is
required by the incumbents to provide a certificate of authority from the Commission enabling it to
do business as a ClEC in the state.2 An Idaho specific CLEC certification is also required for a CLEC
to obtain company codes that allow it to exchange information with other telecommunications
providers for the proper routing and rating of telecommunications traffic transmitted between it
and the rest of the industry.3 Furthermore, a CLEC is not able to obtain numbering resources in
Idaho if it does not obtain written authorization from the Idaho PUC to provide local services here.4
It appears from the briefing and orders in the TWCIS docket that the Commission does not
currently have a process in place to provide a written document demonstrating a wholesale
carriets "authorization" to operate as a non retail local exchange carrier in Idaho. In order to
exercise the above listed Section 251 rights, evidençe of an "authorization" is required. Thus, if it
is correct that no process exists today to address this issue, the undersigned recommends that the
Commission adopt one.
Question No.2: If some sort of Commission certification is needed, what form or
designation might it take?
The Commission here in Idaho may adopt a process similar to that adopted by the Iowa
Department of Commerce Utilities Board to award an alternative certificate to carriers that provide
1 Idaho Code Section 62-603(1).2 See Exhibits A, Band C attached, web pages of Qwest, Verizon and CenturyTel instructIng CLEes how to obtain
interconnectIon.3 See Exhibit D, NECA North American Company Code Assignment Procedures at pp. 1,5 and 6.
4 see 47 C.F.R. Section 52.15(g)(2J(i).
2
wholesale telecommunications services in its state. In Iowa, "a utilty must have a certificate of
public convenience and necessity issued by the board before furnishing land-line local telephone
service in this state."s The Iowa Board determined that "land-line local telephone service" either
"amounts to (or a substitute for) regular dial tone service, the traditional focus of the Board's
regulation.IiG This service is only one of several services that may be provided by a carrier under
the federal Act to qualify a carrier as a local exchange carrier. To close the gap between state and
federal law and allow competitive local telecommunications service providers seeking to provide
services in Iowa to exercise their Section 251 and 252 rights, the Board established a separate
"certification" process to be used by those local exchange carriers that do not meet the state CPCN
requirement but enables the providers to exercise rights, privileges and obligations under the
federal Act? The Board found that establishing this separate "certification" process was consistent
with the state legislature's intent to require the Board to "exercise regulatory flexibilty in a
changing telecommunications environment.',8
Question No.3: What'legl authority does the Commission have to Issue certification that is not
a certificate of Public Convenience and Necessity?
The Wireline Competition Bureau of the FCC determined,"wholesale providers of
telecommunications services are telecommunications carriers for the purposes of sections
251(a) and (b) ofthe Act, and are entitled to the rights oftelecommunications carriers under
that provision."9 In reaching this conclusion, the Bureau observed,
(O)ur decision today is consistent with and will advance the Commission's goals in
promoting facilities-based competition as well as broadband deployment. Apart from
encouraging competition for wholesale services in their own right, ensuring the
protections of section 251 interconnection is a critical component for the growth of
facilities-based local competition. Moreover, as the Commission has recognized most
recently in the VolP 911 Order, VolP is often accessed over broadband facilities, and
there is a nexus between the availabilty of VolP services and the goals of section 706
of the Act. Furthermore, as the Petition and some commenters note, in that order the
Commission expressly contemplated that VolP providers would obtain access to and
interconnection with the PSTN through competitive carriers. Therefore, we also rely on
section 706 as a ba~is for our determination today that affirming the rights of
wholesale carriers to interconnect for the purpose of exchanging traffc with VolP
5 Iowa Code Section 476.29
6 Iowa Department of Commerce Utilties Board, Docket Nos. TCU-02-1, March 15, 2002 Order at p. 2.
7 See Iowa Departent of Commerce Utilties Board, Docket Nos. TCU-02-1, TF-DS-31, SPU-OS-21.
8 See Docket No. TCU-08-07 Order in Lieu Of Certificate (Issued July 25, 2008) at p. 2.
9 Memorandum Opinion and Order, In the Matter
of Time Warner Cable Requestfor Declaratory Ruling that
Competitive Local Exchange Carriers May Obtain Interconnection Under Section 251 of the Communications Act of
1934, as Amended, to Provide Wholesale TelecommunIcations Services to VolP Providers, we Docket No. 06-55, 22
FCC Red 3513 (rei' March 1, 2007) at para. 1.
3
providers wil spur the development of broadband infrastructure. We further conclude
that such wholesale competition and its facilitation of the introduction of new
technology holds particular promise for consumers in rural areas. (Footnotes
omited)lo
Moreover, the Act and implementing FCC orders provide that the states playa critical role in
promoting local competition.ll
Idaho state law gives the Commission the full power and authority to implement the federal
Telecommunication Act of 1996, and to promulgate rules and/or procedures necessary to carry
out the duties authorized or required by the Act.12 The Commission may use this authority
under both state law and the Act to promulgate a process to issue a written certificate to a
wholesale provider of telecommunications services wishing to operate in its state.
Question No.4: What can the Commission do to ensure numbers are used efficiently by
CLECs and other telecommunications providers?
No change to existing practice is required. Wholesale telecommunications providers requesting
numbers from the North American Numbering Administrator have the same obligations as
retail telecommunications providers under 47 C.F.R. Part 52. The wholesale provider extends
the same obligations to any non-telecommunications provider customers through commercial
agreements.
-¥t-
Dated this~ay of March 2010.Respectfully Submitted,
10 Id. at para. 13.
11 See First Report and Order, In the Matter of Implementation of the Local Competition Provisions in the
Telecommunications Act of 1996, CC Docket No. 96-98, FCC 96-325 (rei' August 8, 1996) at para. 133.12 Idaho Code Section 62-615.
4
)
)
Getting Started as a CLEe Checklist .
Wholesale Interconnection/Getting Started as a Facilty-Based CLEC Download
Qwest.J2
Wholesale Markets
Getting Started As A CLEC
linking Our Strengths With Yours
A number of steps must be completed for you to successfully interconnect with Owest as a Competitive Local
Exchange Carrier (CLEC). Owest provides this checklist to define our joint activities and results (by responsibilty
owner), where information is obtained and the timeframe suggested to perform the activity, many of which can be
done as you obtain your state cerification(s) as well as in parallel with each other.
Fulfillng Regulatory and Industry Related Requirements
Page 1 of9
GS_CLEC _ Chec!disto9-04.09.doc
Getting Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a Facility~Based CLEC Download
Qwest-2
V'JholesaJe Markets
Activities and Results Wheretri-Obtain Information .Tlmeframe--- _...SuggeSted..~....--
CLEC Responsibilties:
.Obtain certifcation as a telecommunications · State Public Utilty Commission/Agency .Before
provider enabling you to do business as a in state(s) you are operating as a CLEC.Negotiations
CLEC.Step 2 of Getting Started as a Facility-
Based CLEC:
http://ww.qwest.com/wholesale/clecs/c
lec_index.html
.Secure unique Operating Company Number · OCN: National Exchange Carrier
(OCN), Access Customer Name Abbreviation Association (NECA) 800-228-8597 ext
(ACNA) and Revenue Accounting Code 8249 or 973-884-8249 or
(RAO) (if choosing Qwst as your RAO)http://w.neca.orglsource/NECA Hom
identifiers for each state you wil be operating e.asp
as a CLEC.· ACNA & RAO: Telcordia 732-6.99-5281
or http://ww.telcordia.com
.Create your E911 plan contacting the
relevant Public Service Answering Point · E911 & PSAP:
(PSAP) to negotiate a default Emergency http://w.qwest.comlwolesale/pcatl9
Service Network (ESN) and establish default 11.html
routing confgurations for Automatic Number
Identification (ANI)..To provide your switch-based end-users .NPAlNXX:
numbers begin obtaining your NPAlXX for http://ww.gwest.comlwholesale/notice
each NPA you wil be operating.s/npa nxxProcess.html
.Identify your Revenue Accounting provider for .North American Numbering Plan
each state you wil be operating as a CLEC.Administration http://w.nanpa.com
Note: Sales Executve assists with .CMDS:
Centalized Message Distribution System http://w.qwest.comlholesalefpcatlc
(CMDS) hosting agreement if Owest chosen mds.html
as your Revenue Accounting provider..Operator Services (OS):.Determine Operator Services / Directory
Assistance (OS/DA) provider, if applicable.http://ww.gwest.comfwholesalefpcatlo
Note: Separate agreement required if not psserv.html and Regional Directory
within your Interconnect Agreement. Sales Assistance Database (DA):
Executive wil negotiate if applicable.http://ww.qwest.comlwholesale/pcatJv
oicedirasst. htm I
Establish your Initial Local Interconnection .LIS;.
Service (US) forecast.http://ww.gwest.comlwholesale/pcatli
s.html.Forecasting forms:
http://ww.qwest.com/wholesale/guide
s/forecastina.html
Page 2 of9
GS _ CLEC_ Checklist09-04-09.doc
Getting Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a Facility-Based CLEe Download
Qwest4
\JJholesa~e Markets
Initiating Interconnection Agreement Negotiations
Activities and Results Where to Obtain Information Timeframe. .::S-uggéšted-
CLEC Responsibilties:.Review awesls Negotiation Process flow .Step 3 in Getting Started as a Facilty-.Before
and evaluate your options for creating your Based CLEe:Negotiations
awest Interconnect Agreement.http://ww,Qwest.com/wholesale/clecs/
.Initiate contact with Qwst to begin clec index.html
Interconnection Agreement Negotiations.
Qwest Responsibilties:.Qwests Contrct Negotiations Administrator .Contact the Manager - Interconnection
assists you with initiating the Interconnection Agreements intagree(cgwest.com by
Agreement Negotiation process with Qwest.email, by telephone at 303-965-3029.
or fax at 303-965-3527.
Obtaining Sales Executive & Service Manager Contacts .
..,: ;-~!;-~~g:~;, :-:;A~~~~m~~t~,~.-~~:~:(~~,'::-'~. -_::~- -::/S~:/i¿::: ~ )l;.)::;:t:-:~~~t~::t~t~~.~;§fl~tlT~~t~; ~;i~j:;;~~~ ::::::::~~~~¡d.;::f:~~
CLEC Responsibilties:
· No action required.
Dwest Responsibilties:
· Sales Operations Manager requests Sales
Executive and Service Manager assignments
to establish your Qwest Account Team.
· Service Manager contacts you via telephone
or email to provide your contact information.
· Assigned Sales Executive and Service
Manager contacts can be obtained on
awest Wholesale Information Tool
(QWIT):http://ww.qwest.comlwholesale/ccdb
. Account Team:
http://ww.qwest.com/wholesale/clecs/
accountmanagers.html
. During
Negotiations
Page 3 of9
GS _ CLEC_ Checkllst09.049.doc
*'q;~.~c~..'
Getting Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a Facility-Based CLEe Download
WholesaJe Markets
Completing Your Customer Questionnaire
Qwest--
Where to Obtain Information Timeframe
Suggested
. .
':':;/:~':;:f~:::-::~-' :A~~.yit;f:.~ii~._'R~.L(tt:s
CLEC Responsibilties:
· Submit our "'Customer Questionnaire,
complete all sections required prior to placing
service orders. All subsequent sections must
be completed and submitted prior to
implementation or receiving contractually
required report.
"'A Customer Questionnaire required even if
your Interconnection Agreement is signed.
Qwest Responsibilties:
· Service Manager assists answering your
questionnaire questions and coordinating a
meeting if necessary.
· Service Manager obtains your Owest
assigned Facilty-Based CLEC Identifier
(ZCID) and provides your assignment to you.
· Servce Manager obtains and informs you of
your provisioning and billng center
assignments.
Required sections identified in the
Customer Questionnaire:
http://ww.gwest.comlwholesale/clecs/
newcustguestionnaire.html
. During
Negotiations
. When you
submit your
Customer
Questionnair
e
. Beforeyou
place your
initial order
If Qwest is your Operator Services / Directory
Assistance (OSIDA) Services provider:
CLEC Responsibilties:
· Dowload and complete our OSIDA
Questionnaire.
· Send your service Manager when your
OSIDA questionnaire is complete.
Qwest Responsibilities:
· Service Manager wil assist you with
completing your OS/DA questionnaire.
· When complete, Servce Manager forwrds
your questionnaire to Qwests OS/DA
Implementation Manger.
· OS/DA questionnaire can be found at:
http://w.gwest.comlwholesale/pcatlo
psserv.html
. 30-45 days
prior to
placing initial
order
Page4of9
GS CLEC Checldist09-4-09.doc
..~~--.:~~~'. .
Getting Started as a èLEC Checklist
Wholese Interconnection/Getting Started as a Facilty-Based CLEC Download
_/1
Qwest~~
Wholesale Markets
Defining Your Network Point of Interconnection (POI)
ActiV~P~_~~~::.~~s,,~!~~_-:,):;;;~:-:_;;:._:;;:.;.;_::~..--i;-::~:::_~_:::Where to. Obtain Information Timefi"ame
':?'~~~~~:?:;':..:~':":-:(~:'~' .:.-::~_: -::.- .... -": ":-:- ~'. -. . :.::. .: ..' .:-Suggested
CLEe Responsibilties:....
.Refer to your Interconnection Agreement to .Your Qwest Interconnect Agreement .6 months
determine your available POI options and before
establish a diagram of your proposed .LIS Product Catalog (PCAT):launch
network.To assist us in understanding your http://w.awest.comlwholesale/pcat/Ii
network, your diagram should include:s.html
-Method of interconnection .Collocation general information and-Local callng area and NXs ordering forms can be found at:-Your switch location(s) (ClLls)http://ww.gwest.comlwholesale/pcatlc-Qwest switch location(s) (CLLls)ollocation. html-Number and type of LIS trunks
-Trunking to Qwts Tandems/end-offices
-Ancilary Services (E911, Operator
Services, etcol
Establishing Your POI and LIS Trunking Site Activation Requirements
I;. -.'-:.;(;;~~i~;;;~;;:;;!;=;;~~J:~l~i;~~~i~i~~;~.~t~llf:Jla¡!:-¡I~:-11~g~t~;~~:.~~£~~~~~tlrm~~~~,:-::--:~;:~.,.'-::::J:iIlEtfrae :
.;: Suggested
"
CLEe Responsibilities:
.In preparation for our Site activation meeting .LIS:.After
provide your Service Manager the following:http://ww.awest.com/wholesale/pcat/li contract
-Netwrk diagram identifyng your Method s.html negotiations
of Interconnections such as:.Forecast:.Mid-Span Meet Point of POI http://ww.qwest.com/wholesale/guide.Colloction s/forecasting.html.Entrance Faciliy (OS3 or above).E911:
-Inital LIS forecast http://w.gwest.comlwhofesale/pcat/9
-E911 plan and trunk requirements 11.html
Joint Responsibilties:.Partcipate in LIS Site activation meeting to:
-Review your Network Diagram
-Verify initial LIS forecast and options for
Interconnection with LIS Project Manager
(LIS Project Manager will provide you a
project number when you are ready to
issue LIS Trunking orders.)
-Sales Executive answers price questions
-E911 Manager reviews plan and assists
with requirements
-State interconnect manager addresses
local netwrk Issues
-Service Manager coordinates post market
launch activities .
Meeting determines issues to address in
future meetings.
Page 50f9
GS_CLEC _ Checklist09-04-Q9.doc
)
.~,.
Getting Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a FaciHty~Based CLEC Download
QwestJ2
Wholesale Markets
Activities: and Results..-Where to Obtain: lnformatíon ", '.' ". ....:..Timeframe.-.
. .. ... ~ "")' ...:" ":;~Sugg'ested
If Owest is your Signaling System? (SS7)
connectivity provider:
CLEC Responsibilties:
· Contact your Service Manager to request a
meeting to discuss 557 requirements as
defined in your Interconnection Agreement.
· Issue A link and SS? facility orders after
preorder meeting.
Qwest Responsibilites:
· Service Manager facilitates preorder meeting
to discuss 55? connectivity and Link Data
Sheet requirements.
If Owest is your provider of these SS7 Database
servces:
- Line Information Data Base (LlDB) to
provide accurate biling for callng cards for
your end-users
- 800 Data Base Access Serice for 8XX toll~ .
free servce to originating end-users
- Ofer your end-users "caller ID and Name"
with InterNetwrk Calling Name Service
(ICNAM)
CLEC Responsibilties:
· Contact your Sales Executive for possible
Intercnnection Agreement Amendment.
· Contact your Service Manager to include SS?
database servce on Link Dat Sheet.
Qwest Responsibilties:
· Service Manager faciltates preorder meeting
to discuss Link Data Sheet requirements.
. SS7:
http://W.NW.gwest.comlwolesale/pcatlc
csacss7.html
. After site
activation
meeting
. L1DB:
http://w.gwest.com/wholesaleloct/i
db.html
BOO Data Base:
http://IN.gwest.com/wholesale/pcatlB
OO.html
. ICNAM:
http://IN.awest.comlwolesale/pcat/ic
nam.html
. After site
activation
meeting
Achieving E911 Interconnection Requirements
Page 6of9
GS CLEe Checldist09.04-09.doc
. ":~\t\~~~:~;'
~Getting Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a Facility-Based CLEC Download
Qwesc2
Wholesale Markets
Acti'¡iti~ 'à.iid: Results Where to Obtain Information Timeframe
..Suggéšb!d
CLEC Responsibilties:
· Provide E911 interconnection plan and trunk
requirements if not covered during Site
activation meeting.
· Prepare and submit E911 T1 trunk orders.
CLEC Responsibilties:
· Service Manager initiates Service Planning
meeting to review E911 interconnection
requirements, if necssary.
· Service Manager coordinates E911 message
trunk orders once your E911 T1 facilty is
ordered.
. E911:
httc:/Iww.awest.comlwolesaleJpcaV9
11.html
. During or
after site
activation
meeting
. E911 T1
trunks one
month prior
to market
launch
. E911
message
trunks after
ordering T1
trunks
Page 70f9
OS _ CLEe _ CheckJist09-04-9.doc
-~~l~¥..- :... ~.~__'h ~.,
Getting Started as a CLEC Checklist ---- ---,
Wholesale Interconnecion/Gettng Started as a Facility-Based CLEC Download
/r)
Qwest.~w
Wholesale Markets
Evaluating and Establishing OSS Connectivity-
:.0 _ ,. .:-.;:.4~.int~;,~i:t~#F~1~~t~o'~:-)~._;-~~:~.._ .;:0.;'_' .. .Whereto Obtain Information Timeframe
-'.'-.:':,::',Suggested.-.-.
CLEC Responsibilties:.,..........
.Evaluate access and tools to support your .Overview of Qwests Electronic Access .4 to 8 weeks
preorcer, ordering, repair, biling functions and Tools can be found at:prior to
with Qwest: (e.g., Interconnect Mediated http://ww.awest.com/wholesale/clecs/desired
Access (IMA GUI or Extensible Markup electronicaccess.html implementati
Language (XML), Customer Electronic on date to
Maintenance and Repair (CEMR), Directory establish
Listing Inquiry (DLlS) Fiber data report Tool,files.
etc)..Request specifics concerning establishing
dedicated access with Qwest from your .NOTE:
Service Manager.Connectivity
Qwest Responsibilities:for dedicated
.Service Manager obtains details on how to access
setup a Dedicated Access system-to-system requires
interface via dedicated electronic method.addition
time.Verify.Service Manager coordinates technical OSS requirementconnectivity setup meeting with you and our during setup
i IT Implementation & Deployment Team.meeting.
Accessing Qwest's Operations Support Tools
-t~;'~1t~il;~~.~~~iljfi¡1~~lij!j~;;tl~~tt~~~~ttt£~ ~:::~:;;.;~'~.t-;.~r:~j~reJ~~~sl~ig'::!1r~~j~~-~:H:-..;~~~:~.è,~ i:
:/Tlmeframe :-';d
'::)SU-gg~ted
CLEC Responsibilties:.Request access to Qwesttools completing .External User Access Reauestand IMA .4-6 weeks
and em ailing forms to System Administrator Setup forms at:prior to initial
wholesale.servlcesupporteam(ágwest.com http://ww.gwest.com/wholesale/clecs/order
with "Digitl Certificate"subject line:electronicaccess.html
-Dedicated access to IMA GUI or IMAXML.
Complete an IMA System Administrator
Setup Request form
-Digital Certifcate access to requested tools
Qwest Responsibilties:.Wholesale Systems Security Administrator
emails notifcation to you and your Service .Digital Certificate access information at:
Manager.htto:/Iw.gwest.comlwholesale/svste
ms/generalinfo.htmJ .30 days prior
to initial
order or on
request
Page 8 of9
GS GLEC Checklist09-04-09.doc
f:~~~.:'
Gettng Started as a CLEC Checklist
Wholesale Interconnection/Getting Started as a Facilty-Based ClEC Download
Qwese2.
Wholesale Markets
Participating in Change Management Process and Training Opportunities
.Activities á"ncl Results . Where too¡'Iäriî,Jnf.ormati'on Timeframe, .'.::." .~ :
.. . :..':' "-. ~ /~?~.:..:.::.~~::~~:::;.~t::.;,~;~.:.~~~l:tt¥&~~~~:~~..~~:..'...::.:.... :.' '..-.Suggested...,
CLEe Responsibilties:...---~..
.Paricipating in Qwests CMP (Change .Details on CMP can be found at:.As you
Management Process)http://ww.awest.comlwholesale/cmpli choose to
ndex.html participate
Qwests instructor-led, web-based and
downloadable training opportunities are .Select our course catalog at:.As youavailable to learn more about our product and http://w.awest.comlwholesale/trainin choose to
services, how to use our Operations Support 9 participate
Systems. and how to do business with us.
Joint Responsibilties:.Contact your Service Manager to request
training informatÎon that will assist you with
navigating our training web page.
Additional reference information is available at following web sites as desired:
External:
· Federal Communications Commission (FCC) http://ww.fcc.gov/
, Allance for Telecommunication Industr Solutions (ATIS) http://w.atis.org
of Teleordia - Exchange Carrier Code (ECC), local Exchange Routing Guide (LERG) (at 732-699-6700), Common
Language Location Identifer (CLU) http://w.telcordia.com
· National Emergency Number Associations (NENA) http://ww.NENAorg
· Number Portbilty Administration Center (NPAC) http://ww.NPAC.com
Internal Qwests Wholesale Interconnection:
· Wholesale Interconnection Products and Services http://ww.awest.comlwholesale/pctlndex.html
· Technical Publications http://w.qwest.comltechpub/
· Acces Service Ordering Guidelines (ASOG) - Access Service Requests (ASRs)
htto://ww.awest.comlwolesalelsvstems/asr.html
· Local Service Ordering Guidelines (LSOG) - Local Service Requests (LSRs)http://ww.gwest.comlwholesale/clecsllsog.html.
· Interconnect Mediated Access (IMA) User Guide http://w.Qwest.com/wholesalelima/gui/document.html
· Wholesale Customer Contacts http://ww.gwest.comlwholesale/clecs/customercontacts.html
· Escalation process http://w.awest.com/wholesale/clecs/exescover.html
Page 90f9
GS CLEC Checklîst09-04-09.doc
_._, .~:ot" .Venzoii Global Wholesalel Establish & Maitai Account for Local Serces Page 1 of2
Systems & M~asures. ~ ; Resources -
Verîci Globl Wholesale \ Doing Business
II
FAQs Contact Us
Establish & Maintain Account for Local Services
I Dong 8usiii
Local
Establish &
Maintn Account
Ordering
Welcome to Verlzon Wholesale Local Services. This setion covers information you need to know about Verlon
to begin doing business wfth Verion and maintain your accunt Information as your business changes andgraw. .
To establish a wholesale relationship wfth Verlon, you wil have to undersand state and federal regulatory
requirements and the tanff under whic you can purchase service from Verlzon. Next. you wil need to
negotiate an interconnection agreement with Verizon, make yourself familiar with and obtain the appropriate
Industry codes, and will nee to crate and maintain a Local Services Profie via the Customer Profile Self-
Service Tool (CPSSTl You wil need to establish connectivity and establish billng arrangements before being
able to submit transactns to Verizon. Local Serices Profie dala must be submitted prIor to requesting
connecivity. As your needs may change and business grows, returning to this site wil help ensure you are able
to maintin the accuracy of your account.
After finalizIng your agreement wih Verlon, you will need to begin Implementation of your network plans.
Depending on your network considerations, you may require accss to Poles, Conduits. Rights of Way and Joint
User Agreements, or want to apply for collocation arrements with Verlzon. Finally, we will requIre regular
forcasting input from you.
Provisioning
Trouble Admin
Biling
Once your relationship is established wih Verizon, other sections of the web site will help you conduct day-today
operaions with us.
RequiÆments
Regulatory and Verizon requirements define what
Information Is needed to do business with Venzon.
Lear more abo thes requirements and indust
cocl by accessing the selectlons below.
Regulatory Requirements
State Cerçaon and Tariff Information
Veron Requirements
Neaotiating an Agreement
Acount Securilv Reguirements
Industr Codes and Contacts
Customer Profile Sel-Servce Too (CPSSTl
Billng and Connectvity Options
Estblish System ConectIvity
Establish Billing Arrangement
Ke'l Network and Servces DecIsions
The information below will assist you in making
deCIsions about the network and services that may
need to be cared for to bein doing business in the
Verlzon Region.
Determ ining how and what facilites need to be
provided (by eHher Veron or another provider) is a
key driver to business deCisions that need to be
made to do business with Venzon. The steps that a
CLEC will take to interconnect to the Venzon
network depend heavily on the network facilIty
deCIsions made by the CLEC.
Network
Netwrk Faciltv Deisions !:
Netwrk Interconnecions ~
- FaCilities Based Inteconnections
Network Design Reuest Forms: _
M Verizon Operator Servics Questionnaire !)
- LATA Presence Reqyes Form - Nor !1
1I:'- LATA Presence Request Form - South;;
- LATA Presence Request form - west!3
- Une Class Code Provisioning Form '!
poles. ConduIts and RJghts of Way
CollocatIon
E911
ForecastIng
Forecasting Overview
New York Sold House and Riser Assets
http://ww22.verzon.comlwholesale/businesslocal/establisblomelO...00.html 1111812010
Veron Global Wholesalej Establish & MàU~~uñ1orllõèa Services Page 2 of2
Last Updated August 1998
A listing by general geographic srea in the State of
New York served by Verlzon that provides the
names of the original purchasers and the addresses
to whom Verizon - New York (formerly New York
Telephone) sold some or all of the Outide Plant
Cable assets catgorized in the accounting system
as House and Riser facilties.
To view, navigate, and prInt PDF flies. you need
Adobe Acrobat Reader.
Click here to download a free copy if you don't
already have it
You may have 10 adjust your printing preferences in
Acrobat Reader for the PDF file to print properly.
Bronx (38k pdffllel m
BrookiYn - Staten Island (54k pdf file) 11
Central Area (62k pdf fie) (includes Syracuse,
Binghamton Utica, Waerown) 11
Manhattn (63k pd filel 'I
Mid Hudson Area (5ak pdf file) (Includes
POUGhkeepsie, Montjçello. Kingston and Calskilll ~
Nassu (57k pdf file) m
Norteast Area (46k pd fie) (includes A1bai1
Schenecty, GleOS Falls and plattsburgh) .
Queens (3Sk pd IUel m
Sufolk (aSk pdf fie) m
WeSlhesterlPtnamlRockland 178k pdf lle) m
Western Area (64k pdf file) (Includes Buffalo. Olean)
om
Copyright 2009 Verlzon Privacy Policy
http://ww22.veron.com/wholesalelusiness/local/establishlomeI0..00.htm 11/18/2010
Verizon Global Wholesale I State Cerfication and Tarff Inormation Page 1 ofl
~
Vern Global Wholesale \ Doing Business \ Establish & Maintain Accunt
State Certification and Tariff Information
I Doing Businus
Local
Establish &Maintin Account
Ordering
ProvisiOning
Trouble Admin
Billng
Stae
Public Utiites CommissIon (PUC) approval is required from the state utility commission In the stale you want to
do business. This approval win include a Certificate of Operang Authority. A contact number for your state
Commission can be found in the local telephone directory or via the ~.
Federal
The Federal Communications CommissIon (FCC) may impose various requirements on CLEes with regard to
enforcement of the Telecommunications Act (Communications Act of 1934 as amended by the
Telecomunications Ac of 1996). Review the Federal tariffs to undersd the Regulations, Rates and Charges.
See Verizon Tariffs for State and Federal Tarif information.
Copyright 2009 Verl:in Priacy Policy
http://ww~2.verizon.coinholesaleJusiness/locallestablish!content/1"est_ maint_state _'" 11/1812010
12/1/2010
" ..~. ~ C L"~Hi.~ entury ink'"
Forms
Gettng'Startd
To becom a Faii Baaed or a Resell C1EC w ii !he C8nluryLi teitry. fOlow
these slaps: .
SIGp 1
Obin cert~ication from th I'bYc Ul Cormssio in !he Slales) w here you plan
to operai.
Slep2
Fí ou the Neiat Reest fan for lIe desir negtitins and e-mai it io the
Cl Accunt Neoi Tea
Slep 3
One CefJryUnk receies !he COle CLEC Neot Request form, you w II be
e- a CLEC Inleronnen Agnl lera a prin lisl for eah stae
reeste, and a tOO. day tell.
Step 4
'O part have signe lIe kieranaction Agreemt, an account manager
¡aslgned as YOU conta w lUin ceryLink for jrrmetaijon seices.
'r... aee Ihe Cusior Colect sectin of this sil for rre conlsct informatio.
Start-Up Forms
To establh bl~g accOlIl for Coele Li81 Eichanglt carrrs (Cl), the
foll in elht forms and/o documals mil be coleed and subir to
CeturyLln CL wil not be able to process any Acces Service Reuests (ASR)
or Local Sevice Requests (lS) un the doumets have been received,
apprved an processed by yo Sal Mager; and the deposit reuirem
fulild.
Required documentation:
l'e subrr co of you orinl of lIe follin two ii:
. I'bl Sere Coslon (llAblic U1ils Cossio (f\
CBrllcalin - a copy of th lel racelved from the appropriate state
coßl is reUÎed.
. Operating Cony Nurrer (OC - a coy of th noliictlon from !heNaal Eicfige Caier Asocltio (NE) is required. ir you have not
yel appfied for an OC you ma conla NE 81888-221-82.
RequIred forms:
Do nI th folo Jig for and email fim to your Sale Manager. Additonally,
proide hard caples of Ihose doculTnls têqulrg a sigature (i electrnic signature
is no availbl).
..---.-_._-- . ..._-_.--¡ Ham It I Descrption i
iã;;;';ii:;~~';; ! AuU;~e ce--i:; to pr~-:Thio-;m~-'l
i ~ J reDeve Ihe CL of securii en manlani end user iL---l cuto aulhaizall. . -...-.----..! Coliicale of I FTovid proof of Federal Bcise la exerrtin on II ~ i ConJtis Seres. !i~ ~~----~-.---------.~-.".-i
! . BI Me II Eslablsh biD mara preferences for Ù1oices andlor daify ,
sl/Oina usage fHes. The form Is also used fo bRiing address !r., ., i changes. i
¡-~-chect;;--t Reuied to sel up acls an obtai clËe-;~-;k;;; fro";--¡
~~~:._I_:~~~k;~d by U1~l~busn~;;'~fi~-;;h-;~
! iwr for ft~s- I! an ood-user contacts CelULlnk kltea of Ihe CLEe !i titcled BI !
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centuryLìnk Wholesle
Personal Business
CLEC issue Resoluti
Get answ ers to Fraguenll ASkeQuesliolU .
Wholesle About Us My Account
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12/1/2010 CenturyLink WholesaleUsers ,_..__~._.__..n.__.J._._~___._~.~""_____~..___R_M._______.____.;
CLJ:C Portin ¡ Required for each new ClEC Allo s for Itnly t
. ~ ¡ cOlltookeival of roadblocks on LNaclîalions.
¡ pog dels an af hors LNP escalaions. ,_.-~._.. ..._-. -.- \. -----....---.----.-.----....----1
":~ ! RequIred for each ne ClEe or existing GLEe thai w rshes iicast ' 10 becoi aellve in a new slate la provide a loal service ¡- i forEKasi. !l' - _. -- _. -.. _. _. ... .ojNe ar OUlage ! Du 10 pa repng. it is mandatory lIat all ClEC j
IIlCallaiver : coi eitr Ihe report reuesi or Ihe repor waiver !Outage j forll. :
-U;;;-Š;.;a--lRo--;;-;;:r;--ia and ~ï~;~ia-;' exe~-;'--i~ j Comnnication Services. !Ceale ¡ ¡- - ,_...-...--._-_.....~- ~------.....~----~_.._A._..._~_.w..___~.....n_____....
The following forms may be useful 10 you while purchuing services from
CenturyLlnk.
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! BlOiec tiooal i Use lits form to inllate th process 10 conver Recirocal ¡
; Triinklg Reuesl ! (RC12) and local (RC14) Ir 10 al-diecliol (AC t6) ¡i : trunks. I
tai~~~~-=l~!~~~~~~~~!~~~~~~~te~~=~=-~~.~=-~=I
: ~ ¡ E"teblh a new colocalion, augllnl a colocallon, or ¡i Appliation ¡ desÎO a coftcalln. !
rC;;;n-¡;~cl i Reii;';;b;;;-;;;-carr~~ d'-ee c-;;~:-'-_.'-¡! Cablig LOA I !;- - +--_.._._-- ----
I CS Rlouesi I Reiiest user D and pasword for access 10 CSPR ClEe ¡¡¡Peore Repor Ii'--~.~--~~.-'_...~n.~-~---_---.--------.-'-.-~l
i Ccl Form ¡ Requ 10 eslalish ne conacts, cIange exlslii i
! ¡ contats. SQIe type of nolificlios an report each ¡¡ ¡ colact is 10 rece fro CeryLink Notice. ¡..-.---.- --.----1I Qistome Serlte i ThIs for is used when see Cenlirylink customer i
i ~ i servic reords, and shoul only be used w hen records can ¡
i i no be oblane thouh th rnlera Requet Entr System '
! -.---_L.~i:.:_______._.___.___._____...._¡
~ I ThIs form Is reqund to inftiae the dark fiber app1lal I.iaI ¡ proc w it CeturyLinlc ii-~------¡'-'-'-" ---'-"--'---'.'---'--
i E'EAcc8Ss i Reques access Ie EASE Th syslem is used for ¡, ~ i prssing eltric loca8elvlce Reuets (LSR) and i
¡ ! Access Service Requests (ASRs). j1--_.__...--------_.__.._..__._._-_.._.._---1
i æ. Criera ! li addlU 10 th quaifylng sere critria, a ClEe mui i
I ~ ¡ procertcaon Ihatii salifies ih seretlibll L
i .b I crIteria for each ne or convered crcuilo oblaln EBs. I1-.__._.__._-----_.. . ._. ~
j Faclil ¡ Ried to gai acces to CøturyLink Propert. i! AccesJolo ID I i1-- .. . -, .-~-~....-.....-..----------i
; lirCOtion i Inilale discssions abul planned inerconneclion trunk I
! ~ I arrangemnt in ars w h..lhe GLee and CønlurUnk wil!¡ , exhane Iocallr. Ii-_____ !.---..----i
i lnoi i Reuired to. each Ponl of htconecllon (POO, All trunks i
I Truk Forecast i (lointrLA TA. reiprocal, htLA TA and Sll1) requird j
i i for each PO can be coiÌ1ed OI one forecast report. i
¡-Sliqon ! Request an Infomi Invesl/alln ;,to an issue. The 5eic;l
i Request Fom j Perfomi leagen~ wor Ihe cUstome i¡ I inestiatin wilfn 10 businss das or less. I1-. -...----____...
i Localller Request for por a lol tepho nun1er. !; Poiabily Bona !I Ade Reguesi I
!a.dReuesi + ~~ìi~~laa~~i-;~-;~=.. J
I 825 61ankt ¡ certifie lt a Special Access Seice purchased from i¡ ~ i cenlliryUnk Is no inerconnecte w ii loal exchange Ii ! servce. I
i Sceduled I Reesl scheduled malnlmaice. II Maintenance I ji~ ! I¡.--.----.......--.......------------.-.-..-..-.......----.-.----I
¡ Soeclal Accs ! establh. chane or exte a Specia Access Ftirer Term ¡;~ I DIount l'. i. unl' ¡ . i
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¡ SpecIal Acs i EslabUsh a Spcial Access Revenue Volume Di counl Aan. i, ReveVoI i iI Dicout Ran ¡ Ii ~ ¡ .._-_.... '--'''-~--1
¡ Special Access Eslabllsh. chage or exte a Special Access Term Oscounl ¡
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NÉCÃ.~
North American
Company Code
Assignment Procedures
I
060710
Pag i of ii
NECA
North American Company Code Assignment Procedures
1.0 Introduction
A Company Code is a unique four~ëharacter alphanumerc code that identifies providers
of telecommunications servce. The T1.251-2001 (second) stadard, Section 3.3, refers
to th code as an alphanumerc Company Code. The T1.251-2001 (second) designtes
NECA as the Matenance Agent of this code set.
Under the Tl.251 ~200 i (second) standard, NECA assigns Company Codes to
telecommuncations service providers for unque identication. The Company Code is
used in mechaned system thoughout the indus to facilitate the exchange of
inormtion. Applications of the Company Code may include, but are not limted to:
· NECA Tarff FCC No.4
· Routing and Ratig Puroses
· Indust recognzed guidelies includig Access Servce Requests (ASR),
Multiple Exchage Carrer Access Bil (MCAB), Small Exchage Carer
Access Biling (SECAB), Carer Access Billi System (CABS), Exchae
Message Interce (EMI) and Exchange Message Record (EMR).
· Interexchange Carer system used to audit Exchage Access bils.
· FCC Form 502 (North American Numberig Plan Numberig Resoure
Utiation/orecast Report.
Company Codes are used for the exchage of inormation among intecompany
and/or public use. Company Codes wil not be asigned for the exclusive use of
inter company operations.
2.0 Background
NECA became the source for the assignent of Company Codes in 1984 afer becomig
the taff fig agent and the admitrator of the revenue distnbution pools and the
admnistrtor of the wire center and interconnection database formerly operated by
AT&T.
Over the year the assignent of Company Codes has evolved to include, but is not
lited to: Incumbent Local Exchage Carers (!Ees), Facilities-based Competitive
Locl Exchage Carers (CLECs), Unbundled Local Exchage Carer (ULECs),
060710
Page 2 of i i
)
Competitive Access Providers (CAPs), Local Exchage ReseUers, Interexchange Carers
(lCs), IP-enabled servce Providers (IPES), Wirless and PCS entities.
All Incumbent Local Exchange Caers (member ofNECA) are requied to obtai a
Company Code and populate their wire center and interconnection data in TariffNoA. In
early 1996, upon receiving authoriation from the Federl Communications Commission
(FCC), NECA began to include Competitive Local Exchange Carrer (CLEC) data, at the
carrer' option, in Tari No.4 for a cost-based fee.
Ths cost.based fee also applies to NECA members to the extet they offer servce
outside of trditional sering tertories without obtaing a waiver from the FCC.
Carers needing a Company Code and/or those wishig to parcipate in the ta should
refer to the NECA website at ww.neca.org.
Disclaimer:
These gudelies ar developed in conjunction with industr bodies such as NRC and
OBF and are produced, published and distrbuted by NECA. The purpose of these
gudelies is to inorm the industr of the assignent procedures for obtag Company
Codes.
NECA reserves the right to revise or cancel ths document for any reason. includig but
not limted to, conformce with stadads promulgated by varous agencies.
technological changes or the reflection of chaes in the design of any equipment,
technques or procedur described or referr to herin or to conform with the rues and
orders of the Federal Communcations Commion (FCC) or other goverenta
authority.
3.0 Assignment Principles
3.1 StructureIormat
A Company Code is a unque four-charcter alphaumeric code (N
assignble to all telecommuncations service providers. For puroses of ths
document N=O-9 and X=O.9 or A-Z.
Company Codes are assigned at two levels: State! Area specific (See Section 3.3
below for more inormation) and Overall.
Company Codes ar assigned for eah tye of servce a company provides.
Separte and distinct codes are required for incum~ent local exchange carers,
facilities-based certed local exchange carrers, unbundled local exchange
carers, local exchage reseUers. competitive access providers, interexchange
carers. IP-enabled service providers, Wirless and PCS carers.
Companies offerig more than one tye of serice are required to obtai multiple
codes, regardless if a separate legal entity is created.
060710
Page 3 of II
3.2 Historical Assignment Procedures
Historically, prior to July 1, 1996, Company Codes were assigned unoffcially
from a specific series ofnumbers, based on the tye of service provided or the
nature of the entity, i.e. 5000 State Specifc codes for Regional Bell Operatig
Companes (RBOCSs), 9000 Overall codes for RBOCs, 6000 for Wirless
carers, etc.
In an effort to delay the eventual exhustion of al numerc (N Company
Codes and avoid going to alphanumerc codes for as long as possible, NECA (as
Maitenance Agent) began tritionig away from th unoffcial designation in
June of 1996. As a result, companes were assigned codes from any senes of
numbers regardless of natue of entity or service provided.
Notification of ths change was made in mid-1996 to the Data Integrty Group
(DIG) - now referred to as the Netork Ratig & Routig Inormtion
Commttee (NC) -, to the Industr Carer Compatibilty Forn (no longer in
exience, as of Janua 1997) and to the Orderig and Bilg Foru.
Re-elaied Company codes wil not be re-used. (see Section 6.0)
3.3 Assignment Requiements
As a general rue, Company Code assignents may be needed as a result of
mergers/acquisitions or other lega tranaction, e.g formtion of new company
3.3.1 Incumbent LEe codes - The Incumbent Company Code Requet form
ca be located on the NECA website:
htts:/lww .neca.org!cms400miCA TemplatesIusinessSolutionsInteror.aspx?id= 1947
To obta a Company Code, the followig inormation must be forwarded
to your NECA Member Service Mager:
· Merger/Acquisition Agreement or a legal description of the
tranaction
· Letter signed by the offcer of each exchange carer stating the
effective date of the transaction and requesting that NECA amend
its record to reflect the trnsaction
· State Commssion Approval (if required)
· FCC Approval (if requied)
060710
Page40fll
· TarNoA Wir Center Inormtion (Name of exchanges, eLLI
Code, nae of individua who will have update authority)
· Number of Access Lines
· Statement concerng the intent to parcipate in NECA's pools
(Traffc Sensitive, Common Line and End User)
· Arcles ofIncorporation
· Company Strtue (EC commonly contrlled, afliated with
another EC or an independent)
· Issu Carrer Contact Inormtion (TarffNoA and Tarff No.5)
· Signed letter, on company stationery, requestg tht NECA
assign a new and/or expires existig company codes
NECA requir a mium 60-day notice of a trsaction and a mimum
of 30 days, following receipt of all approved documents, before a
traction wi be refleced in the ta (Tarff NO.4 and Tar No.5).
Company Code assignents wil not become effective until all conditions
of the sae/formtion of a new company are fialized and NECA received
conftion frm al parcipants.
3.3.2 Non ILEC codes .(CLEC, ULEC, CAP,IC, IPES, Resellers Wireless
and PCS) - The following inormtion is requied to obtai a Company
Code assignent:
· Company Code Onle Request at
htts:/lwww.neca.orii/cms400min/ECA T emplatesIusinessSolutionsInterior.aspx?id= 194 7
· Legal documentation (e.g. Aricles of Incorporation, State
Registration, etc) as proof of existece and to reflect the
telecommuncations servce provider's legal nae
AN
· For CLEC, ULEC, Competitive Access Provider and Local
Reseller servce - a copy of the certifcation by the state Public
Utities Commssion
· For Interexchange Carer - Documents may var from state to
state. A copy of the state Public Utilties Commssion's approval
is requied when the state commssion regulates the interexchange
060710
Pag 5 of 11
.~~rq
carrer/resel1er serce. If the serice is not regulated by the state
commssion, the requied document may var. Therefore, pleae
contact the Company Code Admstrator at ccfeesØlneca.org or
973w884-8249.
· For IPES service - proof of servce and customer, e.g.,
interconnection agrements (or evidence of an interconnection
order pursuat to an approved taff and contrctul agreements
with end-used customer or reguatory adstration approval, if
applicable
· For Wireless or PCS service - a copy of the company's FCC
radiolPCS license
· For Wireless and PCS ReseUers - a copy of the interconnection
agrement with the wireless carer
CLEC and ULEC codes are assigned by state. Codes for CAP, iC,
IPES, Local Reseller, Wireless and PeS serices are assigned on a
national basis.
Standar code requests wil be processed withn ten (l0) business days
of receipt of requied documents and/or payment (ifby check).
Exprss code requests wil be processed with the (3) business days
of receipt of requird documents and/or payment (ifby check).
3.3.3 State/Area specic and Overall Company Code Assignments
At the request of the Orderig and Billing Foru (OBF), state specific
Company Codes became mandatory in 1987.
For those entities that parcipate in NECA's Tarff No.4, Company Code
assignents are made based upon company operations. RBOC, ILEC,
CLEC and ULEC companes operatig in multiple states are assigned an
Overl Company Code as well as a unque Company Code for each state.
Company Codes for NECA non-member companies parcipatig in Tan
No.4 are also assigned based on company operations. However, based on
legal entity status, state and/or area specific codes may be assigned. For
instace, a company may have different legal entities in several part of
one state. However, these codes may all be "tied" to one "company
name" i.e., ABC Tel (Overall) is legally incorporated as ABC Tel of San
Francisco (area specific) and ABC Tel of San Diego (area specific).
Overall Company Codes unquely identify each legally incorporated
operating entity or official company namè that other legal entities might
060710
Page 6 of Ii
be associated with (see above paragrph). A state/area specific company
code is a unque code assigned for each statearea in which the company
operates. For companies tht first operate in a single state and then
expand operations to other states/areas, an Overa and additional state
specifc Company Codes wil be assigned.
The Overall Company Code wil be assigned automatically with the
second state specific Company Code. There is no fee associated with the
assignent of an Overall code.
For companes parcipatig in TarffNoA, all data must be listed with the
ASEC/state specif Company Code. No data ca be associated with the
Overall code.
3.3.4 Assignent of a New Category
In the event that an applican determes tht the tye of serce prvided
does not fit under an existi category, the applicat may access the New
Company Code Category Request form at:
htts://ww.neca.org/cms400mCA TemplateslusinessSolutionsInteror.aspx?id= 1947
Criteria for reuestig a new company code category mid the process for
submittg the request ar provided on the form.
060710
Page 7 of II
.0.0_''".._;
3.4 Fees for Company Code Assignment
Effective July 1, 2003: The fee for the assignment of a Company Code is $250
per code (stdad processing) and $400 per code (express processin). Ths fee
applies to al companies tht request a new code.
Payment must accompany each request for a new code assignent and must be
submitted vi a credit ca payment through the onle process or by
check/money order made payable to "NECA" and sent to Mellon Bank. The
nae of the company that is requestig the code should be noted on the reference
or memo lie of the check/money order.
Invoices are not issued for Company Code requests.
4.0 ResponsibiJties of Company Code ApplicantlHolder
4.1 The Company Code applicant/older shall adhere to the followi gudelies
when requestig a Company Code. Ths includes followig assignent
proedes such as usi the online reuest form and providin al necessar
suport document in an accurte, complete and tiely maner.
4.2 It is the reponsibility of the Company Code applicant to review the need for a
Company Code and to determe if the company aleady has a Company Code
assigned tht could be used for the identied need. If a new Company Code is
reuied. the Company Code applicant must complete the onle application form
and supply NECA with the requied docuentation.
4.3 The Company Code holder is responsible for providing NECA with information
relative to updatig the data supportg the origial assignment. Tlis includes
chanes in the contact information and/or company name chages. Requests to
updte the contact and corporate information must be made on the company's
letterlead and to include a hadwrtten signatue.
4.4 UpdatelModication of Existing Company Codes
4.4.1 Name Change
In the event of a name change of th legal entity assigned to the Company
Code, the Company Code holder must noti NECA in wrting of the
change. A signed letter, on company letterhead, requesting the nae
change must be submitted to NEeA, along with supportg legal
documentation, i.e. Amended Aricles of Incorporation, Articles of
merger, Purchase Agreement.
06010
PaeS of!!
'-~~~...'
4.4.2 Mergers
In the event of a merger of two or more exig legal entities (with the
name of one retaed), the suvig legal entity must noti NEeA in
wntig of the merger. A signed letter, on company letterhead, must be
submitted along with supportg legal documentation, i.e. Aricles of
Merger, Puchase Agreement. ~;-..
In the event that the survving legal entity does not have a previously
assigned Company Code but a Company Code is assigned to the non-
survvi legal entity. the code assigned to the non-surving legal entity
wi be used and updated with the new legal entity name.
In the event tht the surving legal entity does not have a previously
assigned company code but multiple codes had been assiged to the non-
survi entity. the survor will determe if a new Company Code is
required of if an existing code should be updated with the name of the
survivin legal entity. .
In the event tht the survig legal entity does have a previously assigned
Company Code. the code wi contiue to be assigned to the survivig
legal entity.
If the meger of two or more legal entities result in signficant new bilg
argements, a new Compaiy Code should be assigned.
4.5 Expansion of coverage area or service offered
In the event tht a legal entity expands its coverge area or serces offer
beyond the lits of previously assigned Company Codes. new code(s) should be
reqested though the onle system.
4.6 Bankrptcies
In the event tht banptcy-related proceedigs have an impact on previously
assigned codes, NECA should be notied by the company/companies involved. A
siged request on company letterhead along with supporting legal documentation
should be forwrded to NECA to have necessar chaes mae.
4.7 Reassinment of Company Codes
Preously assigned Company Codes tht are no longer being used and have been
designated as expired wi not be reassigned unless required to prevent code
exhaution.
060710
Page90tll
5.0 Responsibilties of Company Code Administrator
· Provide an industi procedure (these Company Code Assignent Prcedurs) for
obtain new and modifg exitig Company Codes
· Track the receipt of requests for Company Codes ...~..-.
· Make assignents on a first-come, firt~serve basis
· Process the request as follows, upon receipt of the required documentation
accompanying the request (see Section 3.3 above)
· Assign the next available Company Code(s) in accordace with the Company
Code asignment priciples
· Determe if requests for specific Company Codes are in compliance with
Company Code assignent priciples (see Section 3.0 above)
· Resond to the requestor with te (10) business days of receipt of the request,
either by providing the assigned Company Code( s) or by requestig more
infonntion
· Develop, maintain and publish a listin of Company Codes and their offcialy
charered names
· Provide servces and maters under reasonable and non-discritory term
· Notify the developer of the stadad at least two (2) year pnor to any anticipated
exhust of the Company Code sets.
6.0 Company Code ConservationIeclamation
Assignent of Company Codes (either numenc or alphaumenc) is undertaken with the
following objectives:
· To efficiently and effectively admister/mange a limted resource thugh
Company Code conservation
· To delay the eventual exhustion of Company Codes which would requie the
development and implementation of a new Company Code numberig assignent
format
The Company Code Adminstrator wil trck an monitor Company Code Assignents.
Ongoin practices which foster conservation may include the followig conducti
060710
Page 10 or II
periodic audits of Company Codes asigned to verify their use is consistent with these
procedures.
In the periodic audits, the Admnistrator wil expect to review at least the following
information to demonstrte tht the Company Codes are being used properly:
· Assue that the assignent requirements in Section 3.3 are being adhered to
· Assur tht the Company Code holder's responsibilties in Section 4.0 ar being
adhered to
Audit results may be used to accomplish the following:
· Identi and recommend specifc correctve actions that may be necessar, e.g.,
modifcation to the Company Code assignent procedures
· Reclation of Company Codes no longer in use (see Section3.2)
7.0 Maitenance of Guidelies
It may be necessar to review and modif these Company Code Assignent Procedures
perodcally to meet changing cirumstas. At a mjnimnm~ a yearly review should be
done by NECA. The right to chage inormtion contaed with these procedur is the
responsibilty ofNECA.
060710
Page 11 of 11
STATE OF IOWA
DEPARTMENT OF COMMERCE
UTILITIES BOARD
INRE:
DOCKET NO. TCU-02-1
INTRADO COMMUNICATIONS INC.
ORDER DENYING APPLICATION FOR CERTIFICATE
(WITHOUT PREJUDICE)
(Issued March 15, 2002)
On January 8. 2002, lntrado Communications Inc. (ICI), filed with the Utilities
Board (Soard) an application for a certificate of public convenience and necessity,
pursuant to Iowa Code § 476.29(1) (2001). The Board identified ICI's application as
Docket No. TCU-02-1.
iei requests a certificate in order to provide intrastate local exchange
telecommunications services on a statewide basis. However, iei's specific proposal
at this time relates only to aggregation and transportation of emergency calls using its
"9-1-1 SafetyNet" services in Iowa. (Application, page 1.) iei does not intend to
provide local dial tone exchange services or long-distance toll (interexchange)
services in Iowa. (Application, page 6.) iei requests a certificate in order to obtain
interconnection and collocation agreements with other local exchange service
providers. (Application, page 1.)
Pursuant to § 476.29, "a utilty must have a certificate of public convenience
and necessity issued by the board before furnishing land-line local telephone service
DOCKET NO. TCU.02-1
PAGE 2
in this state." For purposes of § 476.29, a lfutility" is defined as lfany person. . .
furnishing communications services to the public for compensation," ~ § 476.1.
Based on the information in iei's application, the services ICI proposes to offer
do not appear to be the type of service intended to be regulated under chapter 476:
ieI's proposed offering does not amount to (or substitute for) regular dial-tone
services, the traditional focus of the Board's telecommunications regulation.
Therefore. based upon the information in iei's application, the Board finds that ICI is
not proposing to offer services that would cause it to be a "utility" for purposes of
§ 476.29. Accordingly. the Board wil deny the application, without prejudice to
re-filng if iei proposes in the future to furnish services regulated by the Board.
In order to provide its proposed 9-1-1 SafetyNetSM services, iei states that it
requires interconnection and collocation agreements with other local exchange
servce providers. (Application, page 1). While iei's proposed services do not qualify
for certification under the Board's rules, based on the information in ICI's application,
ICI appears to be a lftelecommunications carrier" as defined in 47 u.s.e. § 153(44),
and, therefore, entitled to all rights enjoyed by telecommunicaüons carriers under 47
u.s.e. § 251. On this basis, iei may enter into interconnection, collocation, and
resale agreements with LECs pursuant to 47 u.s.e. § 251, and the Board's denial of
iei's application should not adversely affect iei's abilty to do so.
DOCKET NO. TCU-02-1
PAGE 3
Because ICI Îs a telecommunications carrier under the federal statute, it is also
necessary that ICI register with the Board pursuant to 199 lAC 22.23(3). ICI should
do so before providing its proposed services in Iowa.
IT IS THEREFORE ORDERED:
The application for certficate of public convenience and necessity filed on
January 8,2002, by Intrado Communications Inc. and identified as Docket
No. TCU-02-1 is denied, without prejudice.
UTILITIES BOARD
lsI Diane Munns
ATTEST:
lsI Mark O. Lambert
lsi Judi K. Cooper
Executive Secretary
Dated at Des Moines, Iowa, this 15th day of March, 2002.
lsI Elliott Smith o
STATE OF IOWA
DEPARTMENT OF COMMERCE
UTILITIES BOARD
IN RE:
LEVEL 3 COMMUNICATIONS. LLC
DOCKET NO. TF-05-31
(TCU-99-1)
ORDER IN LIEU OF CERTIFICATE
(Issued June 20, 2005)
On April 26, 2005, Level 3 Communications, LLC (Level 3), flied with the
Utilities Board (Board) a request for reconsideration of the Board's "Order Rejecting
Tariff and Denying Certificate" issued April 7, 2005, In the April 7 order, the Board
rejected Level 3's proposed tariff without prejudice and denied Level 3's application
for a certficate of public convenience and necessity, also without prejudice.
In support of its request for reconsideration, Level 3 states that its proposed
service, for which a tariff was filed, is appropriately a retail service and that the Board
relied upon a narrow reading of the term "to the public" when determining that Level
3's provision of wholesale services to other retail providers did not appear to amount
to sufficient sales to the public so as to "clothe the operation with a public interest."
Level 3 also states that the Board should have provided Level 3 with alternative
language in its April 7 order that provIded Level 3 with protections equal to those
provided by a certificate.
On May 13, 2005, the Board granted Level 3's request for reconsideration in
order to explore Level 3's request for alternative language. Based on the record as
DOCKET NO. TF.05-31 (TCU-99-1)
PAGE 2
of that date, it appeared Level 3's proposed service offerings would be unlike most
certificated telecommunications carrers in Iowa, as Level 3 does not intend to
provide retail local exchange service directly to end-use customers. However, the
Board indicated that this difference did not necessarily mean that an alternative
approach is unavailable or undesirable.
Accordingly, the Board scheduled a technical conference between Board staff,
Level 3, and the Consumer Advocate Division of the Department of Justice
(Consumer Advocate) on May 17, 2005, to discuss the nature of Level 3's proposed
se.rvice offering, the public interest, and possible alternative language. The technical
conference was open to the public and the discussions held at the conference are
summarized in the following paragraphs.
Level 3 seeks to provide various products, services, and facilities in Iowa in
order to faciltate the provision of voice telephony services by way of Voice-over
Internet Protocol (VoIP). The Board rejected Level 3's proposed tariff for these
services pursuant to Iowa Code § 476.29, which provides that "a utility must have a
certificate of public convenience and necessity issued by the board before furnishing
land-line local telephone service in this state." For purposes of § 476.29, a "utilty" is
defined as Nany person. . . furnishing communications services to the public for
compensation," see § 476.1. Based on the information in Level 3's application. the
Board concluded that the. services Level 3 proposes to offer do not appear to be the
type of service intended to be regulated under a § 476.29(1) certificate.
DOCKET NO. TFM05-31 (TCU-99-1)
PAGE 3
In Level 3'g motion for reconsideration, it asserted three alternatives for
reconsideration which were more fully developed in the motion but which are
summarized here: (1) that the Board should provide a more expansive reading to the
phrase "to the public" that would permit Level 3 a traditional certificate; (2) that Iowa
Code § 478.29(2) provides a safety valve that allows certification of non-standard
carriers; or (3) if the Board denies Level 3 a certificate, it should issue such a denial
with language like that in the Board's prior Intrado order,1 ensuring that the absence
of a certficate does not create unintended barriers to entry such as the inabilty to
obtain numbering resources or interconnection.
On May 13, 2005 the Board granted Level31s motion for reconsideration,
saying that "(bJased on the record to date, it appears Level 3's proposed service
offerings are unlike most certficated telecommunications carriers in Iowa, as Level 3
does not intend to provide retailloeal exchange service directly to end-use
customers.02 As the Board also stated in that order, however, "this does not
necessarily mean that an alternative approach is unavailable or undesirable."
At the technical conference, various alternatives were discussed. The most
promising of these is the idea that the Board modify its order denying Level 3's
1 In re: Intrado Communications fnc., Docket No. TCU-02-1 (Mar. 15,2002) (denying certficate but
ensu~ing Intrado the benefit of all rights under 47 U.S.C. § 251).2 In fe: level 3 Communicatlons. lLC, "Order Granting Reconsideration and Setting Technical
Conferenc," Docket No. TF-05-31 (TCU-99-1) (My 13, 2005).
DOCKET NO. TF-05-31 (TCU-99-1)
PAGE 4
certificate to include language modeled after the Board's order in the lntrado case,
granting Level 3 the emoluments of a certifcate in lieu of the certificate itself.
Based on the discussion at the technical conference, the Board concludes that
the approach taken in Intrado is consistent with the General Assembly's intent in
Iowa Code § 476.95, which requires that the Board exercise regulatory flexibilty in a
changing communications environment. This approach allows the Board to ensure
Iowa is not denied the benefits of innovative approaches, while taking a careful,
individualized look at each such set of facts and tailoring relief so as to ensure
consumers and the public interest are protected. It upholds the Board's precedent as
to the requirements for an actual certificate of public convenience and necessity,
while ensuring the absence of a certificate does not keep new providers out of the
market.
The Board has denied certificates to carriers like Level 3 and Intrado because
§ 476.29 does not contemplate issuance of a certificate for wholesale
telecommunications service. The public purposes served by issuing a certificate to
a carrier, however, may not be limited to retail services. Generally speaking,
certificates are useful because they:
(a) identify carriers offering landMline local service in Iowa and the
appropriate contact points for those carriers for purposes of service and other
communications;
DOCKET NO. TF-05-31 (TCU-99-1)
PAGE 5
(b) define the service territory in which land-line local telephone service
is offered, which allows the Board to "assure that all territory in the state is
served by a local exchange utilty" (§ 476.29(11)) and defines the utility's
"obligation to serve all eligible customers within the utilty's service territory"
(§476.29(5)); and
(c) give the carriers the crear authority to obtain telephone numbering
resources for use in providing local service in defined geographic areas.
In this settng, in which Level 3 proposes to offer wholesale services to carriers that
may not be required to obtain a certificate pursuant to § 476.29, it appears that
issuing an equivalent authorization to Level 3 wil benefi the public interest by
serving the same general functions as a certificate does for a retail service provider.
This question was examined in greater detail at the technical conference.
Part of that examination included the capabilties of Level 3'$ network as
compared to the capabilties that a retail service provider is required to offer. To this
end, the-Board notes that at the technical conference Level 3 stipulated that its
network is fully capable of number porting and pooling, that it is capable of providing
911 and E911 functionaliy subject to limitations based on the mobilty of the end-
user's VolP-enabled customer premise equJpment, that it wil cooperate with the
Board in resolving consumer complaints involving entities for whom Level 3 is
facilitating the provision of telecommunications services, and that Level 3 will not use
telephone numbering resources obtained pursuant to this order to provide dial-up
)
)
DOCKET NO. TFM05-31 (TCUM99-1)
PAGE 6
ISP-bound non-voice traffc using a Virtual NXX architecture until such time as this
Board, the Federal Communications Commission, or any court of competent
jurisdiction in Iowa issues a final ruling, no longer subject to appeal. that such use of
numbers is permitted.
Based on these representations, the Board's own investigation, and the
discussion at the technical conference. the Board finds it in the public interest to
provide a means for Level 3 to provide its requested services in Iowa. While the
Board finds Level 3's proposed services do not qualify for certifcation under
§ 476.29, Level 3 appears to be situated similarly to Intrado and should be authorized
to obtain telephone numbering resources in its own name for use in providing the
services it has described in its proposed tariff. Thus. both as a right enjoyed undèr
section 251 and pursuant to the "safety valve" provisions in 47 C.F.R. § 52. 15(g)(4),
the Board states that this Order entitles Level 3 to numbering resource upon proper
application to the North American Numbering Plan Administrator.
Thus, based on the record in this proceeding, including the information
gathered at the May 17, 2005. technical conference, the Board tentatively concludes
that it should affrm its decision to deny Level 3's application for a cerffte;-hit--- .- - - - -
the same time the Board should issue Level 3 an order in lieu of certificate that will
allo.w Level 3 all of the same rights, privileges, and obligations that are associated
with possession of a certificate. Moreover. because the Board is not issuing an
actual certificate to Level 3, the Board wil not approve Level 3's proposed tariff, but it
DOCKET NO. TF-05-31 (TCU-99-1)
PAGE?
wil accept the fiing on an informational basis as a description of Level 3's proposed
telecommunications service offerings in Iowa. Level 3 wil be expected to maintain
the tariff in an upMto-date status, even though it is only informational, because it is
worthless if it is not accurate.
The Board is describing this as a tentative conclusion because of the
somewhat unusual procedures used in this dock~t. It is possible that Level 3 or
Consumer Advocate may object to the terms and conditions of this order.
Accordingly, the Board wil delay the effectiveness of this decision to allow the parties
ten days to file objections.
Finally, the Board takes note of the fact that while this matter has been
pending, at least one other company has filed an application for certificate and
proposed tariff describing services that appear to be similar to Level 3's proposed
offering. Thus, it is possible that the new approach to certification represented by this
order may become more common. It is also possible that the Board, having gained
experience wit this new approach, wil conclude it is not really in the public interest.
In either event. or for any other appropriate reason, the Board may commence a rule
making proceeding to consider adopting rules of general application for
telecommunications utilties that offer wholesale services. If so, the action the Board
is taking in this docket will be subject to any and all such future rules.
DOCKET NO. TF-05-31 (TCU-99-1)
PAGE 8
IT IS THEREFORE ORDERED:
1. The Board's denial of Level 3 Communications, LLC's application for a
certificate of public necessity and convenience is affrmed, but is modified as stated
herein to ensure that this order in lieu of a certficate provides Level 3 with all of the
rights. privileges. and obligations associated with a certificate of public convenience
and necessity issued pursuant to Iowa Code § 476.29, all subject to complaint,
investigation, and any rules the Board may adopt in the future.
2. The effective date of this order is delayed by ten days to allow the
parties to this proceeding an opportunity to file objections to this order. If no
objections are filed, then this order shall become effective without furter action of the
Board. If objections are filed, the effecive date of this order shall continue to be
delayed pending further order of the Board.
UTILITIES BOARD
/sl John R. Norris
ATTEST:
151 Diane Munns
151 Judi K. Cooper
Executive Secretary
Dated at Des Moines, Iowa, this 20th day of June, 2005.
lsI Elliott Smith
STATE OF IOWA
DEPARTMENT OF COMMERCE
UTILITIES BOARD
IN RE:
MOMENTUM TELECOM, INC.
DOCKET NO. TCU-Q8-7
ORDER IN LIEU OF CERTIFICATE
(Issued July 2S, 2008)
On May 15,2008, Momentum Telecom, Inc. (Momentum), filed with the
Utilities Board (Board) an application for an order in lieu of a certificate of public
convenience and necessity. In support of its application, Momentum states that it
proposes to offer switching and interconnection services to cable providers or other
wholesale customers. Momentum states that it intends to utilize an order in lieu of
certficate to interconnect with incumbent local exchange carriers (ILECs) and that
Momentum's wholesale customers would then offer competiive voice services to
their retail consumers in the ILECs' service territories. Momentum also states that it
intends to use an order in lieu of certificate to obtain telephone numbering resources
from the North American Numbering Plan Administrator (NANPA).
Momentum requests an order from the Board in lieu of a certificate similar to
orders issued to Level 3 Communications, LLC (Level 3), on June 20, 200S, in
TF-05-31, and to Sprint Communications Company L.P. (Sprint) on March 3, 2006, in
Docket No. SPU-QS-21. The Board notes that the issuance of such an order would
provide Momentum with essentially all of the rights and privileges of a certificate
l\
DOCKET NO. TCUM08-7
PAGE 2
holder, other than authorization to offer land-line local telephone service in Iowa.
Momentum's application has been identified as Docket No. TCU-08-7 and no
objections to the application have been received.
The Board has reviewed the application and supportng information filed by
Momentum and finds that the wholesale business plan described therein is similar to
that of Level 3 and Sprint. The Board recognizes that for a telecommunications
provider to obtain telephone numbering resources from the NANPA, the rules of the
Federal Communications Commission req!Jire that such a carrer be authorized to
provide service in the state where the carrier seeks numbering resources. 1 The
Board finds that Momentum appears to be situated similarly to Sprint and Level 3 and
should be autorized to exercise interconnection rights under 47 U.S.C. § 251 and to
obtain telephone numbering resources in its own name for use in providing the
services it has described in its application. Therefore, the Board wil grant the
request and issue this order in lieu of a certificate. The Board finds this action is
consistent with the General Assembly's intent as expressed in Iowa Code § 476.95,
which requires that the Board exercise regulatory flexibilty in a changing
telecommunications environment.
IT IS THEREFORE ORDERED:
The Board wil grant the request filed by Momentum Telecom, Inc., and issue
this order in lieu of a certificate to provide Momentum Telecom, Inc., with suffcient
rights, privileges, and obligations associated with a certificate of public convenience
it\1 See 47 C.F.R. § 52.15(g)(2)(i).
DOCKET NO. TCU-08-7
PAGE 3
and necessity issued pursuant to Iowa Code § 476.29 and 47 U.S.C. § 251 to enable
Momentum to provide wholesale services as proposed in its application filed May 15,
2008, all subject to complaint, investigation, and any rules the Board may adopt in
the future.
UTILITIES BOARD
lsI John R. Norrs
ATTEST:
lsI Krista K. Tanner
fi
lsI Margaret Munson
Executive Secretary, Deputy
Dated at Des Moines, Iowa, this 25th day of July, 2008.
lsI Darrell Hanson
J