20031112Qwest Batch Hot Cut Proposal.pdf

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Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
'1nt11 MNl F~i 2: 20LiJU" \,u.
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Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case. No. GNR-03-
QWEST CORPORATION'S BATCH HOT
CUT PROPOSAL
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
Pursuant to Order No. 29375 , Qwest Corporation ("Qwest") respectfully submits
this proposal for a region-wide batch loop conversion process. Qwest proposes a single
centrally coordinated ordering and conversion process that would be used in all fourteen
of its states whenever a CLEC has the requisite number of qualified lines to convert from
Qwest's circuit switch (both Qwest retail and CLEC UNE-P lines) to the CLEC's circuit
switch. The same process could also be used to convert lines from one CLEC's circuit
QWEST CORPORATION'S BATCH HOT CUT PROPOSAL - Page 1
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switch. The same process could also be used to convert lines from one CLEC's circuit
switch to another s to the extent that sufficient volumes existed to justify use of the batch
process.
Qwest's proposal builds on, and makes improvements to, a process for
provisioning unbundled loops that already operate at a demonstrably high level
performance. As discussed below, Qwest's current process does not suffer from many of
the cost and operational problems that the Triennial Review Order
1 identified; Qwest
does not have problems with excessive provisioning delays or service outages;2 and
Qwest does not levy huge non-recurring charges to perform a hot cut3 Moreover, unlike
some other incumbent LECs 4 Qwest actually does have substantial experience migrating
large batches of CLEC lines including thousands in 2003 for one CLEC alone from
UNE-P to stand-alone unbundled loops on a project-managed basis.These batch
conversions are reflected in Qwest's current performance data , and establish that Qwest
has continued to provide these loops to the CLEC at an extraordinarily high level of
quality.
Even with this strong performance, in the two and a half months since the
Triennial Review Order release, Qwest has worked hard to improve this process even
further. Qwest has re-examined every step of its current loop-conversion process to find
Report and Order Review of the Section 251 Unbundling Obligation of Incumbent Local
Exchange Carriers CC Dkt. No. 01-338, FCC 03-36 (reI. Aug. 21 , 2003) Triennial Review Order
TRO"
Compare TRO ~ 466 with infra at section I(B) (discussion of Qwest provisioning and outage data).
Compare TRO ~ 470 with infra at section II(D) (discussion of Qwest's current NRCs).
See TRO ~ 474 & n.1466 (fmding that Verizon s procedures for performing project-managed
migrations "not sufficiently developed" and noting Verizon s failure to provide any performance data
reflecting these project-managed cuts).
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the efficiencies that become available when a CLEC works with Qwest to convert
twenty-five lines or more in a single batch.Qwest has also used its experience
performing large-scale project-managed conversions to identify the steps that can be
streamlined or eliminated when the carriers are migrating batches of in-service loops.
Qwest's work has paid off: The batch conversion process that Qwest proposes reduces
substantially the work times associated with some of the steps within the process, the
number of times Qwest has to contact the CLEC, and the process of clearing the order
once the work has been completed. While Qwest has not yet completed its detailed cost
studies, it appears that in virtually every instance these efficiencies will reduce Qwest's
cost of performing a batch hot cut.
Qwest first provides a brief background summarizing the FCC's instructions to
the state commissions concerning adoption of a new batch conversion process, as well as
the loop-conversion process that Qwest is currently using.Qwest then presents its
proposal for a new batch process.
BACKGROUND
The Triennial Review Order and the FCC's Imvlementine Rules.
In the Triennial Review Order the FCC determined that "in the large
majority of locations" (though not all),5 the incumbent LECs' existing processes for
migrating in-service loops one at a time from their own switches to their competitors
would "serve as barriers to competitive entry in the absence of unbundled switching" for
mass-market customers.6 The FCC found that the incumbents' current one-at-a-time
conversIOns, as a general matter, imposed non-trivial one-time costs and service
TRO~ 473.
TRO~ 460.
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disruption risks on CLECs, and it questioned whether these processes would be able "
handle the necessary volume of migrations" if mass-market switching is taken off the
unbundling list.7 The FCC did note that some incumbents had begun to perform larger
numbers of loop migrations on a project-managed basis, and that "(t)he record evidence
strongly suggests" that managing and performing cut-overs on a batch basis in this
manner could yield significant improvements. But based on the specific record before it
the FCC concluded that these project-managed processes were not yet "sufficiently
developed or widespread enough to adequately address the impairment created by the
loop cut over process.
The FCC acknowledged that the evidence before it was "not sufficiently
detailed" to permit it to evaluate whether these general observations held true for any
carrier s particular hot cut process in any individual market 9 and that states might well
find in some markets that "existing hot cut practices would be adequate even in the
absence of unbundled local circuit switching.lO But for all other markets, the FCC
directed the states to "approve, within nine months of the effective date of this Order, a
batch cut migration process. . . that will address the costs and timeliness of the hot cut
process."l1 The FCC'
s formal rules implementing the Triennial Review Order define a
batch cut process" as "a process by which the incumbent LEC simultaneously migrates
two or more loops from one carrier s local circuit switch to another carrier s local circuit
TRO ~ 459.
TRO ~ 474.
TRO ~ 473.
TRO ~ 490.
TRO ~ 488.
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switch, giving rise to operational and economic efficiencies not available when migrating
loops. . . on a line-by-line basis.12 The FCC held that the efficiencies that become
available when migrating loops in batches rather than singly would mitigate the economic
and operational burdens on which the FCC's presumptive national finding of impairment
for mass-market switching was based:We conclude that the loop access barriers
contained in the record may be mitigated through the creation of a batch cut process by
spreading loop migration costs over a large number of lines, decreasing per-line cut over
costS.
The FCC rules implementing the Order direct state commissions to make
four determinations with respect to the new batch conversion process (beyond
determining whether any new process is required in a given market at aIl
(1) A state commission shall first determine the
appropriate volume of loops that should be included in the
batch. "
G.) A state commission shall adopt specific processes to
be employed when performing a batch cut, taking into
account the incumbent LEC' s particular network design
and cut over practices.
(J.) A state commission shall evaluate whether the
incumbent LEC is capable of migrating multiple lines
served using unbundled local circuit switching to switches
operated by a carrier other than the incumbent LEC for any
requesting telecommunications carrier in a timely manner
and may require that incumbent LECs comply with an
average completion interval metric for provision of high
volumes of loops.
47 c.P.R. 951.319(d)(2)(ii).
TRO ~ 487.
47 c.F.R. ~ 51.319( d)(2)(B) provides
, "
If a state commission concludes that the absence of a batch
cut migration process is not impairing requesting teleconmmnications carriers ' ability to serve end users
using DSO loops in the mass market without access to local circuit switching on an unbundled basis, that
conclusion will render the creation of such a process unnecessary." The rule specifies the findings that a
state must make if it chooses not to require adoption of a new batch process. See also TRO ~ 490.
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(1) A state commission shall adopt rates for the batchcut activities it approves in accordance with the
Commission pricing rules for unbundled network
elements. These rates shall reflect the efficiencies
associated with batched migration of loops to a requesting
telecommunications carrier s switch either through a
reduced per-line rate or through volume discounts as
appropriate. 15
The paragraphs of the Order giving state commissions specific instructions for the nine-
month cases contain these same directives.
Qwest's Current Hot Cut Process.
As just noted, in considering any new batch conversion process, a state
commission must "tak(e) into account the incumbent LEC's particular network design
and cut over practices.17 Qwest has already spent considerable time and effort to
develop a seamless process for provisioning large quantities of unbundled loops for
CLECs at an extremely high level of quality, and to develop TELRIC-compliant rates for
that process. The state commissions and the FCC examined Qwest's existing hot cut
process at length in the section 271 proceedings and found it adequate. Rather than
redescribing the entire process in this document, Qwest attaches the affidavit of William
M. Campbell, filed before the FCC in the recent Arizona section 271 docket, which
outlines Qwest's current hot cut process. See Exhibit 1. To highlight:
Qwest uses, and must continue to use, the same hot cut process in
all fourteen of its states.
Qwest has a dedicated center in Omaha, Nebraska - the QCCC
that oversees the provision of each and every hot cut throughout
the Qwest region.
47 c.F.R. ~ 51.319(d)(ii)(A)(1)-(1).
See TRO~ 489.
47 c.F.R. ~ 51.319(d)(ii)(A)(~).
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Qwest has a detailed procedure that defines the hot cut process.
See Exhibit 2.
Qwest has trained its technicians on the hot cut process.
Qwest has provisioned unbundled loops for CLECs using this
process at an extremely high level of quality. Qwest's audited and
reconciled performance data shows that it is routinely provisioning
over 98% of its hot cut commitments across the region on time.
See Exhibit 3. This percentage varies in individual states, but in
general remains within the 95-98% performance level. See
Exhibit 4. Moreover, only a small fraction of migrated loops
experience any trouble in the 30 days following cut-over.
Regionally, for example 97.5%-99.99% ofloops do not experience
installation troubles. See Exhibits 3-
Qwest uses its current process to provision approximately 1 000 hot cuts per day on
average, and has processed up to 1 350 hot cuts in a single day. Importantly, these
numbers reflect CLECs ' actual order levels , not the maximum number of hot cuts Qwest
could perform in a single day.
Qwest has experience working with CLECs to transition very large
batches of UNE-P lines to stand-alone unbundled loops simultaneously.Qwest has
already worked with one CLEC to migrate thousands ofUNE-P lines to the CLEC's own
switching using its current form of "batch processing.These numbers continue to
mount. Unlike some other LECs whom the FCC specifically considered in the Triennial
Review Order 18 Qwest includes the results of this large-scale batch conversion process in
its performance data. Thus, the extremely good performance results noted above reflect
Qwest's ability to perform hot cuts for its CLEC customers in larger quantities. See
Exhibits 3-4. The batch conversion process that Qwest proposes in this forum reflects
The FCC noted that Verizon s project-managed large-batch hot cuts were not offered at set rates
were not subject to any performance intervals, and, as a result, were not tracked by Verizon s performance
metrics. SeeTRO~474&n.1466.
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Qwest's actual experience with these types of large-scale cuts and the lessons it has
learned regarding what does and does not work.
II.QWEST'S BATCH LOOP CONVERSION PROPOSAL
Qwest presents its proposal for a new batch hot-cut process in terms of the four
determinations the FCC instructed state commissions to make.
The Minimum "Batch" That Qualifies for the Batch Conversion
Process (47 CoF.R. & 51.319(d)(ii)(A)(1)).
As noted above, the very point of adopting a batch hot cut process is to
capture the operational and economic efficiencies that come from migrating many in-
service loops simultaneously rather than singly. The FCC directed the states to consider
batch conversions specifically because it "expect( ed) these processes to result in
efficiencies associated with performing tasks once for multiple lines that would otherwise
have been performed on a line-by-line basis 19 and it is the ability to "spread loop
migration costs over a large number of lines, decreasing per-line cut over costs" that
enables "the loop access barriers contained in the record (to) be mitigated.20 But these
per-loop costs drop only if the CLEC converting a high enough quantity of loops to give
rise to economies and justify the slightly greater up-front coordination that batch
conversions require. The CLEC must also be seeking to convert loops of a kind that
actually permit conversion tasks to be consolidated; otherwise, there are no efficiencies to
pass through.
For these reasons, the first task the FCC assigned the states was to
determine what minimum "batch" of loops a CLEC must be converting in order to
TRO ~ 489.
TRO~ 487.
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qualify for "batch" conversion. See 47 c.F.R. 9 51.319(d)(ii)(A)(1); TRO ~ 489. (This is
a separate question from the maximum volumes of loops the batch conversion process
must be prepared to handle, which is discussed in part C below). Qwest's preliminary
determination is that the necessary economies and efficiencies may be realized when a
CLEC is converting twenty-five (25) voice grade lines at a single time in a single central
office. The reason why CLECs need at least twenty-five (25) lines individually is that
some of the significant efficiencies for example the ability to reduce the number of
separate calls between Qwest and the CLEC, and the ability to perform multiple pre-
wirings in the same physical locations on the frame come from performing multiple
conversions for the same CLEC not just from doing multiple conversions per se.
In addition, batched loops must all be capable of conversion on a
consolidated basis. The FCC adopted its batch conversion requirement to assist CLECs
in serving the "mass market " which the FCC defined as "consumers of analog 'plain old
telephone service' or 'POTS' that purchase only a limited number of POTS lines and can
only economically be served via analog DSO 100ps.22 A batch conversion process is
possible for these analog DSO loops, which constitute the vast majority of Qwest's
outside plant. But it is not feasible to gain these efficiencies when the underlying facility
uses integrated digital loop carrier systems ("IDLC"). The Triennial Review Order itself
recognizes23 that IDLC is not unbundled via the same, uniform cut-over process as other
loop plant: Each IDLC loop must be examined individually tp determine which of the
Cf TRO ~ 489 (FCC expects efficiencies to come from consolidating pre-wiring and reducing
number of communications between ILEC and CLEC).
TRO ~ 459.
See TRO ~ 297 (noting that unbundling IDLC loops "may require incumbent LECs to implement
policies, practices, and procedures different from those used" to unbundle other kinds of loops); id. 855
(describing a number of different ways that IDLC loops might be unbundled).
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several unbundling methods used for such loops (such as finding a metallic pair
alternative, hair-pinning, reconnecting the loop to a universal DLC system at the remote
terminal, or installing a new central-office terminal) is available or appropriate for that
loop. Qwest emphasizes that it will continue to unbundle IDLC lines a very high level of
quality; however, such loops (which form the small percentage of Qwest's plant in any
event) must be migrated individually using the existing hot cut process.24
See Exhibit
Likewise, the FCC expressly defined its batch-cut requirements in terms
of developing a process to migrate loops "from one carrier s local circuit switch to
another carrier local circuit switch.25 The FCC's definition of a "batch cut process
thus does not include conversions including loop-splitting arrangements that also connect
an unbundled loop to a third carrier packet switch.As the Arizona Corporation
Commission has properly recognized 26 the FCC directed carriers to pursue line-splitting
implementation, not as part of the nine-month switching cases or the development of a
batch conversion process, but rather as part of the pre-existing change management
process.27 The FCC's decision
not to include loop splits as part ofthe batch conversion
process makes sense: conversions from UNE-P directly to loop-splitting arrangements
See TRO ~~ 251-252
47 c.F.R. ~ 51.319(d)(ii) (defming "batch cut process ) (emphasis added). See also 47 c.F.R. ~
51.3l9( d)(ii)(A) (directing state commissions to establish process "for use in migrating lines served by one
carrier s local circuit switch to lines served by another carrier local circuit switch) (emphasis added).
See Arizona Corporation Commission, Procedural Order ILEC Unbundling Obligations As a
Result of the Federal Triennial Review Order Dkt. No. T-00000A-03-0369 (Nov. 6, 2003) at 5-6 ("(T)he
FCC's Triennial Review Order did not require line splitting to be addressed in the nine-month docket and.
. . no party could point to another state commission that is addressing line splitting in its triennial review
proceedings.
);
id. at 7 ("IT IS FURTHER ORDERED that line splitting will not be addressed in this
docket
See TRO ~ 252 ("(W)e encourage incumbent LECs and competitors to use existing state
commission collaboratives and change management processes to address OSS modifications that are
necessary to support line splitting.
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cannot be consolidated into a batch because each loop must be individually checked to
ensure it is capable of carrying DSL signals and, if not, conditioned.Just as
contemplated by the Triennial Review Order the voice CLEC in a potential line-splitting
arrangement will be able to use Qwest'current processes to migrate individual lines to
stand-alone unbundled loops connected to that CLEC's circuit switch.
The Process Emvloved (47 eRR. & 51.319(d)(2)(ii)(A)(2)).
The FCC's second instruction to the states is to "adopt specific processes
to be employed when performing a batch cut, taking into account the incumbent LEC'
particular network design and cut over practices.29 Compared to the loop conversion
process that Qwest uses today, the new batch hot cut process eliminates many of the
repetitive dial tone testing steps much of the telephonic contact between the two
companies, and the need for duplicative entries into Qwest systems in order to update
records. The new process also has new business rules associated with it on both Qwest's
and the CLEC's part. Each is intended to make the work steps within the new process
more efficient and workable for both parties.
Process flow.
Exhibit 6 is a process diagram describing the recommended tasks
for the new batch hot cut process. As illustrated in this diagram, a CLEC will perform
pre-order functions including an initial batch coordination meeting with Qwest. CLEC
must submit to Qwest a Local Service Request ("LSR") with a Purchase Order Number
PON") and a three-letter unique identifier BHC") to designate it as a batch hot
cut candidate in order to begin the batch conversion. Once a complete and accurate LSR
TRO ~~ 251-252.
47 c.F.R. ~ 51.319(d)(2)(ii)(A)(~). See also TRO~ 489.
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is received, a service order will be generated resulting in a firm order confirmation
FOC") back to the CLEc. Once the service order is issued, a Qwest project manager
residing in the QCCC , will begin compiling the batch orders on a Central Office ("CO"
by CO basis.
Approximately two days prior to due date for the batch, a
spreadsheet containing all loops in the batch will be forwarded to both the CLEC and the
central office where the work will take place. This batch spreadsheet will contain order
related information such as the CLEC Purchase Order Number ("PON") with a three-
letter unique identifier ("BHC") describing it as a batch hot cut candidate; the Qwest
order number; a Qwest project ID number; and CLEC contact information.
On the due date, the Central Office Technician ("COT") will
perform both the pre-wiring and lift and lay activity associated with the conversion order.
Prior to performing the lift and lay, however, the COT will perform a dial tone test on
both the Qwest switch port and the CLECs facility to verify the existence of dial tone on
each facility, and that each facility has the correct number working on it. These tasks will
occur before any conversion is conducted. If the COT does not have dial tone on the
CLEC's facility on the due date, the QCCC will contact the CLEC via a phone call
asking the CLEC to resolve the issue. If CLEC dial tone is present, the COT will monitor
the line to ensure an idle state prior to disconnecting the Qwest circuit switch and then
reconnecting it to the CLEC's switch. Upon completion of the orders identified on the
batch spreadsheet, Qwest will notify the CLEC via email that it has completed the
conversIOns.It remains the responsibility of the CLEC to ensure that each line is
triggered for number porting upon completion of the order.
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Batch Hot Cut Requirements.
Exhibit 7 contains a list of the draft requirements that both Qwest
and the CLECs must follow in order to make the conversion process as seamless and
efficient as possible. A summary of the most significant of these requirements is as
follows:
General requirements
The batch hot cut process is applicable to basic installations
that will re-use existing facilities; this will avoid the need to dispatch a Qwest technician
to the field to change outside plant facilities. Other installation options will remain
available during normal business hours to provision other types of unbundled loops. For
example, UNE-P loops working on Integrated Digital Loop Carrier systems, or line
splitting arrangements will be converted during normal business hours using existing
processes because a field dispatch may be required to complete the conversion.
Qwest-specific requirements
Qwest will produce and distribute via e-mail a batch
spreadsheet for the CLEC documenting all order activity within a given central office
and use this batch spreadsheet to communicate with the CLEC on order status and
completion. Unlike the QCCC's current process, to maximize efficiency Qwest will
conduct pre-wire work on the due date, not two days earlier, to minimize the number of
instances technicians must work on each order.
CLEC-specific requirements
The CLEC must provide both email and live contact
information on the LSR when it is submitted. The CLEC must provide accurate end-user
service address information. The CLEC dial tone must be on their designated CF A
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termination prior to the due date. The CLEC must make resources readily available to
clear all loops identified on the batch spreadsheet in a timely manner between the hours
of 3:00PM CST and 11:00PM CST. This will ensure that the CLEC and Qwest can
promptly resolve any issues the COT may encounter (i.bad CFA or no dial tone).
The Cavacitv and Timeliness of the Batch Process (47 C.
& 51.319(d)(2)(ii)(A)(3)).
The FCC's third instruction to state commissions is to "evaluate whether
the incumbent LEC is capable of migrating multiple lines served using unbundled local
circuit switching to switches operated by a carrier other than the incumbent LEC for any
requesting telecommunications carrier in a timely manner. . . .30 This requires state
commissions to make predictive judgments regarding the volumes of conversions the
batch cut process must be able to handle and whether Qwest can continue to provision
loops at an acceptable level of quality at those volumes.
The expected volume of conversions turns on five factors: (1) current
volumes of stand-alone unbundled loop provisioning, (2) current volumes of new UNE-
orders, (3) the size of the embedded UNE- P base, (4) the fraction of that base and new
UNE-P orders that will convert to stand-alone unbundled loops, and (5) the Triennial
Review Order schedule for transitioning the embedded UNE-base to other
arrangements. Qwest addresses each factor in turn. The volumes ofUNE-P and UNE-
lines CLECs submit monthly are well established in Qwest's performance data. The only
unknown is the percentage of UNE-P lines (new and existing) that will convert once
switching is no longer available as a UNE.
47 c.F.R. ~ 51.319(d)(2)(ii)(A)(J). See also TRO~ 489.
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The FCC set a transition schedule for moving the embedded base ofUNE-
P lines to unbundled loops. CLECs must submit 1/3 of their embedded UNE-P lines for
conversion 13 months after the state commission decision; 1/3 of their UNE-P lines 20
months after the state commission decision; and the last 1/3 of their UNE-P lines 27
months after the state commission decision.31 Assuming a July 2 2004 decision from the
state commission, that means 1/3 of the embedded base will convert between August
2005 and February 2006; 1/3 of the embedded base will convert between March 2006 and
September 2006 , and the remainder will convert before April 2007.32 The FCC also
stated that state commission decisions eliminating unbundled switching as a UNE will
become effective on December 2, 2004.
Thus, to calculate the expected monthly volumes in each state, the state
commissions should apply the following formulas based on the volumes of UNE-P lines
and UNE-L lines in each individual state:
December 2004 - July 2005: (Inward unbundled loop volume
(growth) eligible for the batch hot cut process * percent of UNE-
lines in markets where Qwest is challenging the impairment
finding)
August 2005 - April 2007: (Inward unbundled loop volume
(growth) eligible for the batch hot cut process * percent of UNE-
lines in markets where Qwest is challenging the impairment
finding) + (Embedded UNE- P base amortized over 21 months *
percent ofUNE-P lines in markets where Qwest is challenging the
impairment finding)
These formulas will provide the expected volumes of unbundled loops that
Qwest's must be prepared to provision in each state on a monthly basis.
47 c.F.R. ~51.319(d)(4)(A).
TRO ~ 532.
47 c.F.R. ~51.319(d)(4).
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Batch Cut Rates (47 CoF.R. & 51.319(d)(2)(ii)(A)(4)).
The FCC's last directive to each state commission is to "adopt rates for the
batch cut activities it approves in accordance with the Commission s pricing rules for
unbundled network elements " which should "reflect the efficiencies associated with
batched migration. . . ." 34 The final rate will obviously depend on the precise procedure
adopted in this forum.
As an initial matter, Qwest notes it is starting from a better position than
many other incumbent LECs in this regard. The FCC found in the Triennial Review
Order that currently hot cuts are often priced at rates that prohibit facilities based
competition for the mass market ,35 citing ILEC non-recurring charges exceeding $100
and as high as $185.36 But Qwest's hot cut charges across its region are not nearly this
high. In virtually every state Qwest's current non-recurring charges for a basic hot cut
range between $29.10 and $65.00.
The batch conversion process that Qwest proposes above will yield
significant additional efficiencies and in most states the CLEC community can expect to
experience a significantly reduced rate.
III.CONCLUSION
Qwest hereby presents a viable batch hot cut proposal that will allow CLECs to
convert large volumes of DSO lines to unbundled analog loops, while still ensuring that
47 c.F.R. ~ 51.319(d)(2)(ii)(A)(1). See also TRO ~ 489.
TRO ~ 465 (emphasis added).
TRO ~ 470.
In two states, Idaho and Minnesota, the nomecurring rates associated with hot cuts are
substantiall y below this range. In these states, these costs are well below the cost of providing the service
even with the new batch hot cut process. As such, it does not set forth these rates as an example.
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CLEC end-user customers have minimal service interruption, and minimal installation
service problems. In most states, the process will also significantly reduce the non-
recurring rate associated with provisioning an individual unbundled loop. Qwest has
already demonstrated that the CLEC community can use its existing hot cut process to
reach mass-market customers at a high level of quality. This simplified process should
do nothing but improve an already strong process. Qwest asks the Idaho Public Utilities
Commission to approve its proposed process.
Respectfully submitted this 12th day of November, 2003.
Qwest Corporation
~Wt--
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
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CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of November, 2003 , I served QWEST
CORPORATION'S BATCH HOT CUT PROPOSAL as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
i i ewell(2i),puc. state.id. us
----L Hand Delivery
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Wayne Hart
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
whart~puc.state.id.
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Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~JJuc. state.id. us
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Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
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Marattv(2i),Qwest.net
Attorney for Verizon
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QWEST CORPORATION'S BATCH HOT CUT PROPOSAL - Page 18
Boise-164195.10029164-00097
Charles Carrathers
Verizon Northwest Inc.
l800 41 st Street
Everett, W A 98201
Telephone: [phone]
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chuck. carrath ers~v erizon. com
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Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ID 83702
Telephone: [phone]
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i oe~mcdevitt -miller. com
Attorney for MCImetro, Time Warner
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Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway - Suite 400
Greenwood Village, CO 80111
Telephone: [phone]
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bpomeroy~ho llandhart. com
Attorney for AT&T
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Adam L. Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
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asherr~qwest.com
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Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
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clays~mossadams.com
Attorney for ITA
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QWEST CORPORATION'S BATCH HOT CUT PROPOSAL - Page 19
Boise-164195.10029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, Inc.
1875 Lawrence Street - Suite 1575
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
ls:friesen~att.com
Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ID 83701
Telephone: [phone]
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cew~givenspursley.com
Attorney for ITA
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/f?;Jt Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S BATCH HOT CUT PROPOSAL - Page 20
Boise-I64195.10029164-00097
BHCP - Exhibit 1
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
Qwest Communications
International Inc.
, )
WC Docket No.
In the Matter of
Consolidated Application for Authority
to Provide In-Region, InterLATA Services
in Arizona
DECLARATION OF WILLIAM M. CAMPBELL
Checklist Item 4 of Section 271(c)(2)(B):
Unbundled Loops
II.
Campbell Loops Declaration
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY .....................................................................
QWEST HAS COMPLIED WITH THE COMMISSION'
UNBUNDLED LOOP REQUIREMENTS...........................................
A. Qwest Offers All Required Categories of Unbundled Loops
and Related Services.......................................................................
Voice-Grade/Analog Loops ...................................................
xDSL-Capable Loops ............................................................ 7
High-Capacity Loops ............................................................
B. Qwest Complies With the Commission s Spectrum
Management Rules .........................................................................
C. Qwest Policies and Procedures with Respect to Unbundled
Loops Demonstrate Qwest's Compliance with Checklist
Item 4...............................................................................................
Ordering Process ..................................................................
Provisioning Process.............................................................
Maintenance and Repair Process.........................................
III.THE ARIZONA COMMISSION HAS THOROUGHLY
REVIEWED QWEST'S UNBUNDLED LOOP OFFERINGS..............
SUMMARY AND CONCLUSION........ .................. ................ ...............IV.
- 1 -
Campbell Loops Declaration
TABLE OF EXHIBITS
Exhibit Description
WMC-LOOP-Qualifications of William M. Campbell
WMC- LOOP-2 Quarterly Growth of Unbundled Loops
WMC-LOOP-Tasks Performed by Qwest Personnel to Install an
Unbundled Loop
WMC- LOOP-4 Provisioning Process for Coordinating Loop Installation and
Number Portability
WMC-LOOP-Engineering Decision Tree for Installation of Loops
Provisioned With IDLC Technology
WMC- LOOP-II-Step Process for Facility Assignment
WMC- LOOP-Process Flow for New Loops
WMC-LOOP-Process Flow for Hot Cuts
WMC- LOOP-Flow Chart Delineating the Tasks Performed by Qwest
Personnel to Maintain Unbundled Loops
WMC-LOOP-Charts Showing Improvement in Coordinated Installation
Performance
- 11 -
Campbell Loops Declaration
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of
WC Docket No.Qwest Communications
International Inc.
Consolidated Application for Authority
to Provide In-Region, InterLATA Services
in Arizona
DECLARATION OF WILLIAM M. CAMPBELL
Checklist Item 4 of Section 271(c)(2)(B):
Unbundled Loops
Pursuant to 47 C.R. ~ 1.16, William M. Campbell declares as follows:
My name is William M. Campbell. My business address is 1801
California Street, Denver, Colorado. I am Director, Product Marketing-
Interconnection Services, at Qwest Corporation ("Qwest"). 1/ I am the Product
Director responsible for Checklist Item 4 - Unbundled Loops. In that position, I
have directed the Qwest Unbundled Loop Product Team developing products and
processes for the Qwest Unbundled Loop products and have the responsibility to
represent Qwest in formal Section 271 proceedings. As part of Qwest's work to
ensure its compliance with Section 271 , I have participated extensively in the state
1/ A description of my professional experience and education is attached as
Exhibit WMC-LOOP-l to this Declaration.
Campbell Loops Declaration
proceedings in Arizona, Colorado, Nebraska, Oregon, Washington, and the Multi-
state 271 workshops involving Idaho, Iowa, Montana, New Mexico, North Dakota
Utah, and Wyoming. This includes directing testimony in South Dakota and
Minnesota.
I. EXECUTIVE SUMMARY
Qwest satisfies the requirements of Section 271(c)(2)(B)(iv) of
the Telecommunications Act of 1996 ("1996 Act" or "Act") and Federal
Communications Commission ("Commission" or "FCC") rules that relate to the
provision of unbundled loops. Consistent with the Act and Commission
precedent, 2/ Qwest has a concrete and specific legal obligation to provide
competitors with nondiscriminatory access to unbundled loops under both its
2/ See New York 271 Order 15 FCC Rcd at 3962-63 (~ 20) ("(T)he Commission
must consult with the relevant state commission to verify that the BOC has one or
more state approved interconnection agreements with a facilities-based competitor
or a statement of generally available terms and conditions ("SGAT"), and that either
the agreement(s) or general statement satisfy the 'competitive checklist.
);
see also
Texas 271 Order 15 FCC Rcd at 18360-61 (~ 11) (illustrating use of an SGAT
rather than individually negotiated interconnection agreements, to test compliance
with the checklist requirements). Once an SGA T has gone into effect pursuant to
Section 252(:t)(3)(B), every CLEC is entitled to adopt any of the services or terms of
the agreement pursuant to Section 252(i). The Commission has held that the "pick
and choose" rule of Section 252(i) applies to SGATs. See 14 FCC Rcd at 20984-
(~ 167).
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Campbell Loops Declaration
Statement of Generally Available Terms and Conditions ("SGAT") 3/ and state-
approved interconnection agreements.
Qwest's unbundled loop offerings comply with Commission
requirements. 5/ Qwest makes available to CLECs all required types of unbundled
loops, including analog/voice grade loops, digital subscriber line ("xDSL") loops , and
high-capacity loops. Qwest performs hot cuts for CLECs and, where technically
feasible, provides CLECs with access to unbundled loops provisioned over
integrated digital loop carrier ("IDLC") technology. Qwest performs loop
conditioning where necessary to allow CLECs to provide digital services. Qwest
also provides CLECs with nondiscriminatory access to pre-order loop makeup
3/ Qwest's Arizona SGAT is located at Attachment 5, Appendix B of this
Application.4/ Appendix L contains state-approved interconnection agreements that Qwest
has entered into with CLECs in Arizona as of August 1 , 2003. The Arizona SGAT
has been converted to a state-approved interconnection agreement ("SGAT-Based
Interconnection Agreement") as the result of New Edge Networks' opt-in to the June
2002, Arizona SGAT. Qwest relies on this agreement and the other
interconnection agreements filed with the Arizona Commission, in addition to its
SGAT, to establish checklist compliance. Unless otherwise noted, references to
SGAT language and section numbers also are intended to refer to SGAT-Based
Interconnection Agreements.5/ Qwest recognizes that in its Triennial UNE Review proceeding, the
Commission modified its requirements with respect to unbundled loops. In the
wake of the Commission s decision, Qwest will continue to ensure that its
unbundled loop policies and practices are consistent with applicable federal law.
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Campbell Loops Declaration
information. 6/ Finally, Qwest makes available to CLECs unbundled access to dark
fiber loops, to subloops, and to the high-frequency portion of the loop.
As of May 31 2003, Qwest had in service 37 719 unbundled
loops in Arizona. (These figures represent stand-alone loops only, not those
provided as part of a UNE combination.) Specifically, Qwest had in service 30 253
unbundled voice-grade analog loops, 5 578 xDSL-capable loops, and 1 888 high-
capacity loops. The volume of unbundled loops in service demonstrates that Qwest
is provisioning loops to CLECs in Arizona in a nondiscriminatory fashion.
II. QWEST HAS COMPLIED WITH THE COMMISSIONS UNBUNDLED LOOP
REQUIREMENTS
Section 271(c)(2)(B)(iv) of the 1996 Act requires Bell Operating
Companies ("BOCs ) wishing to offer in-region interLATA service to provide "local
loop transmission from the central office to the customer s premises, unbundled
6/ Qwest's loop qualification tools , policies , and practices are discussed in the
Declaration ofLynn M V Notarianni and Loretta A. Huff on Operations Support
Systems ("OSS"7/ These products are discussed in separate Declarations of Karen A. Stewart
, respectively, Dark Fiber, Network Interface Devices and Subloops , and Line
Sharing and Line Splitting.8/ Exhibit WMC- LOOP-2 shows the growth in the number of loops in service in
Arizona. Qwest's commercial performance for unbundled loops is described in the
Commercial Performance Declaration of Dean Buhler.
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Campbell Loops Declaration
from local switching or other services." 9/ In the UNE Remand Order the
Commission defined the local loop as:
(A) transmission facility between a distribution
frame (or its equivalent) in the incumbent LEC
central office and the loop demarcation point at an
end-user customer premises, including inside wire
owned by the incumbent LEC. The local loop
network element includes. . . dark fiber, attached
electronics (except those electronics used for the
provision of advanced services, such as Digital
Subscriber Line Access Multiplexers), and line
conditioning. 10/
Qwest complies with the unbundled loop requirements of the
1996 Act and the Commission s rules and orders. Qwest has a concrete and specific
legal obligation to provide CLECs with access to unbundled loops under its SGA
and state-approved interconnection agreements. Moreover, Qwest provides
unbundled loops to CLECs in a nondiscriminatory manner.
The loop provisions in Qwest's SGAT have evolved not only on a
state-by-state basis , but across Qwest's region through workshops and hearings
that were part of collaborative processes, conducted on an open basis with active
participation by CLECs. Throughout these processes, Qwest attempted to reach
consensus with CLECs on SGAT language. When that was not possible , the
47 D.C. ~ 271(c)(2)(b)(IV).
10/ UNE Remand Order 15 FCC Rcd at 3772-78 (~~ 166-79); see also 47 C.~ 51.319(a)(1).
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Campbell Loops Declaration
impasse" issue went to the state regulatory authority for resolution. As a result
Qwest's SGAT reflects a great deal of CLEC input.
In addition to the SGAT, Qwest further defines the
specifications, interfaces, and parameters associated with unbundled loops
Technical Reference Publication Nos. 77384 (unbundled loops), 77375 (DS1), 77324
(DS3), and 77346 (OCn), all of which are available on Qwest's web site. 11/ Qwest's
Wholesale Product Catalog ("PCAT'), also available on Qwest's web site , provides
CLECs with additional product information. 12/
Qwest Offers All Required Categories of Unbundled Loops and Related
Services
Qwest offers CLECs the complete range of unbundled loops.
Specifically, Qwest offers (1) 2-wire and 4-wire voice-grade/analog loops; (2) four
types of loops that generally can be grouped together in the category of "xDSL
capable" loops; and (3) four types of high-capacity loops. 13/
1. Voice-Grade/Analog Loops
10.Basic 2- Wire/4- Wire Analog Loop. The basic 2-wire/4-wire
analog loop is available as a 2-wire or 4-wire voice grade , point-to-point
configuration suitable for local exchange type services. This service is a
11/ Technical publications can be found at http://www.qwest.com/wholesale/
notice s/techPub. h tml.
12/The PCAT can be found at http://www.qwest.com/wholesale/pcat/index.html.
13/See SGAT ~~ 9., 9.
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Campbell Loops Declaration
transmission path that provides a connection from the Qwest serving central office
distribution frame or equivalent to the demarcation point at the end user s location.
The actual loop facilities may utilize various technologies or combinations of
technologies. 14/
2. xDSL-Capable Loops
11.Qwest offers four types of loops that can be classified as "xDSL
capable" loops: (1) 2-wire and 4"wire "non-loaded" loops , (2) asymmetrical digital
subscriber line ("ADSL") compatible loops, (3) Basic Rate ISDN ("BRI") capable
loops, and (4) xDSL- I capable loops.
12.2-Wire/4-Wire Non-Loaded Loop. The 2-wire/4-wire non-loaded
loop is a metallic facility that provides a transmission path from the Qwest serving
central office distribution frame, or equivalent, to the end user s demarcation point.
It is a metallic, wire cable pair with no load coils , and, depending on the Network
Channel ("NC") and Network Channel Interface ("NCI") codes specified by the
CLEC , with, potentially, some limited lengths of bridged tap. Qwest will condition
loops at the CLEC's request. The loop conditioning process is described in detail
below.
13.ADSL Compatible Loop. The ADSL compatible loop is an
unbundled 2-wire non-loaded metallic facility that establishes a transmission path
between a Qwest serving central office distribution frame and the demarcation
14/SGAT ~ 9.
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Campbell Loops Declaration
point located at the end user s designated premises. This loop will meet the ADSL
performance requirements specified in Qwest's Technical Publication No. 77384. If
necessary, Qwest will condition the loop at the CLEC's request to meet ADSL
technical parameters.
14.Basic Rate ISDN (UBRI") Capable Loop. The Basic Rate ISDN
capable loop is a Qwest facility with a 2-wire interface that provides a transmission
path from the Qwest serving central office distribution frame, or equivalent, to an
end user s demarcation point. This loop transports bi-directional, 2-wire signals
with a nominal transmission rate of 160 KBPS , meets the performance
requirements specified in Qwest's Technical Publication No. 77384 , and permits
access to 144 KBPS channelized payload bandwidth for transport of services.
15.xDSL-I Capable Loop. The xDSL- I capable loop is a 2-wire
facility that provides a transmission path from the Qwest serving central office
distribution frame, or equivalent, to an end user demarcation point. This loop
transports bi-directional, 2-wire signals with a standard transmission rate of 160
RBPS , meets the performance requirements specified in standard technical
publications, and permits access to a nominal 144 KBPS unchannelized payload
bandwidth for transport of services.
16.Qwest uses the terms "capable" and "compatible" to make it
clear that while Qwest provides the loops themselves , CLECs provide the service
over those loops. Specifically, "capable" means that Qwest assures that the loop
- 8 -
Campbell Loops Declaration
provisioned complies with industry technical standards. 15/ The term "compatible
means that Qwest assures that the loop complies with the ordered NC/NCI codes
but makes no assumptions as to the capabilities of the CLEC's central office
equipment or customer premises equipment ("CPE"). 16/ Qwest does not restrict the
CLEC's use of the loop except as expressly permitted or required by existing
rules. 17/
17.Extension Technology- Qwest provides extension technology, if
needed, for Basic Rate ISDN ("BRI") capable loops and xDSL- I capable loops. 18/
Extension technology takes into account, for example, additional regenerator
placement, central office powering, and mid-span repeaters, if required, as well as
BRITE cards in order to provision the Basic Rate ISDN capable or xDSL- I capable
loop. Extension technology may be required to bring the circuit to the technical
specifications necessary to accommodate the requested service. Qwest will add
extension technology if the circuit design requires it or if requested by a CLEC to
meet its specific needs. If the circuit design requires extension technology to meet
15/ SGAT ~ 9.1.1. For example , ANSI Standards T1.601 and T1.102 specify
the ISDN and DS1 interfaces. There are test sets that indicate whether the loop is
performing to the established standards. Qwest will build the capable loop using
whatever equipment it takes , such as subscriber loop carrier or range extenders, to
ensure that the loop meets the standards.
16/SGAT ~ 9.1.2.
17/SGAT ~ 9.1.5.
18/SGAT ~ 9.
- 9 -
Campbell Loops Declaration
the technical standards, then Qwest will add it at no charge. 19/ However , if a
CLEC requests the addition of extension technology even though the loop conforms
to the technical standards, then the inclusion of extension technology will result in
a monthly recurring charge to the CLEC.
3. High-Capacity Loops
18.Qwest offers four types of high-capacity loops under the SGAT:
(1) DS1-capable loops, (2) DS3-capable loops, (3) OCn loops, and (4) dark fiber
loops. 20/
19.DBI-CapableLoops. The DS1-capable loop is a transmission
path between the Qwest serving central office distribution frame, or equivalent , and
the demarcation point at the end user location. The DS I-capable loop transports
bi-directional DS1 signals with a nominal transmission rate of 1.544 Mbps and
meets the design requirements specified in standard industry technical
publications. 21/
20.DBa-Capable Loops. The DS3-capable loop is a transmission
path between a Qwest serving central office distribution frame, or equivalent, and a
demarcation point at an end user location. The DS3-capable loop transports bi-
19/Id.
20/SGAT ~ 9.
21/SGAT ~ 9.
- 10 -
Campbell Loops Declaration
directional DS3 signals with a nominal transmission rate of 44.736 Mbps that meets
the design requirements specified in standard industry technical publications. 22/
21.For DS 1- or DS3-capable loops, Qwest will provide the necessary
electronics at both ends, including any intermediate repeaters. In addition, the
CLEC will have access to these terminations for testing purposes. 23/ Additionally,
Qwest permits CLECs to add multiplexing to both DSI and DS3-capable loops. 24/
22.DCn Capable Loops. Qwest also stands ready to provide access
to higher capacity loops, including OC3, OCI2 , OC48 , and OC192 loops, where
facilities are available. 25/
23.Dark Fiber Loops. Qwest's dark fiber offerings are in section 9.
of the SGA T and are discussed in the Dark Fiber Declaration of Karen A. Stewart.
Qwest Complies With the Commission s Spectrum Management Rules
24.Spectrum management is the administration of loop plant to
facilitate spectrum compatibility for services and technologies that use pairs in the
same cable. Spectrum compatibility, in general, refers to the ability of loop
22/SGAT ~ 9.
23/SGAT ~ 9.
24/SGAT ~ 9.10.
25/SGAT ~ 9.
- 11 -
Campbell Loops Declaration
technology to operate and reside in the same or an adjacent binder group without
causing an unacceptable degradation of service from the end user s perspective. 26/
25.In the Arizona proceedings, Qwest's spectrum management
policies generated an impasse issue. Qwest modified its Arizona SGAT to reflect
the outcome of this issue in the ACC's final order on loops. 27/ Qwest's spectrum
policies therefore comply with the ACC's final order on loops. Qwest is also in
compliance with current federal requirements for spectrum management. As the
Commission continues to develop its spectrum management policies, Qwest will
revise its spectrum policies as necessary to remain consistent with them.
Qwest Policies and Procedures with Respect to Unbundled Loops
Demonstrate Qwest's Compliance with Checklist Item 4
26.The following sections describe the steps through which a CLEC
obtains unbundled loops from Qwest, including ordering, provisioning, and
maintenance and repair. Qwest has well-developed processes in place for
provisioning, maintaining, and repairing unbundled loops for CLECs.
Ordering Process
27.The Local Service Request Form. CLECs order unbundled loops
by completing a local service request ("LSR") and submitting it over one of Qwest's
26/Line Sharing Order 14 FCC Rcd at 20988-89 (~178).
27/ACC Loops Final Order ~~ 73-86.
- 12 -
Campbell Loops Declaration
electronic or manual interfaces. 28/ For each unbundled loop ordered, CLECs must
specify the loop type (including the NC/NCI codes), provide the Connecting Facility
Assignment (which identifies where the loop should be wired in the central office),
specify the desired installation option, and note the desired due date.
28.Desired Due Dates and Standard Installation Intervals. CLECs
may calculate a due date based on the minimum number of days provided in the
SGAT as Qwest's standard installation interval for the specified loop type. A CLEC
may also specify a later date (i.e.allow a longer installation interval than the
standard interval). The following chart is a summary of Qwest's loop installation
intervals in Arizona 29/:
28/SGAT ~~ 9.2.4., 9.2.4.4.
29/ Qwest's loop installation intervals are consistent with the ACe's final order.
ACC Loops Final Order 'iI'iI 27-34.
- 13 -
Campbell Loops Declaration
Standard Analog Loops 5 days 6 days ICB
AnalogN oice Grade
Quick Loop Analog-3 days 3 days ICBLoops
Conversion 30/
No Conditioning Required 5 days 6 days 7 days ICB
xDSL-Capable Loops
Conditioning Required 15 days ICB ICB ICB
DS1-Capable 5 days 7 days 9 days ICB
DS3-Capable 7 days ICB ICB ICB
High-Capacity Loops (1-(4-
loops)loops)
Fiber/OCn/Other High -ICB ICB ICB ICB
Capacity
29.During the state proceedings, Qwest made a number of
CLEC-friendly modifications to the loop installation intervals. For instance, Qwest
reduced the interval for xDSL- I loops from 10 days to align with the intervals of 5
, and 7 days for xDSL- and ISDN-capable loops. Qwest also created a shorter
installation interval for analog loop conversions, called Quick Loop. Quick Loop
offers a three-day installation interval for conversion of existing service to a 2-wire
analog loop ordered with the basic installation option. 31/ Since October 22, 2001
30/ Qwest provides a 3-day installation option, called Quick Loop, for conversion
of in -place analog loops that do not require coordinated installation or cooperative
testing. Quick Loop is not available for loops served over IDLC technology. As
discussed herein, Quick Loop is also offered for loops with number portability. The
installation intervals for Quick Loop with LNP are 3 days for 1 to 24 loops and ICB
for 25 or more loops.
31/ All Quick Loop performance results are reflected in the analog loop
performance indicators.
- 14 -
Campbell Loops Declaration
this option has also been available for analog loops with number portability. Few
CLECs have utilized the Quick Loop option to date. CLECs do not need a contract
amendment to utilize these shortened intervals.
30.Process for Requesting Loop Conditioning. Loop conditioning (or
line conditioning) is the term used to describe the process of removing load coils and
excess bridged tap from existing copper loops that would negatively affect the
transmission of a digital signal. In many cases , the data portion of the loop is
diminished if there are load coils or certain amounts of bridged tap on the loop. To
allow CLECs full use of the loop s capability, Qwest provides CLECs with loop
conditioning for xDSL"capable services upon request, consistent with Commission
rules. 32/ The ability to condition loops is not, however, unlimited. The conditioning
requirement is subject to a technical feasibility standard the Commission has
delineated. 33/
31.Although the Commission does not require that Qwest condition
loops proactively, in 2000 Qwest voluntarily established a bulk de-loading project to
remove load coils from copper loops that are under 18 000 feet in length in selected
wire centers and routes in which CLECs and Qwest were providing DSL services.
32/ See 47 C.R. 9 51.319(a)(3)(i) & (h)(5) (ILECs must "remov(e) from the
loop. . . any device that may diminish the capability of the loop to deliver high-
speed switched wire line telecommunications capability, including xDSL service
see also SGAT 99 9.2.4 and 9.2.4.
33/Local Competition First Report and Order 11 FCC Rcd at 15691-92 (,; 381).
- 15 -
Campbell Loops Declaration
The CLECs assisted Qwest in prioritizing the project schedule for this work. The
de-loading project reduced the occurrence of short copper loops that needed to be
conditioned on a one-by.one basis. Qwest provided the CLECs with a web-based
tool that identified the wire centers and routes included in the project as well as an
expected completion date. Once Qwest de-loaded a route and updated the
databases, the route was posted on the web as a completed route. Two hundred
ninety-eight wire centers were included in this project regionwide. 34/
32.The bulk de-loading project was completed in March 2001 at no
cost to the CLECs. As the individual jobs were completed, the conditioned pair
status was updated in the loop qualification databases , increasing the available
inventory of digital-capable loops. This inventory is available, as with all loops, on a
first-come , first-served basis.
33.Qwest's loop qualification tools provide CLECs with information
to determine whether loop conditioning will be required. 35/ When submitting an
unbundled loop order, CLECs may indicate that they approve loop conditioning,
where needed, by entering a "Y" (for yes) in the space provided for "special
34/ Qwest initiated a second bulk de-loading program in 2002. Thus Qwest
continues to take voluntary steps to minimize the need for line-at-a-time
conditioning.
35/ These tools are described in the pre-order section of the OSS Declaration of
Lynn M V Notarianni and Loretta A. Huff.
. 16 -
Campbell Loops Declaration
construction authorization" on the LSR form. 36/ This entry on the LSR provides
Qwest with approval to complete any required conditioning. If the LSR form
contains the indicator for loop conditioning but conditioning is not required, then
the due date can be consistent with the installation interval based on loop type and
the number of non-conditioned loops ordered, as described above. 37/
34.If the CLEC fails to indicate on the LSR form that loop
conditioning is approved, but Qwest determines that conditioning is required, then
Qwest will inform the CLEC of the need for conditioning. The CLEC then has a
four-hour window to provide positive authorization via a supplement to the LSR. If
the CLEC does not respond within four hours, Qwest cancels the order.
35.Firm Order Confirmation. Qwest will provide the CLECs with
confirmation of the receipt of their LSR and indicate the due date for the service
installation via a Firm Order Confirmation ("FOe"). One of Qwest's performance
measures, PO-, monitors the timeliness with which Qwest returns FOCs to CLECs
in response to LSRs. PO-5 requires Qwest to provide the CLEC with a FOC for
unbundled analog loops within 24 hours of receiving a valid and complete LSR. For
36/SGAT ~ 9.2.4.
SGAT ~ 9.2.4.37/
- 17 -
Campbell Loops Declaration
xDSL- and DS I-capable loops , the PIDs require Qwest to return the FOC within 72
hours. 38/
Provisioning Process
36.Facility Assignment. Although Qwest recommends that CLECs
pre-qualify loops prior to placing an order, pre-qualification is not mandatory. Once
a valid service order has been received by Qwest, all retail and wholesale orders
follow the same facility assignment process. 39/ The mechanized assignment process
searches for compatible facilities and will assign the first compatible facilities that
can support the requested loop type. If compatible facilities are not available for
DSQ-level facilities, Qwest uses a standard II-step facility assignment process to try
to identify compatible facilities. This process includes, but is not limited to, looking
for a line and station transfer ("LST") or recovering defective pairs. The II-step
facility assignment process is presented in Exhibit WMC- LOOP-
37.Provisioning Process. When Qwest provisions an unbundled
loop, a central office technician must be dispatched to run jumpers connecting the
unbundled loop to the CLEC's connecting facility assignment ("CFA") as specified
on the LSR by the CLEC. Additionally, a field technician may need to be
38/ As a result of a trial conducted during the Colorado workshops, Qwest and
CLECs agreed to support revising the FOC interval in the PO-5 PID for xDSL and
DSIloops from 24 to 72 hours. The ROC TAG approved that modification, and
Qwest notified CLECs of the change through the Change Management Process.
Qwest's performance under PO-5 is discussed in the Commercial Performance
Declaration of Dean Buhler.
- 18 -
Campbell Loops Declaration
dispatched to perform cross connect work at the feeder distribution interface
FDI"), pedestal, or network interface device ("NID"). Exhibits WMC-LOOP-7 and
WMC-LOOP-8 delineate the tasks Qwest personnel perform to install an unbundled
loop.
38.Installation of Loops Provisioned with IDLC Technology. The
Commission requires Qwest to unbundle loops that are provisioned over integrated
digital loop carrier ("IDLC") technology. However, the Commission acknowledged in
the UNE Remand Order that unbundling loops provisioned over IDLC is difficult
and may even be impossible in some circumstances. 40/ Qwest is committed to
providing CLECs access to unbundled loops, even when IDLC technology is
deployed, whenever technically feasible. 41/ Qwest has continuously provided loops
on this type of facility since early 1999, long before Qwest offered an IDSL solution
to Qwest's retail end users in April 2000. Throughout 2000 and 2001, Qwest
worked through the difficulties inherent with the provisioning of loops for DSL
generally, and loops provisioned with IDLC specifically. IDLC technology was the
subject of discussion in state 271 workshops, and numerous CLEC meetings focused
on identifying provisioning alternatives. Qwest worked cooperatively with CLECs
to clear loop orders that were held due to IDLC provisioning issues by identifying
39/SGAT ~ 9.1.2.1.1.
40/UNE Remand Order 15 FCC Rcd at 3788-89 (~ 204, n.390).
41/SGAT ~ 9.
- 19 -
Campbell Loops Declaration
viable engineering solutions. Further, Qwest established a specialized team within
the Qwest CLEC Coordination Center (which is described in paragraph 48 of this
Declaration) to focus specifically on supporting CLEC unbundled loop orders over
IDLC. Qwest developed and utilizes an engineering decision tree, depicted in
Exhibit WMC-LOOP-, to determine the best method to provision unbundled
analog, ISDN, and xDSL-I loops served by IDLC.
39.To assist the CLEC considering future market opportunities
Qwest provides access to its ICONN database. 42/ The IcaNN database, available
on Qwest's external website , provides information at a wire center level.
Information includes number of total lines available, lines in service , and lines
served by universal or integrated DLC.
40.Qwest also makes available wire center makeup information in
the Wire Center Raw Loop Data Flat File. 43/ This flat file is comma delimited and
downloadable to an Excel type spreadsheet that allows the CLEC to manipulate and
analyze the data. CLECs may also use Qwest's electronic interfaces , IMA-GUI and
IMA-EDI, to obtain individual loop makeup information. 44/
42/The ICONN database is located at http://www.qwest.com/iconn.
43/ CLECs must obtain a digital certificate in order to use this tool. Qwest's ass
web site, http://www.qwest.com/wholesale/systems , includes instructions for
obtaining a digital certificate and for using the Wire Center Raw Loop Data Flat
File.
44/ These tools are described in the ass Declaration of Lynn M V Notarianni
and Loretta A. Huff.
- 20 -
Campbell Loops Declaration
41.Process for Conditioning Loops. Qwest provides for loop
conditioning to ensure that CLECs can obtain a copper loop without load coils and
excessive bridged tap. Conditioning requires an engineering job to be issued and a
construction technician is dispatched to the field to cut away from the load coil cable
stub and re-splice the loop together. For efficiency, CLECs may request both line
conditioning and installation on the same LSR.
42.Two loop conditioning issues reached impasse in the Arizona
Section 271 proceedings. The first involved a question of whether Qwest must
reimburse a CLEC for conditioning costs if the CLEC loses the customer within a
certain period of time , as the CLECs presumed that such a loss would be due to
Qwest's actions. The ACC ordered a change to SGAT section 9.2.4., providing for
a credit of conditioning charges if Qwest does not meet a due date for line
conditioning or does not perform conditioning in accordance with the standards
applicable under the SGAT. 45/
43.The second loop conditioning issue involved a question of
whether Qwest may charge CLECs for conditioning lines ofless than 18 000 feet in
length. The ACC affirmed that the UNE Remand Order permitted such charges
and required no change to the SGAT language on this issue. 46/
45/ACC Loops Final Order ~~ 70-72.
46/Id.~~ 66-67.
- 21 -
Campbell Loops Declaration
44.Installation Options. Qwest's SGAT offers CLECs five
installation options, all of which are available for both the conversion of existing
customer lines to unbundled loops and the installation of new unbundled loops. 47/
These options are: (1) basic installation; (2) basic installation with performance
testing; (3) basic installation with cooperative testing; (4) coordinated installation;
and (5) coordinated installation with cooperative testing. In addition, Qwest offers
an enhancement to the standard installation options called project coordinated
installation, which is available for high-volume orders and other special orders. 48/
Regardless of the installation option chosen, Qwest notifies the CLEC when the
installation work is complete. Qwest also coordinates the activities associated with
installation of unbundled loops and number portability, as depicted in Exhibit
WMC-LOOP-4. Qwest's installation options are described in further detail below.
45.Basic Installation Options. CLECs may select from among three
options for basic (i.e.non-coordinated) installation. First, the Qwest central office
technician and field technician execute basic performance tests and perform the
installation. 49/ If a CLEC selects basic installation with performance testing,
Qwest technicians conduct performance tests and provide the results to the CLEC
47/SGAT ~~ 9.1 - 9.
48/SGAT ~ 9.
49/SGAT ~ 9.1.2.
- 22 -
Campbell Loops Declaration
after the tests are concluded. 50/ Qwest has implemented a process to e-mail the
test results to CLECs within two business days so that CLECs have a written
record of the tests Qwest performs. 51/ For the basic installation with cooperative
testing option, after the Qwest technicians conduct their performance tests, they
contact the CLEC with the results, and the CLEC performs its own loop back
acceptance test. The CLEC then accepts the loop, and the parties exchange
demarcation information. 52/ If Qwest fails to perform cooperative testing due to
Qwest's fault , Qwest will waive the non-recurring charge for the installation
option. 53/
46.Coordinated Installation Options. Coordinated installation and
testing are often needed by the CLEC in order to have a seamless installation for
the end-user customer. The coordinated installation options allow the CLEC to
designate a specific appointment time on the date when Qwest will begin the
installation of an unbundled loop. The CLEC may request installation outside the
standard business hours of 8:00 a.m. to 5:00 p.m. on business days, but additional
charges apply. CLECs most often request a coordinated installation to coordinate
work between Qwest and the CLEC when the service is associated with an existing
50/SGAT ~~ 9.1.3.
SGAT ~ 9.51/
52/SGAT ~ 9.
SGAT ~ 9.53/
- 23 -
Campbell Loops Declaration
working line, although coordinated installation is also available for new customer
lines. 54/ Coordinated installation enables the GLEC and its customer to plan ahead
for minimal service interruption.
47.Qwest has established a control center , the Qwest CLEC
Coordination Center ("QCCC"), to coordinate all loop installations. Qwest created
the QCCC to improve the level of service on hot cuts. Mter observing the best
practices of other ILECs and customizing for Qwest use, Qwest invited the CLEC
community to review and suggest modifications to the QCCC's business
processes. 55/ The QCCC continues to improve performance through focused
operational analysis , continued CLEC feedback, and proposed Change Request
CR") activity. 56/ Approximately 100 Qwest employees work at the center, all
having completed unique and focused training. Mterthe establishment of the
54/ Exhibit WMC- LOOP-7 is the process flow for coordinated installation of new
loops, which includes a description of the tasks performed for these types of
installations. Exhibit WMC- LOOP-8 is the process flow for the coordinated
installation of an existing customer, commonly called a "hot cut." Page two of the
Exhibit defines the tasks, and page three is a sample of the data collected by Qwest
implementers to track the coordinated installation.
55/ Qwest invited the CLEC community to a forum dedicated to reviewing the
new hot cut procedures in the QCCC. The May 2001 session was a constructive
two.way dialogue modifying and clarifying the resulting processes for the QCCC
operation.
56/ CR# 5548229 is an example of a GLEe-submitted CR. This CR, accepted and
implemented by Qwest , allows CLECs to verbally change Connecting Facility
Assignment ("CF A") on an order to resolve CLECs' CF A assignment issues without
renegotiating a new due date. CR# 5548229 can be found on Qwest's web site , at
http://www .qwest.com/cmp/changereq uest.html.
- 24 -
Campbell Loops Declaration
QCCC in March 2001 , Qwest's performance for providing coordinated installations
improved significantly, as Exhibit WMC-LOOP-10 shows. In April 2002, the QCCC
assumed all control responsibility for installing unbundled loops.
48.On the order due date at the appointment time specified by the
CLEC, a QCCC coordinator coordinates activities between the CLEC and Qwest.
A call is placed to the CLEC to determine if the CLEC is ready for the service to be
transferred. If the CLEC is ready, Qwest central office and field work is performed.
If the CLEC indicates that it is not ready, Qwest will wait up to 30 minutes from
the appointment time. If the CLEC is still not ready, then a new appointment (date
and time) is scheduled. If Qwest misses the appointment time by 30 minutes or
fails to perform cooperative testing, due to Qwest's fault, Qwest will waive the non-
recurring installation charge. If Qwest fails to perform testing, Qwest will
reschedule the test at no charge to the CLEC if the CLEC still wishes to perform
cooperative testing. 57/
49.The first coordinated installation option is coordinated
installation without cooperative testing. On the due date, at the GLEe-designated
appointment time, the QCCC coordinator contacts the CLEC to ensure that they are
ready for the installation. The Qwest technicians complete the installation and
57/SGAT ~~ 9., 9.9.4.
- 25 -
Campbell Loops Declaration
work with the Qwest implementor/tester to complete the required performance
tests. The CLEC is verbally advised that the installation is complete. 58/
50.The second option is coordinated installation with cooperative
testing. This option permits the CLEC to request an appointment time as well as
joint testing with Qwest. When a CLEC requests a coordinated installation with
cooperative testing, Qwest will perform testing with the CLEC to ensure
connectivity between a CLEC's collocated equipment and its network demarcation
point. 59/ Cooperative testing is performed after the Qwest installation and testing.
The cooperative test is requested by the CLEC, and Qwest will assist in these tests
at the CLEC direction. As with basic installation with cooperative testing, Qwest
provides CLECs with an option to receive the Qwest test results via e-mail.
51.Qwest also offers project coordinated installation. This highly
synchronized form of coordinated installation permits the CLEC to obtain a
coordinated installation for unbundled loops with or without number portability
where the CLEC orders unbundled DS1-capable loops, DS3-capable loops, or 25 or
more DSO unbundled loops. Because of the increased collaboration between Qwest
and the CLEC with a project coordinated installation, Qwest and the CLEC must
negotiate the date and time for the installation in advance. Project coordinated
58/SGAT ~~ 9.9.4.9.4.
SGAT ~ 9.59/
- 26 -
Campbell Loops Declaration
installation was negotiated during the state workshop processes and can be added
to any CLEC interconnection agreement in Arizona. 60/
52.To perform a coordinated installation, both companies must be
ready at the same time on the scheduled due date. The activities that occur on the
due date are critical to the success of an "on time" installation. In order for a
coordinated installation to be considered on time, Qwest must perform the following
due date activities: contact the CLEC prior to starting the installation; complete
the Qwest physical work within a specified time period; and call the CLEC when
the job is completed.
53.When coordinated installations involve existing customers, they
are often referred to as "hot cuts." A hot cut involves a "lift and lay" procedure in
the central office: a Qwest technician removes the customer s line from a Qwest
switch and attaches it to a CLEC switch. At the QCCC, Qwest employs "hot cut
coordinators" who review hot cut orders for accuracy and are responsible for events
on the hot cut due date, including final verification of the order , calls to the central
office and the CLEC, the lift and lay, dial-tone verification, and notification of
completion. Qwest's commercial performance with respect to hot cuts has been
excellent and is discussed in the Commercial Performance Declaration of Dean
Buhler.
60/SGAT ~ 9.
- 27 -
Campbell Loops Declaration
54.Installation of Loops If No Compatible Facilities Exist. Qwest's
policies with respect to the construction of UNEs in Arizona are fully consistent
with the ACC's final order on unbundled loops. 61/ If a CLEC orders an unbundled
loop and compatible facilities are available, Qwest will perform incremental facility
work (i.e.conditioning, placing a drop, adding a network interface device , adding a
card to existing equipment in the central office or remote locations, adding central
office tie pairs , or adding field jumper cross-connects) if necessary to complete the
order. If the CLEC requests an unbundled loop and compatible facilities are not
available, the following process takes place: 62/
If an engineering job is pending that satisfies the request, Qwest
will accept the LSR and inform the CLEC of the ready-for-service
date.
If the LSR is requesting a loop to provide an end user with primary
voice grade service that would fall under Qwest's Provider of Last
Resort ("POLR") or Eligible Telecommunications Carrier ("ETC"
obligation, Qwest will accept the order and build the new facility.
If the request is for the unbundling of a loop supported by IDLC
technology, Qwest will accept the LSR and process it according to
the process described above for IDLC loops.
If the LSR does not fall into one of the above categories, Qwest
holds the order for 30 business days and continues to attempt to
assign compatible facilities. 63/ If a facility becomes available
during the 30 business day period, the order will be released and
installed for the retail or wholesale order. The availability of
61/ACC Loops Final Order ,-r,-r 56-62.
62/SGAT ~~ 9.1.2.1.3, 9.1.2.1.3., 9.1.2.1.3.
SGAT ~ 9.16.63/
- 28 -
Campbell Loops Declaration
facilities is on a first-come , first-served basis. The CLEC must
approve the activity prior to installation of the CLEC order. If after
30 business days compatible facilities still are not available, Qwest
will reject the order and inform the CLEC that no compatible
facilities exist. 64/ At any time, the CLEC has the option to request
the facilities according to the construction process outlined in the
SGAT.65/
55.In a petition for enforcement filed in WC Docket No. 02-314
CLECs recently raised concerns about Qwest's construction policies as they apply to
DS 1 loops. 66/ CLECs have raised the same concerns in Arizona and other states
Qwest's territory. In response , Qwest has agreed to provision DS1loops to CLECs
where existing DSO facilities can be used to construct new DS1 facilities. This
policy will remain in effect until rates for the construction of DS 1 loops from
existing DSO facilities can be developed. Any remaining CLEC concerns relating to
DS1100ps will be addressed in separate proceedings at the Commission and in the
states.
Maintenance and Repair Process
56.Consistent with Commission requirements, 67/ Qwest maintains
unbundled loops utilizing a defined maintenance and repair flow. 68/ A CLEC can
64/ After 30 business days the CLEC may submit a second order, and Qwest will
continue to attempt to assign compatible facilities for another 30-day period.
65/ SGAT ~ 9.19. In addition, Qwest provides notification of major facility builds
through the ICONN database. SGAT ~ 9.1.2.4.
66/ Petition for Enforcement Pursuant to Section 271 (d)(6) of the Act WC Docket
No. 02-314 (filed July 29, 2003).
67/See, e., Second Louisiana 271 Order 13 FCC Rcd at 20692 (~ 145).
- 29 -
Campbell Loops Declaration
report repair problems by issuing repair tickets or by calling Qwest's repair center.
Qwest creates a trouble ticket, which is processed using the same systems that are
used to process trouble tickets for Qwest retail services. The trouble ticket is passed
to the appropriate groups to analyze, test, and repair any Qwest problems that are
identified. The repair technician closes the ticket when the CLEC is notified that
the trouble is resolved. Qwest will also advise the CLEC if no trouble is found or if
the problem is not in the Qwest network.
57.Exhibit WMC- LOOP-9 is a flow chart that delineates the tasks
Qwest personnel perform to maintain unbundled loops. This Exhibit also includes a
matrix that describes each of the work tasks identified in the flow chart.
58.Qwest charges CLECs for trouble isolation only if the trouble is
isolated to the CLEC side of the Loop Demarcation Point or as otherwise provided
for in the CLEC's contract. 69/
59.Commercial Volumes. As of May 31 2003, Qwest had in service
719 unbundled loops for 14 CLECs in Arizona. (These figures represent stand-
alone loops only, not those provided as part of a UNE combination.) Specifically,
Qwest had in service 30 253 unbundled voice"grade analog loops, 5 578 xDSL-
capable loops, and 1 888 high-capacity loops. Qwest's performance in provisioning
68/SGAT ~ 9.
SGAT ~~ 9.69/
- 30.
Campbell Loops Declaration
and repairing these loops has been outstanding and is described in the Commercial
Performance Declaration of Dean Buhler.
III. THE ARIZONA COMMISSION HAS THOROUGHLY REVIEWED QWEST'S
UNBUNDLED LOOP OFFERINGS
60.The ACC has thoroughly reviewed Qwest's provisioning of
unbundled loops in an open and collaborative process. The first unbundled loop
workshop was held on March 5 2001. In addition to Qwest, parties participating in
the workshops included AT&T, MCI WorldCom, Sprint, Electric Lightwave , Inc.
spire, Eschelon Telecom, and Allegiance Telecom. Parties filed testimony and
comments between July 2000 and March 2001. An additional workshop was held
on May 14, 2001. Through the workshop process, all but eleven disputed unbundled
loop issues were resolved, with the appropriate changes made to the Arizona SGAT.
61.On February 20, 2002, ACC Staff filed a Final Report on Qwest's
Compliance with Unbundled Loops. After another round of comments by the
parties and a recommendation by an administrative law judge , the ACC issued its
final order on unbundled loops on May 17, 2002. 70/
62.Most of the significant impasse issues relating to unbundled
loops are described in this Declaration. However, two issues relating to loop
qualification are discussed in the pre-ordering section of the OSS Declaration of
Lynn M.V. Notarianni and Loretta A. Huff. Although other impasse issues arose in
70/CC Emerging Services Final Order.
- 31 -
Campbell Loops Declaration
the workshop processes relating to unbundled loops , they are not significant for
purposes of examining Qwest's Section 271 compliance , and Qwest is in full
compliance with the ACC's resolutions of each of them. 71/
IV. SUMMARY AND CONCLUSION
63.Qwest satisfies the unbundled loop requirements of Section
271(c)(2)(B)(iv). Qwest provides unbundled loops in a nondiscriminatory manner to
CLECs in Arizona. This Commission should therefore find that Qwest has satisfied
Checklist Item 4.
64.This concludes my Declaration.
71/ These issues are: 1) allegations of cooperative testing failures, on which the
ACC approved Qwest's position; 2) allegations of anticompetitive behavior by Qwest
employees, for which the ACC required a change to the SGAT that Qwest promptly
made; 3) reciprocity of trouble isolation charges, which the ACC determined had
been closed already, and 4) redesignation of interoffice facilities as loop facilities, on
which the ACC approved Qwest's policies but required a clarification of those
policies in the SGAT. ACC Loops Final Order ,-r,-r 87-104 111-17.
- 32 -
Campbell Loops Declaration
VERIFI CAT! ON
I declare under penalty of perjury that the foregoing is true and
correct. Executed on
off j)J-2003.
~II::
\ \ \DC . 6698310030 -17Z80SI vI
DIAGRAMS NOT SCANNABLE
SEE CASE FILE
BHCP - EXHIBIT 2
EXHIBITS 3, 4, 5
DIAGRAMS SEE FILE
BHCP - EXHIBIT 5
Unbundled Loop
ordered on DLC
systems
Utilize appropriate
cards for UBL circuit
or Line & station
transfer (LST) to
copper facilities for
UBL installation
Line & station
transfer (LST) as
required for UEL
installation
Establish, augment
or use existing INA
Digroup to install
UEL circuit
Unbundled Loop
using Hairpins, not
to exceed 3 at CO.
Yes
Note:
Manufacture Discontinued
(MD) COT equipment should
\IIDC 6b~/-'\911t~~$'d from Reuse stock
Note:
As a last resort, Hairpins can be used to
complete the installation of UBLs in very
small quantities (3 loops or less). This
method has been used by Qwest in the past
and remains a very difficult method, although
not recommended due to several severe
administrative complications. Use of Hairpins
reQuires Director level approval to proceed.
INA capability is only possible in
systems with Time Slot Interchange
(TSI) components.
Unbundled Loop
using Universal
Digroup D
Unbundled Loop
using 1/0 DCS
Unbundled Loop
using appropriate
COT equipment
(i., LS2000
SLC96, SER5
Legend for IDLC Flow
Solution provisioning intervals:
1) UBL circuit cards - 5 days
LST - 5 days
2) LST - 5 days
3) INA Digroup (D4 Channel Bank, dedicated DS1 ) - 5 days if span capacity
4) Order COT - 90 days - 120 days
5) 1/0 DCS (Adtran BR110) - 90 days -120 days
6) LS 2000, SLC 96, Series 5 - 90 days -120 days
7) Hairpin - 15 days after approval
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6
BHCP - Exhibit 7
Batch Hot Cut Process (BHCP) Requirements - Draft
General:
IDLC, OSP facilities with an EX designation and Line Splitting circuits will not be candidates
for the Batch conversions.
Batch conversions will utilize existing UNE-, CLEC or Retail facilities.
Basic Installation only on batch conversions
Coordinated and/or basic installation is still offered for business as usual activities - for
example - requests not identified as part of the conversion or a part of a project managed hot
cut.
Qwest Impacting:
Qwest will continue to perform a line verification test and issue a trouble ticket if trouble is
found to exist on the circuit prior to the conversion to UNE-Loop.
100 orders (total) per Central Office per day is the limit. (100 is the maximum per office
while 25 per central office is the minimum)
. RCMAC - Translations completed on Due Date ("DD"
. UNE-P with line splitting (511 in AZ, CO, MN, OR, W A) will not be included in the batch
conversion - Qwest will provide a list of those TNs (CLEC specific) where line splitting has
been deployed by the CLEC and these orders will be scheduled during normal business hours.
Once an LSR is submitted to Qwest, Qwest will produce a spreadsheet that contains the
following information: CLEC PON with 3 letter identifier (e.
, "
BHC"), Qwest order
number, TN, Qwest project ID #, valid CLEC CBR information
CLEC Impacting:
CLEC will interface with a Qwest representative(s) to negotiate order entry and the
prioritization of the Batch Hot Cut activity.
CLEC will be responsible for submitting LSR to Qwest - LSR must contain contact
information including CLEC contact number and email address.
PON number assigned will end in "BHC" to identify that the order is a part of the Batch Hot
Cut Process.
CLEC industry standard dial tone needs to be at the ICDF prior to DD.
If industry standard Dial Tone ("DT") is not present when a technician is ready to perform the
lift and lay, the order will be referred to the CLEC via a phone call for the CLEC to resolve.
The CLEC will have one hour to provide industry standard DT. If not resolved by the end of
conversion shift or tour, the order, and all lines associated with that specific order, will be
jeoped back to the CLEC and will have to be resubmitted following the normal process flow.
Batch clearing/closing of orders is via the Qwest provided spreadsheet and will be sent to the
CLEC provided email address.
CLEC must complete activation of their subscription for number porting upon notification of
order completion.
IfCLEC experiences trouble on the newly converted UNE-Loop within the rust 30 days, the
CLEC should contact the QCCC for resolution through the warranty group.
Proposed changes to the current hot cut process:
. CLEC requirements:
CLEC must provide/copy accurate end user service address ..
If industry standard dial tone is not available on DD, CLEC will have one hour to
resolve the issue or the order will be dropped from the BHCP.
Page 1 of 2
llLl~/;Q3 11 II /03
BHCP - Exhibit 7
Qwest Requirements
Qwest will pre-wire the CLEC jumper on due date not on DV A date (DD-2).
Qwest would submit a spreadsheet to the CLEC of the conversions by CO, by end user
etc. within 24 hours of receipt of the FOe.
Qwest will not perform the 48 hour pre-due date industry standard DT test in the CLEC's
switch terminations.
Qwest will only notify the CLEC of a no industry standard DT condition on the due date.
CLEC will be notified of the No DT condition on the DD (notification is by phone call)
and update in TlRKS OSSLOG once the order is jeop ed to new date.
DT/ANI test on CLEC switch termination and existing UNE-P terminations will take
place on the DD with COT updating TIRKS records upon order completion.
No email distribution of test results.
COT will no longer call to RCMAC to work the disconnect of the UNE-
The Central Office process will change to do the FOMs disconnect work the day after
the DD.
Central Office will only call the QCCC if translations are not completed.
QCCC performs batch close out of CLEC orders using the Qwest generated spreadsheet
via emai1. Close out is completed and is sent to CLEC designated email address.
LNP activation is verified by both Qwest and CLEC..
. A failure of one order within the batch does not constitute the failure of the entire batch
cut.
Page 2 of 2
11LL2i0:l 1l/l 1,'03