20050919Linse rebuttal.pdf

. \\/
E lJ
. lLED
T;.,
"",
Mary S. Hobson, ISB #2142
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise, ill 83702-5958
Telephone: [phone]
Facsimile: [phone]
?nos C'f:f) . U Wi;; ,.n. I Pl'it: 2
iftl ;~
--.
PUbllC
Ll i E~ COI"~ff..f
Thomas M. Dethlefs
Qwest Services Corporation
1801 California Street - 10th Floor
Denver, CO 80202-1984
Telephone: [phone]
Facsimile: [phone]
Attorneys Representing Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF LEVEL 3
COMMUNICATIONS, LLC'S PETITION FOR
ARBITRA TI ON PURSUANT TO SECTI ON
252(B) OF THE COMMUNICATIONS ACT
OF 1934, AS AMENDED BY THE
TELECOMMUNICATIONS ACT OF 1996,
AND THE APPLICABLE STATE LAWS FOR
RATE, TERMS, AND CONDITIONS OF
INTERCONNECTION WITH QWEST
CORPORATION
CASE NO. QWE-05-
TESTIMONY OF
PHILIP LINSE
QWEST CORPORATION
SEPTEMBER 16, 2005
(Disputed Issue Nos. 1 , 2, 3 , 6, 8 and 20)
Boise-186365.10061273-00018
TABLE OF CONTENTS
Page
IDENTIFICATION OF WITNESS ...................................................................
II.PURPOSE OF TESTIMONY .............................................................................
III.DISPUTED ISSUE NO.1: COSTS OF INTERCONNECTION ................... 2
IV.DISPUTED ISSUES NO. 2A AND 2 B: ALL TRAFFIC ON
INTERCONNECTION TRUNKS....................................................................
DISPUTED ISSUE NO.3: VNXX TRAFFIC ................................................. 21
VI.DISPUTED ISSUE NO.6: AMA SWITCH TECHNOLOGY..................... 30
VII. DISPUTED ISSUE NO.8: DEFINITION OF CALL RECORD ................. 31
VIII. DISPUTED ISSUE NO. 20: SIGNALING PARAMETERS ........................ 37
IX.SUMMARY/CONCLUSION ............................................................................
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page i
IDENTIFICATION OF WITNESS
PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND POSITION
WITH QWEST CORPORATION.
My name is Philip Linse. My business address is 700 West Mineral Avenue
Littleton Colorado. I am employed as Director - Technical Regulatory in the
Network Policy Organization. I am testifying on behalf of Qwest Corporation
Qwest"
ARE YOU THE SAME PHILIP LINSE THAT PROVIDED DIRECT
TESTIMONY IN THIS ARBITRATION?
Yes I am.
II.PURPOSE OF TESTIMONY
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to respond to the testimonies of Mr. Duc1oo and
Mr. Gates with respect to technical matters related to certain disputed issue
between the parties. My testimony will address the following issues from the
Matrix of Unresolved Issues filed by Level 3 in this arbitration:
Issue 1: Costs of Interconnection
Issue 2: Combining Traffic on Interconnection Trunks
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 1
Issue 3: VNXX Traffic
Issue 6: AMA and Switch Technology
Issue 8: Definition of Call Record
Issue 20: Signaling Parameters
In portions of my testimony that follow, where Level 3 proposes modifications to
Qwest's language, I have underlined the language that Level 3 wishes to delete or
add.
III.DISPUTED ISSUE NO.1: COSTS OF
INTERCONNECTION
Issue No. lA
PLEASE EXPLAIN DISPUTED ISSUE NO. lA.
Issue 1A involves disputed language regarding points of interconnection.
Level 3 mischaracterizes the issue as having to do with its right to interconnect at
a single point in the LATA and Qwest's obligation on its side of the point of
interconnection ("POI"). However Qwest does not dispute that Level 3 can
establish a single POI in a Qwest LATA. The POI is not the real issue here. The
real issue is whether Qwest should be required to provide interconnection where it
is not technically feasible or to provisionlbuild such transport facilities to Level 3
without compensation. My testimony will explain where Level 3 concurs with
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 2
Qwest, why this language is important from a technical perspective, and why
there is still dispute regarding this issue.
WHAT LANGUAGE DOES QWEST PROPOSE?
Qwest proposes the following language, which is also found on page 66 of the
proposed ICA filed by Qwest on June 28th, 2005 as a supplement to its initial
response to the petition for arbitration:
This Section describes the Interconnection of Qwest's network and
CLEC's network for the purpose of exchanging Exchange Service (EAS/Local
traffic), IntraLATA Toll carried solely by local exchange carriers and not by an
IXC (IntraLATA LEC toll), ISP-Bound traffic, and Jointly Provided Switched
Access (InterLATA and IntraLATA) traffic. Qwest will provide Interconnection
at any Technically Feasible point within its network. Interconnection, which
Qwest currently names "Local Interconnection Service" (LIS), is provided for the
purpose of connecting End Office Switches to End Office Switches or End Office
Switches to local or Access Tandem Switches for the exchange of Exchange
Service (EAS/Local traffic); or End Office Switches to Access Tandem Switches
for the exchange of IntraLA T A Toll carried solely by local exchange carriers and
not by an IXC (IntraLA T A LEC toll), or Jointly Provided Switched Access
traffic. Qwest Tandem Switch to CLEC Tandem Switch connections will be
provided where Technically Feasible. New or continued Qwest local Tandem
Switch to Qwest Access Tandem Switch and Qwest Access Tandem Switch to
Qwest Access Tandem Switch connections are not required where Qwest can
demonstrate that such connections present a risk of Switch exhaust and that Qwest
does not make similar use of its network to transport the local calls of its own or
any Affiliate s End User Customers.
WHAT LANGUAGE DOES LEVEL 3 PROPOSE?
Level 3 proposes the following:
This Section describes the Interconnection of Qwest's network and
CLEC's network for the purpose of exchanging Telecommunications Including
Telephone Exchange Service And Exchange Access traffic. Qwest will provide
Interconnection at any Technically Feasible point within its network.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 3
Establishment of SPOI: Qwest agrees to provide CLEC a Single
Point of Interconnection (SPOI) in each Local Access Transport Area (LATA) for
the exchange of all telecommunications traffic. The SPOI may be established at
any mutually agreeable location within the LATA, or, at Level 3' s sole option, at
any technically feasible point on Qwest's network. Technically feasible points
include but are not limited to Qwest's end offices, access tandem, and local
tandem offices.
Cost Responsibility. Each Party is responsible for constructing,
maintaining, and operating all facilities on its side of the SPOI, subject only to the
payment of intercarrier compensation in accordance with Applicable Law. In
accordance with FCC Rule 51. 703(b), neither Party may assess any charges on the
other Party for the origination of any telecommunications delivered to the other
Party at the SPOI, except for Telephone Toll Service traffic outbound from one
Party to the other when the other Party is acting in the capacity of a provider of
Telephone Toll Service, to which originating access charges properly apply.
3 Facilities included/transmission rates. Each SPOI to be established under
the terms of this Attachment shall be deemed to include any and all facilities
necessary for the exchange of traffic between Qwest's and Level 3' s respective
networks within a LATA. Each Party may use an Entrance Facility (EF),
Expanded Interconnect Channel Termination (EICT), or Mid Span Meet Point of
Interconnection (POI) and/or Direct Trunked Transport (DTT) at DS 1 , DS3 , OC3
or higher transmission rates as, in that Party s reasonable judgment, is appropriate
in light of the actual and anticipated volume of traffic to be exchanged. If one
Party seeks to establish a higher transmission rate facility than the other Party
would establish, the other Party shall nonetheless reasonably accommodate the
Party s decision to use higher transmission rate facilities.
1.4 Each Party Shall Charge Reciprocal Compensation for the
Termination of Traffic to be carried. All telecommunications of all types shall be
exchanged between the Parties by means of from the physical facilities
established at Single Point of Interconnection Per LATA onto its Network
Consistent With Section 51.703 of the FCC's Rules:
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 4
1.4.Level 3 may interconnect with Qwest at any technically feasible
point on Qwest's network for the exchange of telecommunications traffic. Such
technically feasible points include but are not limited to Qwest access tandems or
Qwest local tandems. When CLEC is interconnected at the SPOI. separate trunk
groups for separate types of traffic may be established in accordance with the
terms hereof. No separate physical interconnection facilities, as opposed to
separate trunk groups within SPOI facilities, shall be established except upon
express mutual agreement of the Parties.
THROUGHOUT HIS TESTIMONY MR. GATES SUGGESTS THAT
QWEST REQUIRES LEVEL 3 TO ESTABLISH MULTIPLE POlS PER
LATA. DOES QWESTREQUIRE MULTIPLE POlS PER LATA?
No. Qwest's proposed language does not force Level 3 to establish more than a
single POI per LATA.
MR. GATES ALSO SUGGESTS THAT QWEST WISHES TO MAKE
LEVEL 3 DUPLICATE QWEST'S NETWORK.DOES QWEST'
PROPOSED LANGUAGE FORCE LEVEL 3 TO DUPLICATE QWEST'
NETWORK?
No. Qwest's proposed language allows Level 3 to establish a single POI in each
LATA and provides Level 3 with multiple options to interconnect the Level 3
network with the Qwest network. Level 3's POI may be located at a Point of
Presence ("POP") location where its equipment is located, collocated within a
Qwest's Central office, or at a mid-way point between Level 3's POP and a
Qwest's central office. Level 3 can provision its own interconnection facilities
through Collocation in a Qwest central office or have Qwest provision entrance
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 5
facilities to Level 3' s POI located at its POP. A mid-span meet-point option is
also available where Qwest and Level 3 both build facilities to a meet-point near
the halfway point between Level 3's POP and Qwest's switch. None of these
interconnection options force Level 3 to duplicate Qwest's network.
IN HIS TESTIMONY, MR. GATES SUGGESTS THAT QWEST IS
REQUIRING LEVEL 3 TO INTERCONNECT AT EACH AND EVERY
SWITCH IN THE QWEST NETWORK.IS THAT AN ACCURATE
DESCRIPTION OF QWEST'S POSITION?
No. As I explained in my direct testimony, Level 3 has several options for
interconnection. Single Point of Presence ("SPOP") is a Qwest wholesale product
that provides Level 3 with Local Interconnection Service ("LIS") trunking that
allows as few as one trunk connection with Qwest's access tandem for the
delivery of local traffic. SPOP is provided over any of the interconnection facility
options my testimony describes above. This type of interconnection trunking has
been offered to and used by CLECs for several years.
IN HIS DIRECT TESTIMONY MR. GATES MISCHARACTERIZES A POI
AS BOTH THE PHYSICAL AND FINANCIAL DEMARCATION POINT.
PLEASE EXPLAIN THE DIFFERENCE BETWEEN A FINANCIAL
DEMARCATION POINT AND A PHYSICAL DEMARCATION POINT.
financial demarcation point is where financial responsibilities for network
facilities are divided. As I explained in my direct testimony, a POI is a physical
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 6
demarcation point between the Level 3 and Qwest networks. Although, the POI
is the physical location where networks interconnect, the financial responsibility
of the interconnection facilities is shared based upon the interconnection option
chosen.
IS LEVEL 3 OBJECTING TO ESTABLISHING INTERCONNECTION
WITH MULTIPLE SWITCHES IN QWEST'S NETWORK?
No. Mr. Ducloo states that Level 3 is willing to establish interconnection with
Qwest's local tandem switch for delivery of local traffic as well as with end office
switches when traffic volumes justify such direct trunking.
WHY SHOULD QWEST'S PROPOSED LANGUAGE BE ADOPTED?
Qwest'language more clearly and appropriately distributes the cost of
interconnection. As Mr. Ducloo states:
As a contractual matter, the parties agree that the cost of facilities used to
connect their networks will be split based on relative use, so that cost
responsibility follows in proportion to which party originates which
portion of traffic on the affected facilities.
Level 3' s proposed language does not reflect the testimony that has been given by
Mr. Ducloo. Level 3's proposed language does not even discuss the relative use
of the facilities. Accordingly, Qwest's language should be adopted since it is the
only language setting forth the terms of relative use.
Issue No. IB
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 7
WHAT LANGUAGE DOES QWEST PROPOSE?
PLEASE EXPLAIN DISPUTED ISSUE NO. lB.
Issue 1B involves disputed language for which Level 3 incorrectly proposes
methods of establishing a POI that are actually methods of interconnection.
Qwest proposes the following, as found on page 68 of its proposed ICA:
1.2 Methods of Interconnection
The Parties will negotiate the facilities arrangement used to interconnect their
respective networks. CLEC shall establish at least one (1) physical Point of
Interconnection in Qwest territory in each LATA CLEC has local Customers.
The Parties shall establish, through negotiations, at least one (1) of the following
Interconnection arrangements, at any Technically Feasible point: (1) a DS 1 or
DS3 Qwest provided facility; (2) Collocation; (3) negotiated Mid-Span Meet
POI facilities; or (4) other Technically Feasible methods of Interconnection, such
as an OCn Qwest provided facility, via the Bona Fide Request (BFR) process
unless a particular arrangement has been previously provided to a third party, or is
offered by Qwest as a product. OCn Qwest provided facilities may be ordered
through FCC Tariff No.
WHAT LANGUAGE DOES LEVEL 3 PROPOSE?
Level 3 proposes the following:
1.2 Methods of Interconnection
CLEC may establish a POI through: (1) a collocation site established by CLEC at
a Qwest wire center, (2) a collocation site established by a third party at Qwest
wire center, or (3) transport (and entrance facilities where applicable).
CLEC shall establish one POI at any technically feasible point on Qwest'
network within each LA T A in which CLEC desires to exchange traffic directly
with Qwest by any of the following methods:
a collocation site established by CLEC at a Qwest Wire Center
collocation site established by a third party at Qwest Wire
Center, or;
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 8
transport (and entrance facilities where applicable) ordered and
purchased by CLEC from Qwest; or
Fiber meet point.
CLEC shall establish one POI on Qwest's network in each LATA. POls may be
established by CLEC through:
a collocation site established by CLEC at a Qwest Wire Center
-------,._--- "
a collocation site established by a third party at Qwest Wire
Center
transport (and entrance facilities where applicable) ordered and
purchased by CLEC from Qwest at the applicable Qwest intrastate
access rates and charges; or
Fiber meet point.
HAVE LEVEL 3'WITNESSES ADDRESSED THE LANGUAGE
SPECIFIC TO THIS ISSUE?
No. Level 3' s witnesses do not specifically discuss either Level 3' s proposed
language or Qwest's proposed language. Level 3' s proposed language confuses
the methods of obtaining interconnection with establishment of its POI "within
Qwest's network. In contrast , Qwest's proposed language appropriately explains
how interconnection takes place and describes the methods that may be used for
interconnection.
WHAT ARE THE ARRANGEMENTS FORTHREETYPICAL
INTERCONNECTION?
I have attached exhibits 309, 310 and 311, which illustrate the options that Qwest
currently provides to enable Level 3 to interconnect its network with Qwest's
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 9
network. As I have explained in my direct testimony these methods include
Collocation, Entrance Facilities, and Mid-span Meet-point as well as any
technically feasible method of interconnection.
ARE THESE METHODS OF INTERCONNECTION AVAILABLE TO
LEVEL 3'S SINGLE POI IN THE LATA?
Yes. Each interconnection method may be used to interconnect Qwest' s network
with Level 3' s SPOI.
DOES QWEST REQUIRE LEVEL 3 TO PROVISION SEPARATE
FACILITIES TO ESTABLISH TRUNKING BETWEEN LEVEL 3'S POI
AND QWEST'S END OFFICES AS MR. DUCLOO CONTENDS IN HIS
DIRECT TESTIMONY?
Not at all. As I explained in my direct testimony, Qwest provides Direct Trunked
Transport ("DTT") so that Level 3 does not have to build separate facilities to
Qwest's end offices.Qwest's DTT product will provide Level 3 with the
appropriate trunking capacity so that Level 3 may establish interconnection
trunking with Qwest's end offices as needed by Level 3. DTT is provided to
Level 3 using Qwest's existing facilities and can be provisioned to Level 3'
single POI in the LATA.
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 10
IS MR. GATES CORRECT WHEN HE STATES THAT EACH CARRIER IS
REALLY ONLY ABLE TO CONTROL THE COSTS AND ACTIVITIES ON
ITS OWN NETWORK AND NOT ON THE OTHER PARTY'S NETWORK?
Absolutely not. Level3's interconnection imposes costs on Qwest's network, and
it requires Qwest to undertake additional activities to manage the interconnection.
Qwest is required to build/provision interconnection facilities to Level 3' s POI.
Although these costs are shared, there is no doubt that Qwest's costs are directly
impacted by the CLEC that requests interconnection. In addition, the ongoing
management of that interconnection imposes costs on Qwest'network.
Forecasting and trunk monitoring are merely two additional activities that Qwest
must take on when CLECs interconnect with Qwest. To say that each carrier only
controls the costs of its own network is simply wrong.
WHY SHOULD QWEST'S LANGUAGE BE ADOPTED?
Qwest language more appropriately reflects the interconnection between Qwest'
network and Level 3' s network. Unlike Level 3' s language, Qwest's language
does not confuse what is required to create a POI with what is realistically
required to interconnect two networks.
Issue No. IF
\PLEASE EXPLAIN DISPUTED ISSUE NO. IF.
Level 3 removes the language describing how Level 3 may interconnect at Qwest
local and access tandem switches. Level 3 also removes the requirement for
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 11
Level 3 to establish trunking as requested by Qwest where traffic volumes justify
alternate trunking.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, as found on page 81 of its proposed ICA:
The Parties shall terminate Exchange Service (EAS/Local) traffic
on Tandem Switches or End Office Switches. CLEC may interconnect at either
the Qwest local tandem or the Qwest access tandem for the delivery of local
exchange traffic.When CLEC is interconnected at the access tandem and when
there is a DSI level of traffic (512 BHCCS) over three (3) consecutive months
between CLEC' s Switch and a Qwest End Office Switch Qwest may request
CLEC to order a direct trunk group to the Qwest End Office Switch. CLEC shall
comply with that request unless it can demonstrate that such compliance will
impose upon it a material adverse economic or operations impact. Furthermore.
Qwest may ID:QPose to provide Interconnection facilities to the local Tandem
Switches or End Office Switches served by the Access Tandem Switch at the
same cost to CLEC as Interconnection at the Access Tandem Switch. If CLEC
provides a written statement of its objections to a Qwest cost-equivalency
illQPosal. Qwest may require it only: C&J!pon demonstrating that a failure to
so will have a material adverse affect on the operation of its network and (Q) upon
a finding that doing so will have no material adverse impact on the operation of
CLEC. as compared with Interconnection at such Access Tandem Switch.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
When CLEC is interconnected at the access tandem and when
there is a DSI level of traffic (512 BHCCS) over three (3) consecutive months
between CLEC's Switch and a Qwest End Office Switch Qwest may request
CLEC to order a direct trunk group to the Qwest End Office Switch.
Notwithstanding references to Qwest's ability to requests that CLECs order direct
trunk groups to the Qwest end office. nothing in this agreement shall be construed
to require CLEC to pay Qwest for any services or facilities on Qwest's side of the
POI in connection with the origination of traffic from Qwest to CLEC~ and
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 12
nothing herein shall be construed to require CLEC to pay for any services or
facilities on Qwest's side of the POI in connection with the termination of traffic
from CLEC by Qwest. other than reciprocal compensation payments as provided
in this Agreement.
WHY IS QWEST OPPOSED TO THE LEVEL 3 LANGUAGE?
As I explained in my direct testimony, Level 3 has removed the language that
specifies tandem switches and end office switches as points where traffic is
delivered. Level 3' s proposed language ignores the existing architecture of the
public switched network and creates ambiguity that may lead to later disputes
because there are no other locations on Qwest' s network where traffic may be
delivered.
DOES QWEST HAVE OTHER CONCERNS ABOUT LEVEL 3'
PROPOSED LANGUAGE FOR SECTION 7.
Yes. Although Level 3 also believes there is benefit in direct trunking, Level 3
holds to its originally proposed language that removes the requirement to
establish trunking to sub tending network switches when increases in traffic
volumes justify the alternate trunking. As discussed below, Level 3 admits to the
benefits of direct trunking, yet still proposes to remove the language that requires
this fundamental network management and maintenance process that benefits all
interconnecting carriers (including Level 3).
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 13
WHY DO YOU SAY LEVEL 3'S TESTIMONY ACKNOWLEDGES THE
REASONABLENESS OF QWEST'S LANGUAGE THAT REQUIRES
DIRECT TRUNKING TO AL TERNATE SWITCHES WHEN TRAFFIC
VOLUMES JUSTIFY?
The direct testimony of Mr. Ducloo explains that Level 3 sees the value in direct
trunking to alternate switches when traffic volumes justify. Mr. Ducloo states:
that when total traffic between Level 3 and a particular Qwest end office switch
reaches a certain reasonable volume, we (Level 3) will establish a direct trunk
group between that end office and Level 3." (Page 4 Lines 11-12) Mr. Ducloo
also agrees on page 37 of his direct testimony:
It is standard practice in the circuit-switched telephone industry to
establish direct trunks between switches when the level of traffic between
them exceeds a certain level. Given this, Level 3 is perfectly willing to
work with Qwest to avoid the problem of tandem overload by jointly
engineering separate trunk groups that go directly between Level 3 and
those Qwest end offices with enough traffic to justify the direct trunking.
These are known in the industry as "Direct End Office Trunks " or
DEOTs.
On page 38 of his testimony Mr. Ducloo states:
With DEOTs, even though the total number of trunks will be higher than
would be the case in a single massive trunk group, Qwest is able to avoid
the use of tandem switching and to cut down on the total number of trunk
ports it has to use. Level 3 is certainly willing to work with Qwest to
permit Qwest to obtain those network efficiencies.
In addition, Mr. Ducloo states on page 40:
What avoids exhausting Qwest's tandem is establishing DEOTs to carry
all the traffic from Level 3 to a Qwest end office on an efficient basis.
Level 3 is willing to do this.
QWE-O5-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 14
Finally Mr. Ducloo states on page 42:
As I note elsewhere in my testimony, Level 3 is not averse to establishing
multiple physical points of interconnection in a LATA when traffic levels
(emphasis added) and other factors so warrant. . .
Thus, Level 3 and Qwest agree on this issue. However, Level 3's proposed
language does not capture its agreement.
HAS LEVEL 3 PROVIDED ANY EXPLANATION WHY IT HAS
REMOVED THE QWEST PROPOSED LANGUAGE THAT PROVIDES
FOR THE TERMINATION OF TRAFFIC AND INTERCONNECTION AT
QWEST'S TANDEMS AND END OFFICES?
No. Level 3 has not provided any testimony explaining why Level 3 proposes to
delete Qwest's proposed language in section 7.
WHY SHOULD QWEST'S LANGUAGE BE ADOPTED?
Qwest's language for issue IF (section 7.6) should be adopted because it
more appropriately represents the positions of the parties as reflected in their
respective direct testimony.
IV. DISPUTED ISSUES NO. 2A AND 2 B: ALL TRAFFIC ON
, INTERCONNECTION TRUNKS
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 15
PLEASE EXPLAIN DISPUTED ISSUE NO.
Issue 2 concerns the types of traffic that may be combined over LIS trunks and
whether Qwest is entitled to compensation for the interconnection trunks that it
provides to Level 3.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest is proposing the following language, as found on page 79 of its proposed
ICA:
9.3.Exchange Service (EAS/Local), ISP-Bound Traffic IntraLATA
LEC Toll, VoIP traffic and Jointly Provided Switched Access (InterLATA and
IntraLATA Toll involving a third party IXC) may be combined in a single LIS
trunk group or transmitted on separate LIS trunk groups.
1 If CLEC utilizes trunking arrangements as described in Section
9.3., Exchange Service (EAS/Local) traffic shall not be combined with
Switched Access, not including Jointly Provided Switched Access, on the same
trunk group, i.e. Exchange Service (EAS/Local) traffic may not be combined with
Switched Access Feature Group D traffic to a Qwest Access Tandem Switch
and/or End Office Switch.
9.3.CLEC may combine originating Exchange Service (EAS/Local)
traffic, ISP-Bound Traffic, IntraLATA LEC Toll, VoIP Traffic and Switched
Access Feature Group D traffic including Jointly Provided Switched Access
traffic, on the same Feature Group D trunk group.
1 CLEC shall provide to Qwest, each quarter, Percent Local Use
(PLU) factor( s) that can be verified with individual call detail records or the
Parties may use call records or mechanized jurisdictionalization using Calling
Party Number (CPN) information in lieu of PLU, if CPN is available. Where
CLEC utilizes an affiliate s Interexchange Carrier (IXC) Feature Group D trunks
to deliver Exchange Service (EAS/Local) traffic with interexchange Switched
Access traffic to Qwest, Qwest shall establish trunk group(s) to deliver Exchange
Service (EAS/Local), Transit, and IntraLATA LEC Toll to CLEC. Qwest will
use or establish a POI for such trunk group in accordance with Section 7.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 16
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following language:
9.3.1 Where CLEC exchanges Telephone Exchange Service, Exchange
Access Service, Telephone Toll Service, and Information Services traffic with
Qwest over a single interconnection network, CLEC agrees to pay Qwest, on
Qwest's side of the POI, state or federally tariffed rates applicable to the facilities
charges for InterLATA and/or InterLATA traffic in proportion to the total amount
of traffic exchanged over such interconnection facility. Oth~rwise each party
remains 100% responsible for the costs of its interconnection facilities on its side
of the POI. Thus, by way of illustration only, where 20% of such traffic is
interLATA (intrastate and interstate) and the remaining 80% is Section 251(b)(5)
Traffic CLEC would pay Qwest an amount equal to 20% of the applicable
tariffed transport rate that would apply to a tariffed facility used solely for the
exchange of such access traffic for such traffic exchanged on Qwest's side of the
POI over a single interconnection trunk.
Except as expressly provided in Section 7.3 .1.1.3, each party shall bear all costs
of interconnection on its side of the network in accordance with 47 C.R. ~
51.703. Accordingly, unless otherwise expressly authorized according to Section
7.3.1.1.3 , neither Party may charge the other (and neither Party shall have an
obligation to pay) any recurring and/or nonrecurring fees, charges or the like
(including, without limitation, any transport charges), associated with the
exchange of any telecommunications traffic including but not limited to Section
251(b)(5) Traffic on its side of the POI.
Each party is solely responsible for any and all costs arising from or related to
establishing and maintaining the interconnection trunks and facilities it uses
connect to the POI. Thus, neither party shall require the other to bear any
additional costs for the establishment and operation of interconnection facilities
that connect its network to its side of the POI. If traffic is combined, Section
7.3.9 of this Agreement applies.
CLEC may combine Exchange Service (EAS/Local) traffic, ISP-
Bound Traffic, Exchange Access (IntraLATA Toll carried solely by Local
Exchange Carriers), VoIP Traffic and Switched Access Feature Group D traffic
including Jointly Provided Switched Access traffic, on the same Feature Group D
trunk group or over the same interconnection trunk groups as provided in Section
7.3.
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 17
HAS LEVEL SPECIFICALLY ADDRESSED THE PROPOSED
LANGUAGE THAT IS IN DISPUTE WITH ISSUE NO.
No. Level 3' s direct testimony never criticizes any specific Qwest language or
even explains its own specific language in any detail.
IS IT TRUE THAT QWEST WANTS LEVEL 3 TO PROVISION
SEPARATE TRUNK GROUPS AS STATED IN THE TESTIMONY OF MR.
DUCLOO?
No. In fact, Qwest has specifically proposed language (section 7.9.3.2) that
allows Level 3 to provision a single Feature Group D trunk group for the routing
of access and local traffic. Accordingly, Qwest is not an outlier on this issue as
Mr. Ducloo portrays Qwest to be.
IS MR. DUCLOO'S DIRECT TESTIMONY CORRECT WHERE HE
CONCLUDES THAT QWEST WOULD REQUIRE LEVEL 3 TO
ESTABLISH SEPARATE TRUNKS FOR IP-ENABLED TRAFFIC?
No. Qwest's proposed language does not require Level 3 to establish separate
trunks for IP-enabled traffic.
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 18
MR.DUCLOO ANALOGIZES THE TELECO MMUNI CA TI 0 NS
NETWORK TO A HIGHWAY AND EXPLAINS THAT IT WOULD BE
INEFFICIENT TO BUILD TWO HIGHWAYS NEXT TO EACH OTHER
BOTH GOING TO THE SAME PLACE. PLEASE COMMENT ON MR.
DUCLOO'SANALOGY.
Although it may seem inefficient to build two highways going to the same place
this is often done to provide people with transportation options. For example
there are often separate toll and non-toll highways. The characteristics of these
types of highways also resemble the way the telecommunications network works.
A toll highway operator has a method of collecting usage charges that is not used
by a non-toll highway operator. This is similar to the relationship between the
method for collecting usage charges for switched access trunking and local
trunking.Charges for switched access trunking are accomplished through
switched access billing.Qwest'local trunking does not have this same
capability. Level 3' s proposal to route switched access over local trunk groups
creates a difficulty analogous to the collection of usage charges on a non-toll
highway. On a non-toll highway there are no toll booths and thus no people to
take and record the toll charges.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 19
WOULD LEVEL 3 OBTAIN THE SAME TRUNK GROUP EFFICIENCIES
BY ROUTING LOCAL TRAFFIC TO FEATURE GROUP D ("FGD"
TRUNK GROUPS?
Yes. Level 3 would experience the same trunk group efficiencies by routing its
local traffic to Qwest over FGD trunking.
ARE THERE CIRCUMSTANCES WHERE LEVEL 3 IS WILLING TO
ESTABLISH FGD TRUNKING WITH QWEST?
Yes. Mr. Ducloo agrees that if Level 3 were to route its IXC traffic over LIS,
third party LECs would receive inadequate information to render access bills. Mr.
Ducloo s testimony agrees that Level 3 will send this traffic to Qwest's tandems
where adequate recording for the third parties can be made. The recordings that
Level 3 is referring to are the same recordings that are only provided via FGD
trunking. Thus, because Level 3 has agreed to use FGD trunking for the purposes
of delivering this third party traffic, there would be no reason that Level 3 would
have not to also route its local traffic to this same FGD trunking. Therefore, the
Commission should adopt Qwest's proposed language that allows Level 3 to route
local and access traffic over FGD trunking.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 20
DO THE DIRECT TESTIMONIES OF MR. DUCLOO AND MR. GATES
INCORRECTLY SPECULATE QWEST'ABILITY
EFFICIENTLY MANAGE ITS NETWORK'S TRUNK CAPACITY?
Yes. The testimony of Mr. Ducloo and Mr. Gates inappropriately and incorrectly
speculate that Qwest either over estimates network capacity demands or under
estimates network capacity demands, thus suggesting that Qwest does not
efficiently manage its network. Mr. Ducloo and Mr. Gates' speculation could not
be further from the truth. Qwest has processes and procedures to efficiently
maintain network capacities for both wholesale and retail network demand. In
addition, Qwest has quarterly forecasting meetings with CLECs so that network
capacity can be made available or decommissioned in a timely manner.
Furthermore, Qwest collaborated with CLECs and state commissions to create
Performance Indicator Definitions ("Pills ) regarding the provisioning of LIS.
For example, the Ordering and Provisioning ("OP") Pills provide measurement of
Qwest'ability to provision service in an efficient manner.Where Pill
Measurements are not met, Qwest's Performance Assurance Plan ("PAP"
triggers a self executing payment to CLECs and/or state commissions.
DISPUTED ISSUE NO.3: VNXX TRAFFIC
PLEASE EXPLAIN DISPUTED ISSUE NO. 3B.
Issue number 3B concerns the agreement's definition of VNXX traffic. My
testimony will reply to Level 3's testimony on this issue.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 21
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, as found on page 33 of its proposed ICA:
VNXX Traffic" is all traffic originated by the Qwest End User Customer that is
not terminated to CLEC's End User Customer physically located within the same
Qwest Local Calling Area (as approved by the state Commission) as the
originating caller, regardless of the NPA-NXX dialed and, specifically, regardless
of whether CLEC's End User Customer is assigned an NPA-NXX associated with
a rate center in which the Qwest End User Customer is physically located.
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
VNXX Traffic shall include the following:
ISP-bound VNXX traffic is telecommunications over which the FCC has
exercised exclusive jurisdiction under Section 201 of the Act and to which traffic
a compensation rate of $0.0007 / MOU applies. ISP-bound VNXX traffic uses
geographically independent telephone numbers ("GITN"), and thus the telephone
numbers associated with the calling and called parties mayor may not bear NP A-
NXX codes associated with the physical location of either party. This traffic
typically originates on the PSTN and terminates to the Internet via an Internet
Service Provider ("ISP"
V oIP VNXX traffic is telecommunications over which the FCC has exercised
exclusive jurisdiction under Section 201 of the Act and to which traffic a
compensation rate of $0.0007 / MOD applies. VolP VNXX traffic uses
geographically independent telephone numbers ("GITN"), and thus the telephone
numbers associated with the calling and called parties mayor may not bear NP A-
NXX codes associated with the physical location of either party. Because VolP
VNXX traffic originates on the Internet, the physical location of the calling and
called parties can change at any time. For example, VolP VNXX traffic presents
billing situations where the (i) caller and called parties are physically located in
the same ILEC retail (for purposes of offering circuit switched "local telephone
service ) local calling area and the NP A-NXX codes associated with each party
are associated with different ILEC LCAs; (ii) caller and called parties are
physically located in the same ILEC retail (for purposes of offering circuit
switched "local telephone service ) local calling area and the NP A-NXX codes
associated with each party are associated with the same ILEC LCAs; (iii) caller
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 22
and called parties are physically located in the different ILEC retail (for purposes
of offering circuit switched "local telephone service ) local calling area and the
NPA-NXX codes associated with each party are associated with same LEC
LCAs; and (iv) caller and called parties are physically located in the different
ILEC retail (for purposes of offering circuit switched "local telephone service
local calling area and the NP A-NXX codes associated with each party are
associated with different ILEC LCAs. Examples of VoIP VNXX traffic include
the Qwest "One Flex" service and Level3's (3)VoIP Enhanced Local service.
Circuit Switched VNXX traffic is traditional "telecommunications services
associated with legacy circuit switched telecommunications providers, most of
which built their networks under monopoly regulatory structures that evolved
around the turn of the last century. Under this scenario, costs are apportioned
according to the belief that bandwidth is scarce and transport expensive. The
ILEC offers to a customer the ability to obtain a "local" service (as defined in the
ILEC's retail tariff) by paying for dedicated transport between the physical
location of the customer and the physical location of the NP A-NXX. Thus, this
term entirely describes a service offered by ILECs, but which cannot be offered
by IP-based competitors as such networks do not dedicate facilities on an end-to-
end basis.
DID YOU ADDRESS VNXX IN YOUR DIRECT TESTIMONY?
No. Mr. Brotherson addressed VNXX issues in his direct testimony. However, I
am addressing VNXX here because of inconsistencies and inaccuracies in the
testimony filed by Level 3' s witnesses.
MR. GATES EXPLAINS THAT ISPS PURCHASE SERVICES FROM
CARRIERS IN THE LOCAL CALLING AREAS WHERE THEY HAVE OR
DESIRE CUSTOMERS. DOES LEVEL 3 PROVIDE SERVICE TO ISPS IN
THESE SAME LOCAL CALLING AREAS?
No. Level 3 does not, in most cases, provide services to its ISP customers within
the local calling areas that ISPs have or desire customers. By that I mean that
Level 3 has no physical presence (nor do its ISP customers) in many (probably the
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 23
vast majority) of the local calling areas where they purport to serve. Instead
Level 3 inappropriately assigns telephone numbers to its ISP customers that do
not reflect the local calling area in which the ISP is located, thereby allowing
Level 3 to avoid (and pass on to Qwest) the additional costs associated with
provisioning local service to its ISP customers. By doing this, Level 3 avoids
actually provisioning facilities-based services to the local calling areas in which
Level 3 claims to provide local service.
DOES LEVEL 3 VIOLATE INDUSTRY GUIDELINES BY ASSIGNING
TELEPHONE NUMBERS IN THE WAY YOU HAVE DESCRIBED?
Yes. There are industry rules that dictate the different types of telephone numbers
and how such numbers are to be assigned.
HOW WERE THE RULES FOR ASSIGNING TELEPHONE NUMBERS
EST ABLISHED?
In 1995, prior to the passage of the 1996 Act, the FCC created the North
American Numbering Council ("NANC"), which makes recommendations to the
FCC on numbering issues and oversee the North American Numbering Plan
NANP"At the same time, the FCC also created the North American
Numbering Plan Administrator ("NANP A"), an impartial entity that is responsible
for assigning and administering telecommunications numbering resources in an
efficient and non-discriminatory manner.Thus NANP is responsible for
allocating NP and NXX codes. Under FCC rules, NANP A is directed to
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 24
administer telephone numbering resources in an efficient and non-discriminatory
manner and in accordance with the guidelines developed by INC (the North
American Industry Numbering Committee).
ARE THE "GUIDELINES" DEVELOPED BY INC INTENDED TO BE
MERE GUIDELINES THAT CAN BE DISREGARDED?
No. INC guidelines are really more than mere guidelines because the adherence
to them is an FCC mandate.2 The Alliance for Telecommunications Industry
Solutions (A TIS) has published a set of INC guidelines entitled "Central Office
Code (NXX) Assignment Guidelines (COCAG)." Level 3's method of assigning
telephone numbers (i., its use of VNXX) is in violation of these industry
guidelines, which designate NP A-NXX codes as geographically-specific.
WHAT PROVISIONS OF THE COCAG DEFINE NPANXX CODES AS
GEOGRAPHICALLY SPECIFIC?
Section 2.14 of the COCAG states that "CO (central office) codeslblocks
allocated to a wire line service provider are to be utilized to provide service to a
customer s premise physically located in the same rate center that the
codeslblocks are assigned. Exceptions exist, such as for tariffed services like
foreign exchange services." (Emphasis added.) Mr. Gates ' direct testimony at
47 C.R. ~ 52.13(b) and (d)
47 C.R. 952.13(d)
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 25
page 39 references this section.However VNXX is not identified as an
exception, and is certainly not an "exception" as it is provisioned by Level 3
without provisioning local service in the rate center to which the codes/ blocks are
assigned.
ARE THERE OTHER PROVISIONS IN THE COCAG THAT SPECIFY A
GEOGRAPHIC CORRELATION WITH TELEPHONE NUMBERS?
Yes. Section 4.6 of the COCAG provides that "(t)he numbers assigned to the
facilities identified must serve subscribers in the geographic area corresponding
with the rate center requested.(Emphasis added.
DOES THE COCAG DISTINGUISH BETWEEN GEOGRAPHIC NUMBERS
AND NON-GEOGRAPHIC NUMBERS?
Yes. The COCAG also states that "Geographic NP As" are the "NP As which
correspond to discrete geographic areas within the NANP" while
Non-geographic NP As" are "NP As that do not correspond to discrete geographic
areas, but which are instead assigned for services with attributes, functionalities
or requirements that transcend specific geographic boundaries, the common
examples (of which) are NPAs in the NOO format, e., 800.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 26
DOES LEVEL 3 APPROPRIATELY ASSIGN TELEPHONE NUMBERS TO
ITS CUSTOMERS OF VNXX SERVICE ACCORDING TO INC
GUIDELINES?
No. The telephone numbers that Level 3 use are geographic NPA numbers - in
other words, they are numbers that should, according to guidelines, correspond to
discrete geographic areas. But under Level 3' s inappropriate assignment of these
numbers, they no longer reflect a specific geographic location. Callers who dial a
Level 3 "local" number would not reach anyone in the local calling area - rather
they would be transported over Qwest' s LIS network to Level 3' s switch, and
then on to an ISP's equipment (e., modems, routers, and servers) that may be in
a different local calling area in the state, or in another state entirely. This use of
numbers violates industry guidelines.
DOES LEVEL 3'S PERSPECTIVE OF ITS VNXX SERVICE COMPORT
WITH THE INDUSTRY NUMBERING GUIDELINES?
Not at all. As explained above, the industry numbering guidelines recognize that
there are numbers that are geographic in nature and others that are non-geographic
in nature.The determination whether a NP A/NXX is geographic or
non-geographic is based on the NP digits that precede the NXX digits.
Geographic numbers are the telephone numbers that most people associate with
their wireline service. Non-geographic numbers are telephone numbers that have
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 27
NP A digits such as 800 or 900. However, Level 3 has inappropriately used
geographic numbers to facilitate a non-geographically provisioned service.
IS THE DIRECT TESTIMONY OF MR. GATES CORRECT WHEN HE
EQUATES THE ROUTING OF VNXX TRAFFIC TO THAT OF FX
TRAFFIC?
No. Mr. Gates incorrectly equates VNXX calls with foreign exchange ("FX"
calls. Mr. Gates fails to recognize that non-VNXX calls, such as those placed to a
subscriber of FX service, are assocrated with services that are provisioned from
within the local calling area where the traffic originates. For example, the FX call
that originates with an end user in local calling area (LCA) A but is destined for
an end user located in LCA B is actually placed by dialing a number associated
with local service physically provisioned in LCA A. The call is routed to an FX
service in LCA A, where it is then transported to LCA B.The end user
subscribing to FX service in this example must establish local service in LCA A
and pay rates that are intended to cover the additional costs associated with
transporting the call from LCA A to LCA B. In contrast, with Level 3's VNXX
service, Level 3 simply assigns numbers to its customers that are associated with
wire centers outside the end user s local calling area. In doing so, Level 3'
VNXX service relies on Qwest to the transport the traffic between local calling
areas. Level 3 incorrectly asserts that Qwest must provide this transport to Level
3 for free, ostensibly because the transport is on Qwest's side of the POI.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 28
MR. DUCLOO CONTENDS THAT SWITCHES HAVE NO WAY OF
KNOWING THE GEOGRAPHIC LOCATIONS ASSOCIATED WITH THE
PHONE NUMBERS ASSIGNED TO A SWITCH. DOES MR. DUCLOO
MISREPRESENT HOW NUMBERS ARE ASSIGNED?
Yes. If Mr. Ducloo s method of assigning telephone codeslblocks to switches
were taken to its logical conclusion, all switches should recognize all telephone
numbers as local calls. Mr. 'Ducloo misses the concept that a switch only
knows" what is programmed into it. Switch programming determines what is
local and what is toll. This programming is based on decades of regulatory
precedent that distinguished local and toll calls based on geographic boundaries
such as local calling area EAS boundaries and LATA boundaries.These
geographic boundaries are either established by federal courts, approved by the
state commissions, or otherwise provided for under state law, and they remain a
significant feature of the telecommunications environment in which all industry
participants operate today.To imply that geographic location makes no
difference is absurd. The history of the telecommunications industry and its
method of regulation are fundamentally based on the geographic location of end
users.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 29
AL THOUGH LEVEL 3'S TESTIMONY DOES NOT ADDRESS MOST OF
MR.DUCLOO'EXHIBITS, DO THE EXHIBITS CORRECTL Y
REPRESENT THE FX SERVICE THAT QWEST PROVIDES?
No. RRD #10 does not correctly represent FX service. Mr. Ducloo only depicts
local service provisioned to customers within each LCA and not FX service. Mr.
Ducloo also attempts to depict FX service provisioned using multiple switches
including tandem switches. Switching for Qwest FX service is never provisioned
using switching other than that provided by the switch from which local service is
purchased by the subscriber. In addition, exhibits RRD #11 and #13 are labeled
as local service but depict non-local call flows.
Furthermore, Mr. Ducloo exhibits are not consistent with Level 3's own
advocacy. On exhibit RRD #15, Level 3 shows Qwest as being compensated for
its transport to the CLEC switch but, as is described in the discussion of Issue
No., Level 3 argues that Qwest must pay for this transport outside of the local
calling area since it is on Qwest's "side" of the POI.
VI.DISPUTED ISSUE NO.6: AMA SWITCH TECHNOLOGY
PLEASE EXPLAIN DISPUTED ISSUE NO.
This issue was never a point of contention during the negotiation of the
interconnection agreement and only became an issue when Level filed its
petition. Level 3 also did not address this language in its direct testimony. The
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 30
issue in dispute is Level 3's objection to use the term "inherent in Switch
technology" within the definition of Automated Message Accounting ("AMA"
Level 3 disputes the use of the language "inherent in Switch technology.
DOES QWEST STILL AGREE WITH LEVEL 3'S PROPOSED LANGUAGE
CHANGE?
Yes. This is no longer an issue.
VII.DISPUTED ISSUE NO.8: DEFINITION OF CALL
RECORD
PLEASE EXPLAIN DISPUTED ISSUE NO.
Disputed issue No.8 concerns what call information must be provided in a call
record so that the record may be used for intercarrier billing purposes. Level 3
agrees that there are some instances when some signaling information may not
always be available. Nevertheless, a call record must include certain fundamental
information to create a record for billing purposes.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, as found on page 13 of its proposed ICA:
Call Record" means a record that provides key data about individual telephone
calls. It includes originating telephone number, terminating telephone number
billing telephone number (if different from originating or terminating number)
time and date of call, duration of call, long distance carrier (if applicable), and
other data necessary to properly rate and bill the call.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 31
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
Call Record" shall include identification of the following: charge number
Calling Party Number ("CPN"), Other Carrier Number ("OCN"), or Automatic
Number Identifier ("ANI"), Originating Line Indicator ("OLI"
).
In the
alternative, a "Call Record" may include any other information agreed upon by
both Parties to be used for identifying the jurisdictional nature of the calling party
or for assessing applicable intercarrier compensation charges.
WHY IS QWEST OPPOSED TO LEVEL 3'S PROPOSED DEFINITION OF
A CALL RECORD?
Level 3' s definition of a call record obligates both parties to provide certain types
of information about a call that has never been required by industry standards and
that may not be available on every call. Level 3' s proposed language would
require call information that is not necessary for the creation of a call record and
yet it omits information that should be required for the creation of a call record.
DO LEVEL 3'S WITNESSES ADDRESS LEVEL 3'S DEFINITION OF
CALL RECORD IN THEIR TESTIMONY?
No not specifically. Mr. Ducloo only addresses it to the extent that Level 3
proposes to populate the OLI parameter in the signaling stream and in a brief
discussion of the process for billing intercarrier compensation.Level 3
otherwise silent on what information should be required in a call record.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 32
DOES MR. DUCLOO DESCRIBE THE INFORMATION THAT SHOULD
BE CONTAINED IN A CALL DETAIL RECORD?
Yes. In his direct testimony, Mr. Ducloo describes information that is consistent
with Qwest's definition of a call record. For example, Mr. Ducloo lists calling
number (i.e. originating telephone number), the dialed number (i.e. terminating
telephone number), carrier delivering the call (i.e. long distance carrier) and the
time that the call starts and stops (i.e. time and date of call, duration of call) as
appropriate for inclusion in a call detail record. These are also elements in
Qwest's proposed call record definition. However, Level 3's proposed definition
does not include all of the elements that Mr. Ducloo listed in his testimony.
Based on Level 3's testimony, it is clear that Qwest's proposed definition of call
record more appropriately represents the fundamental information that belongs in
a call record.
IN HIS DIRECT TESTIMONY, MR. DUCLOO CONCLUDES THAT
THERE ARE PRECEDENTS FOR POPULATING UNUSED SS7 FIELDS
AND CODES.HAS QWEST POPULATED UNUSED SIGNALING
PARAMETERS OR REQUIRED INTERCONNECTING CARRIERS TO
POPULATE UNUSED SIGNALING PARAMETERS THAT ARE
UNDEFINED BY THE INDUSTRY?
No. Qwest has not established these types of processes because of the future
impact they could have to Qwest's network should particular unused parameters
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 33
become defined differently by the industry over time. If a signaling parameter
were to become defined differently by the industry than the way network
operators have decided to use the parameter, then the operators would need to
change their network to be compliant with the industry change. They would then
need to find a new way to accomplish the original purpose for populating the
unused signaling parameter. Using signaling parameters in the way that Level 3
proposes would only cause unnecessary up-front costs and would magnify future
costs should any changes need to be made to the network in the future.
DOES MR. DUCLOO THEN PROVIDE A PRECEDENT FOR THE
POPULATION OF UNUSED SS7 FIELDS?
No. Mr. Ducloo provides an example of population of a call record, but not
population of a signaling parameter.
HAVE INDUSTRY ST ANDARDS GROUPS RECOMMENDED THE OLI
PARAMETER BE USED TO IDENTIFY VOIP TRAFFIC?
No. In fact industry standards groups such as the AMA Technical Support Group
AMASTG") have recommended against the use of the OLI signaling parameter
for the purposes of identifying VoIP traffic.3 Identification of VoIP traffic though
3 Exhibit 312 Letter dated February 4th 2005 from the AMASTG to the Alliance for
Telecommunications Industry Solutions Ordering and Billing Forum Billing Committee
Subject OBF Issue 2776: Identification ofVoIP-Originated Calls.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 34
the signaling stream is only one of several proposals that the industry has
identified.4 Furthermore, the signaling standards committee does not recommend
modification to the SS7 protocol to address the identification of VoIP traffic.
Based on the activity at the industry level, it is clear that the issue of developing a
method for identifying VoIP traffic is being addressed. Level 3 , however, wishes
to include the OLI as a method of identifying VoIP in its agreement with Qwest.
Thus, Level 3 is attempting to create a de facto standard that appears to have been
all but dismissed by industry standards groups. It would be more appropriate for
Level 3 to represent its position in the industry standards forums that have been
established to address these types of issues than attempting to unilaterally force
its industry rejected opinion through an interconnection agreement.
DOES LEVEL 3'S LANGUAGE FORCE QWEST TO POPULATE THE OLI
PARAMETER?
Yes. Although the testimony of Mr. Ducloo suggests that it is only Level 3 that
wishes to populate the OLI parameter, Level 3' s proposed call record definition
4 Exhibit 313 Letter dated May 9th 2005 from the Alliance for Telecommunications
Industry Solutions Ordering and Billing Forum Billing Committee to the Alliance for
Telecommunications Industry Solutions Packet Technologies and Systems Committee
PTSC"), Subject OBF Issue 2776: Identification ofVoIP-Originated Calls.5 Exhibit 314 Letter dated June, 23 2005 from the PTSC to the OBF Subject OBF Issue
2776: Identification ofVoIP-Originated Calls.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 35
language does not make this distinction. Accordingly, Level 3' s definition of call
record should be rej ected.
WHY SHOULD QWEST'S DEFINITION OF CALL RECORD BE USED IN
THE INTERCONNECTION AGREEMENT BETWEEN LEVEL 3 AND
QWEST?
Qwest's definition of call record should be used because it includes the
fundamental information that is required to create a valid call record and provides
flexibility to include other data that may be used to rate and bill calls for
intercarrier compensation purposes.In addition, Qwest uses terms that are
specific enough to identify what is required while at the same time remaining
flexible enough to encompass all of the optional parameters that Level 3 wishes to
require should they eventually become industry requirements. Unlike Level 3'
language, Qwest's language does not include call information that would create
disputes regarding the interpretation of the terms used in the definition. Likewise
Qwest's language eliminates any potential dispute as to whether the existence of
the call duration and the time and date that a call occurred are required in a valid
call record. Simply put, Qwest language addresses all of Level 3' s concerns
more clearly establishes the expectations of both companies for the creation of a
valid call record, and has the flexibility to include additional call information that
may later be required to generate a valid call record in the future.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 36
VIII. DISPUTED ISSUE NO. 20: SIGNALING PARAMETERS
PLEASE EXPLAIN DISPUTED ISSUE NO. 20.
The issue in dispute here is whether SS7 signaling is an appropriate method for
signaling call information for the exchange of traffic between Qwest and Level 3.
WHAT LANGUAGE IS QWEST PROPOSING?
Qwest proposes the following, on page 88 of its proposed ICA:
7.3.Signaling Parameters: Qwest and CLEC are required to provide each
other the proper signaling information (e., originating Calling Party Number and
destination called party number, etc.per 47 CFR 64.1601 to enable each Party to
issue bills in a complete and timely fashion. All CCS signaling parameters will
be provided including Calling Party Number (CPN), Originating Line Information
Parameter (OLIP), calling party category, Charge Number, etc. on calls to 8XX
telephone numbers. All privacy indicators will be honored. If either Party fails to
provide CPN (valid originating information), and cannot substantiate technical
restrictions (i.e..MF signaling) such traffic will be billed as Switched Access.
Traffic sent to the other Party without CPN (valid originating information) will be
handled in the following manner. The transit provider will be responsible for only
its portion of this traffic, which will not exceed more than five percent (5%) of the
total Exchange Service (EAS/Local) and IntraLA T A Toll carried solely by local
exchange carriers and not by an IXC (IntraLA T A LEC toll) delivered to the other
Party. The Switch owner will provide to the other Party, upon request
information to demonstrate that Party s portion of no-CPN traffic does not exceed
five percent (5%) of the total traffic delivered. The Parties will coordinate and
exchange data as necessary to determine the cause of the CPN failure and to assist
its correction. All Exchange Service (EAS/Local) and IntraLA T A LEC Toll calls
exchanged without CPN information will be billed as either Exchange Service
(EAS/Local) Traffic or IntraLA T A LEC Toll Traffic in direct proportion to the
minutes of use (MOU) of calls exchanged with CPN information for the
preceding quarter, utilizing a PLU factor determined in accordance with Section
2 of this Agreement.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 37
WHAT LANGUAGE IS LEVEL 3 PROPOSING?
Level 3 proposes the following:
7.3.8 Signaling Parameters: Qwest and CLEC are required to provide each other
proper signaling information (e., originating Calling Record Information and
destination called party number, etc.) to enable each Party to issue bills in a
complete and timely fashion. All CCS sIgnaling parameters will be provided
including Call Record Information (CRI), Originating Line Information Parameter
(OLIP) on calls to 8XX telephone numbers, calling party category, Charge
Number, etc. All privacy indicators will be honored. If either Party fails to
provide CRI (valid originating information), and cannot substantiate technical
restrictions
(~,
MF signaling, IP origination. etc.) such traffic will be billed as
interstate Switched Access. Transit Traffic sent to the other Party without CRI
(valid originating information) will be handled in the following manner. The
transit provider will be responsible for only its portion of this traffic, which will
not exceed more than five percent (5%) of the total Exchange Service
(EAS/Local) and Exchange Access (IntraLATA Toll) traffic delivered to the other
Party. The Switch owner will provide to the other Party, upon request
information to demonstrate that Party s portion of no-CRI traffic does not exceed
five percent (5%) of the total traffic delivered. The Parties will coordinate and
exchange data as necessary to determine the cause of the CRI failure and to assist
its correction. All Exchange Service (EAS/Local) and Exchange Access calls
exchanged without CRI information will be billed as either Exchange Service
(EAS/Local) Traffic or Exchange Access Traffic in direct proportion to the
minutes of use (MOU) of calls exchanged with CRI information for the preceding
quarter, utilizing a PLU factor determined in accordance with Section 7.9.3.
of this Agreement.
DID LEVEL 3 ADDRESS THIS SECTION IN ITS TESTIMONY?
No. None of Level 3's witnesses have provided testimony in support for its
proposed language for section 7.3.
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 38
PLEASE DESCRIBE AGAIN WHY QWEST OBJECTS TO LEVEL 3'
PROPOSED LANGUAGE?
Qwest objects to Level 3?s language because it mischaracterizes IP origination
(emphasis added) as a technical limitation for populating signaling information in
the SS7 signaling stream. Level 3's proposed language also creates an obligation
to populate a signaling parameter, specifically Call Record Information ("CRI"
which does not exist within the SS7 protocol. In addition, Level 3 does not define
CRI. To the extent that Level 3's definition of CRI would use similar terms to
those used in Level 3' s definition of a Call Record, it is not at all clear that the
requirement to provide the CRI can be met. Level 3' s proposed language also
fails to acknowledge the fact that the FCC has recognized certain limitations exist
that prohibit or limit the delivery of specific types of signaling information.
Qwest further objects to Level 3 language because it inappropriately applies
interstate switched access rates to traffic that is intrastate as is described in Issue
No.
WHY IS QWEST'S LANGUAGE MORE APPROPRIATE?
Qwest's language uses terms that are clearly defined by the contract and the
industry. Qwest language provides clear expectations for the signaling of traffic
between the parties ' networks that are consistent with industry standards.
IX.SUMMARY/CONCLUSION
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 39
PLEASE SUMMARIZE YOUR TESTIMONY.
My testimony has responded to the testimony of Level 3' s witnesses relating
technical matters concerning: 1) the manner of interconnection; 2) the types of
traffic that may be combined on interconnection trunks;3) the appropriate
assignment of telephone numbering resources and the associated routing of local
calls; and 4) the call information that should be required in a call record.
The FCC has recognized that each carrier must be able to retain responsibility for
the management, control, and performance of its own network. Qwest provides
technically feasible points for the purpose of interconnection with Qwest'
network. However, Level 3' s proposed language attempts to shun these well
established arrangements, not for technical reasons, but in an apparent attempt to
avoid paying the cost that interconnection inevitably imposes on the existing
network.
Qwest has attempted to be responsive to Level 3' s desire to combine traffic on
trunk groups. Qwest has attempted to accommodate Level 3' s desire for network
efficiencies by agreeing to allow Level 3 to combine all of its traffic to Qwest
over Feature Group D trunks. This solution achieves the efficiencies sought by
Level 3 while at the same time allowing Qwest to continue to use its existing
billing systems and processes. For these reasons, Level 3's proposed combining
of traffic on LIS trunks should be rejected.
QWE-05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 40
The FCC and state commissions have recognized certain jurisdictional boundaries
for telecommunications traffic.These jurisdictional boundaries have been
incorporated into virtually every aspect of the telecommunications network, from
the routing of traffic and provisioning of facilities to end users to the
interconnection of carriers with other carriers. Accordingly, until industry wide
changes are made, the Level 3/Qwest interconnection agreement should continue
to require that the assignment of telephone numbers be based on the local calling
areas associated with those numbers.
Finally, a call record must include certain fundamental information to create a
record for billing purposes. Qwest' s definition provides for all the fundamental
information needed in a call record, and, at the same time, it provides the
flexibility to accept additional information to create a call record that may be used
for billing. Level 3 goes far beyond what is recognized by the industry and then
inappropriately places financial penalties for non-compliance.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes it does.
QWE- T -05-
September 16, 2005
Linse, (REB)
Qwest Corporation
Page 41
CERTIFICATE OF SERVICE
I hereby certify that on this 16th day of September, 2005, I served the foregoing
REBUTT AL TESTIMONY OF PHILIP LINSE upon all parties of record in this matter as
follows:
Jean D. Jewell
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone [phone]
Facsimile: [phone]
ijewell~puc.state.id.
Weldon Stutzman
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone [phone]
Facsimile: [phone]
weldon.stutzman(q)jJuc .idaho. gov
John Antonuk
Liberty Consulting Group
65 Main Street
O. Box 1237
Quentin, PA 17083-1237
Telephone: [phone]
Facsimile: [phone]
antonuk(q)Jibertyconsultinggroup. com
Erik Cecil
Level 3 Communications LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Telephone: [phone]
Facsimile: [phone]
erik.cecil(q)Jeve13 .com
Boise-187612.l 0061273-00018
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Henry T. Kelly
Joseph E. Donovan
Scott A. Kassman
Kelley Drye & Warren LLP
333 West Wacker Drive
Chicago, IL 60606
Telephone: [phone]
Facsimile: [phone]
hkelly~kelleydrye.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean J. Miller (ISB #1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
ioe~mcdevitt-miller.com
Attorneys for Level Communications
a-t/
Brandi L. Gearhart, PLS
Legal Assistant to Mary S. Hobson
Stoel Rives LLP
Boise-187612.l 0061273-00018
En
t
r
a
n
c
e

F
a
c
i
l
it
i
e
s
Ex
h
i
b
i
t

N
o
.

3
0
9
QW
E
-
05
-
,
L
i
n
s
e
,
Q
w
e
s
t
Ow
e
s
t

C
e
n
t
r
a
l

O
f
f
i
c
e

Bu
i
l
d
i
n
g
Di
s
t
r
i

b
u
t
i
o
n
Fr
a
m
e
Ow
e
s
t

P
r
o
v
i
s
i
o
n
s

S
h
a
r
e
d

F
a
c
i
l
i
t
i
e
s
be
t
w
e
e
n

N
e
t
w
o
r
k
s
Qw
e
s
t
id
-
Sp
a
n

M
e
e
t

P
o
i
Ex
h
i
b
i
t

N
o
.

3
1
0
QW
E
-

T

-
05
-
,
L
i
n
s
e
,
Q
w
e
s
t
aw
e
s
t

Ce
n
t
r
a
l

O
f
f
i
c
e

B
u
i
l
d
i
n
g
GL
E
C

P
r
o
v
i
s
i
o
n
s
Fa
c
i
l
i
t
i
e
s

T
o

M
e
e
t
-
Po
i
n
t
Be
t
w
e
e
n

N
e
t
w
o
r
k
s
Di
s
t
r
i
b
u
t
i
o
n
Fr
a
m
e
aw
e
s
t

Pr
o
v
i
s
i
o
n
s
Fa
c
i
l
i
t
i
e
s

T
o

M
e
e
t
-
Po
i
n
t
Be
t
w
e
e
n

N
e
t
w
o
r
k
s
Qw
e
s
t
Co
l
lo
c
a
t
i
o
n
Qw
e
s
t

C
e
n
t
r
a
l

O
f
f
i
c
e

B
u
i
l
d
i
n
g
Di
s
t
r
i
b
u
t
i
o
n

F
r
a
m
e
CL
E
C
Pr
o
v
i
d
e
d

F
a
c
i
l
i
t
y
Qw
e
s
t

P
r
o
v
i
d
e
d
In
t
e
r
c
o
n
n
e
c
t
i
o
n

T
i
e

P
a
i
r
Qw
e
s
t
CL
E
C
Co
l
l
o
c
a
t
e
d

P
O

Ex
h
i
b
i
t

N
o
.

3
1
1
QW
E
-
05
-
,
L
i
n
s
e
,
Q
w
e
s
t
To

C
L
E
C
Ne
t
w
o
r
k
Exhibit No. 312
QWE-O5-
, Linse, Qwest
AMA TSG
AMA Technical Support Group
Subject:
February 4 2005
Alliance for Telecommunications Industry Solutions
Ordering and Billing Forum
Billing Committee
OBF Issue 2776: Identification ofVoIP-Originated Calls
Date:
To:
Billing Committee Members:
This is an open letter to the participants in the Billing Committee of the Ordering and
Billing Forum (OBF), written at the direction of the AMA Technical Support Group
(AMATSG), regarding OBF Issue 2776: Identification ofVolP-Originated calls. At its last
three quarterly meetings, the AMATSG has been tracking the discussions at the OBF on
this issue, and the members of the AMATSG feel that now is an appropriate time to
contribute the AMATSG's current thinking on this issue.
The AMATSG meets quarterly to discuss matters related to the generation of AMA in
stored program control switches. Its members are the recognized AMA subject matter
experts in their respective companies. Some of the companies represented at the OBF are
also members oftheAMATSG, and the AMATSG SMEs are regularly consulted to provide
their expertise on matters related to new network capabilities and services.
1. Background
The AMA TSG believes that the Billing Committee made the correct decision to accept and
work the issue of identifying calls that originate in a VolP network and ingress to the PSTN
via an interface between a VoIP gateway and a traditional TDM (Time Division
Multiplexing) switching system. There is no need to reiterate the potential regulatory and
technical reasons for acting on this issue; these are already well documented in the OBF
record.
The AMA TSG members would like to address the potential technical solutions that might
be available to accomplish identification ofVolP-Originated calls. We understand that
there have been some proposals floated at this point, and we would like to address those
proposals that we have heard about and propose some of our own. The AMATSG, like the
Billing Committee, realizes that the most efficient network-based solution will involve some
type of alteration to call setup signaling in the Signaling System 7 protocol. We also realize
that neither of our groups can effect a change to this protocol without the assistance of the
standards bodies responsible for standardizing the SS7 protocol. Therefore, the goal of this
letter is to provide substantive technical input from an AMA and billing perspective to the
appropriate standards bodies so that this issue is resolved in an efficient, expeditious
manner.
Before going into each of the proposals, the AMATSG would like to note that each of the
variations on the call setup signaling solution will likely require modifications to existing
TDM switch generic software. Whatever signaling variation is chosen will require some
Exhibit No. 312
QWE-O5-
, Linse, Qwest
modification of call processing and AMA generic software in most TDM switching systems.
For companies using a Link Monitoring System (LMS) to generate CDRs, the impact of a
signaling solution may be considerably less involved. Finally, whether a modified CDR is
generated at the switch or the LMS, the newly-generated VoIP indicator will have to be
detected and processed by service provider billing systems. That said, the goal of the
AMA TSG is to minimize the impact of all these software changes.
2. Potential Signaling Solutions
The AMATSG client companies asked the BAF experts at Telcordia Technologies to provide
a preliminary analysis of potential SS7 parameters that are already present in call setup
signaling that could be used for identification ofVoIP-Originated calls. The criteria
specified by the AMA TSG for parameter selection included the following
characteristics/restrictions:
The parameter:
1. must be a parameter within the Initial Address Message (lAM)
2. must be in general use
3. must be signaled forward as part of normal call transiting
4. must be sent end -to-end
The value set in the parameter:
1. must have an available value within the existing parameter
2. must minimize interaction with or be independent of existing parameter
values (stand -alone)
3. must be transparent to networks not using the value and yet be signaled
forward as part of normal call transiting.
U sing these criteria as a guide, two of the parameters that had been mentioned in
discussions of Issue 2776, namely the Originating Line Information (aLl) parameter and
the Calling Party Number (CPN) parameter, were examined. In addition, two other
parameters that the AMATSG believes may meet the above criteria were also investigated.
The two additional parameters for consideration are the Forward call Indicator (FCl) and
the Nature-of-Connection Indicators (NCl).
Table 1 is a summary representation of how these four parameters meet the criteria.
Table 1: Comparison of Proposed lAM Parameters
General Transiting End-Value Independent Transparent
Use to. End Available (Stand. alone)
aLl Yes
CPN Yes Yes Yes Yes
FCI Yes Yes Yes Yes Yes Yes
NCI Yes Yes Yes Yes Yes Yes
Exhibit No. 312
QWE-O5-
, Linse, Qwest
3. Points of Comparison
The following is a brief explanation of the entries in Table 1 for each parameter.
1 Originating Line Information (OLI) parameter
Using the Originating Line Information parameter, the AMATSG believes, will be
problematic. The first difficulty with using this parameter is that it is in general use only
for the Exchange Access version of the SS7 protocol (reference Telcordia GR-394-CORE).
Traditional signaling used between local exchange carriers for local and short-haul toll calls
does not call for the inclusion of the OLI parameter in the lAM (reference GR-317-CORE).
The AMATSG believes that, if the VoIP-Originated indicator comes to be required, it will be
required for both Exchange Access calls and local calls. If OLI were to be selected as the
parameter, then call processing logic would be required to generate this parameter for local
calls where it is not generated today.
The transiting and end -to-end characteristics for OLI are also deficient in the protocol at
this time. Transiting nodes would be required to pass this parameter through to the
terminating node and while it is true that the standards language states that an unused
unrecognized parameter should be signaled forward, experience has shown that this is not
always the case in existing implementations.
The last characteristic that argues against using OLI to identify VoIP-Originated calls is
the value assignment question. OLI is currently used to identify originating line
characteristics such as cellular calls, toll-free calls, and calls made from coin/coinless
stations. Adding a VoIP-Originated component to this mix does not require just one or two
additional values, but requires values and/or procedures to convey on the originating end
and interpret on the terminating end that VoIP technology was used, which could occur in
conjunction with a line characteristic already assigned an OLI value. Therefore, a
multiplier effect" will cause values to need to be assigned representing each of many
existing values in conjunction with the new need. This type of analysis and assignment is
complicated. The AMATSG believes that resources can be better and more profitably spent
using another parameter rather than trying to develop something that will be inherently
complicated and confusing.
2 Calling Party Number (CPN) parameter
The AMATSG believes that the Calling Party Number (CPN) parameter could be used to
convey an indication that a call has originated in a VoIP network. However, there are at
least two caveats that must be considered. The first is the indicator itself. The AMATSG
believes an independent and stand-alone indicator should be used to avoid interworking
and compatibility issues with established values. To accomplish this in the current
implementation of the SS7 protocol definition for CPN would require the spare bit in the
second octet of the parameter be used to indicate VoIP-Originated. This bit is currently
spare and is the only spare bit available. The fact that the only spare bit would be used to
identify a VoIP call may cause some concern within the signaling standards community.
The second consideration is the industry s experience overall with signaling forward CPN
from an originating network through transiting networks and on to the terminating
Exhibit No. 312
QWE-O5-
, Linse, Qwest
network. The instances where transiting and terminating networks do not receive the CPN
parameter are still numerous enough to warrant caution in using this parameter for a
needed piece of information. The AMATSG members believe that the industry should be
wary of relying on the presence of the CPN parameter for yet another potentially significant
financial and fiduciary function. The AMATSG believes that using the CPN parameter for
VoIP identification is not a viable solution.
3 Forward Call Indicator (FCI)
The most recent industry'wide requirement for sending an indicator from the originating
switch to the terminating switch was accomplished using a bit in the FCI parameter. The
application was Number Portability (NP), and FCI was used to indicate that a NP query
was or was not performed. This indicator was essential for network efficiency and was a
critical piece of information that each network node needed to know as call setup signaling
was passed through to the terminating network. The terminating network used the 'M' bit
in the FCI to trigger whether or not to swap out the telephone number in the generic
address parameter (GAP) with the called party number in order to terminate the call
properly.
It can be argued that the VoIP-Originated indicator is the next industry-wide critical
indicator that must be passed end-to-end in the network. The AMATSG members believe
that the indicator for VoIP-Originated may have applications beyond the initial
regulatory/accounting purpose that is now its focus. The implication to the AMATSG is that
the indicator will be required beyond the point of initial interface between the VoIP
network and the ingress TDM network. This means that the indicator must be available
end-to-end for call setup and, like the 'M' used in NP, must also be stand-alone and not be
burdened with complicated interworking scenarios. As its use for NP demonstrates, the
FCI indicators are stand-alone bits, and as part of the essential information for call setup,
are passed from node to node essentially unaltered.
This parameter meets all of the criteria listed in Table 1; however, the AMATSG members
acknowledge that the available bits in the FCI parameter are limited. Currently, there are
three bits that remain unassigned ('
, '
, and '
).
The 'L' bit is spare and the latter two
are reserved for 'National Use . The AMATSG recommends that the FCI parameter be
considered a reasonable candidate for use as an indicator for VoIP-Originated calls.
4 Nature-ot-Connection Indicators (NCI)
The last parameter examined by the AMATSG is the Nature-of-Connection Indicators
(NCI). Like FCI, the NCI indicator meets all of the criteria listed in Table 1 in that it is in
general use, is signaled forward as part of normal call transiting, and is sent end -to-end.
The value could be set in the parameter by a '0' or '1' in an available bit, which would be
stand-alone and would eliminate interactions with existing parameter values. NCI would
be signaled forward as part of call setup, yet it would be transparent to networks not using
the value. The NCI also has three unassigned bits available ('
, '
, and '). As far as the
title of the parameter to be used
, "
Nature of Connection" is appropriate for an indication of
the technology used to originate the call. The AMATSG recommends that the NCI
parameter also be considered a reasonable candidate for use as an indicator for VoIP-
Originated calls.
Exhibit No. 312
QWE-O5-
, Linse , Qwest
4. Conclusion
The AMATSG members, after considerable research and thought on this issue, would like
to recommend that the OBF consider our arguments for using either the NCI parameter or
the FCI parameter to identify VoIP-Originated calls. Conversely, we would ask that the
OBF avoid any recommendation for using either the OLI parameter or the CPN parameter
for this purpose.
The AMA TSG hopes that the Billing Committee of the OBF will find this letter useful in
focusing your discussions in the committee and invites the Billing Committee to avail itself
of any and all of the information contained in this letter when interacting with the
signaling standards and network interoperability groups.
Thank you for your time and attention. If you have any questions on the technical content
of this letter, please contact either Sara Knapp [phone] or Bill Krall [phone]
at Telcordia Technologies.
Carla Worland
Chair - AMA Technical Support Group
[phone]
Jackie Rymill
Vice Chair - AMA Technical Support Group
[phone]
Copy to: AMATSG Members
Tom Buhler - Qwest
Lourdes Coronado - SBC
Fran Fischbach - Qwest
Mel Kennedy - Verizon
Cindy Kontz - Verizon
Sandy Lauterbach - Verizon
Doug Mabie - Verizon
Deborah May - BellSouth
Robbie McCarty - Verizon
Bob McHugh SBC
Linda Mudd SBC
Jackie Rymill - Qwest
AI Todd - SBC
Dave Whitney - BellSouth
Carla Worland - BellSouth
Sara Knapp - Telcordia Technologies
Bill Krall- Telcordia Technologies
Loren Lewin - Telcordia Technologies
1200 G Street, NW
Suite 500
Washington, DC 20005
www.atis.org
Ordering and Billing Forum
(OBF)
Dean Grady
OBF Co-Chair
dean.qradv(Q).mci.com
David Thurman
OBF Co-Chair
David. Thurman(Q).mail.sprintcom
John Pautlitz
ATIS Director Industry Forums-OBF
jpautlitz(Q).atis. orq
Developing Standards
that Drive the Business
of Communications and
Information Technology
May 9, 2005
Exhibit No. 313
QWE-O5-
, Linse , Qwest
Packet Technologies and Systems Committee (PTSC)
Bob Hall
PTSC Chair
SBC Communications
bhall~labs. s bc. com
Joe Zebarth
PTSC Vice Chair
Nortel Networks
ze barth~n ortel. com
RE: OBF Billing Committee Issue 2776 - Identification of IP-
Originated, PSTN- Terminated Traffic for Intercarrier Compensation
Purposes
The OBF Billing Committee is currently reviewing Issue 2776 (See
Attachment 1), related to Intercarrier Compensation between IP and
PSTN networks. Due to the nature of Voice Over Internet Protocol
(VoIP) origination, there is an apparent need to separate VolP traffic
from other PSTN traffic for intercarrier compensation issues.
The committee is investigating the following three options for
identifying VolP traffic:
1. Utilizing existing signaling parameters as provided by the
AMATSG (See Attachment 2) - where the possible solution
includes one of the following:
a. Originating Line Identifier (OLI)
b. Calling Party Number (CPN)
c. Nature of Connection Indicator (NCI)
d. Forward Call Indicator (FCI)2. ENUM Database type solution - which may contain a list of all
VolP 10-digit numbers.3. New Feature Group trunk type for packet type interconnection
- which could be similar to existing Feature Group trunk types
(Example: FGB & FGD). In this case , we would need to
investigate the best signaling protocol available.
Weare requesting any recommendations specific to the AMA TSG
solution (1) but would also like to get your input regarding the other
alternatives (2 & 3) that we are considering. We would welcome any
other options that we have not yet identified.
Would you kindly provide a response with a status or update in time
for review prior to the next OBF General Session (June 22, 2005).
Exhibit No. 313
QWE-O5-
, Linse, QwestYour questions and feedback may be directed to the Billing Committee Co- Chairs: Syl-Vonna Mabie at
[phone] (email: sylvonna.mabi~nisc.coop) and Larry Martin at [phone]
(email: larry.martin~consolidated.com)
Regards
Syl-Vonna Mabie
Billing Committee Co-Chair
NISC
Larry Martin
Billing Committee Co-Chair
Consolidated Communications
CC:
Dean Grady, OBF Co-Chair, MCI dean.grad~mci.com
Dave Thurman, OBF Co-Chair, Sprint David.Thurman~mai1.sprint.com
Khristine Natelli, OBF Billing Committee Administrator knatelli~atis.org
John Pautlitz, ATIS OBF Director ipautlitzematis.org
Alissa Medley, OBF Project Manager amedle~atis.org
Yvonne Reigle, OBF Team Manager vreigl~atis.org
Tom Goode, ATIS Attorney, tgoode(2lJatis.org
Jean-Paul Emard, Director - Technical Committee, PTSC, ATIS ipemard~atis.org
Steve Barclay, PTSC Manager, ATIS sbarclay~atis.org
Catrina Akers, PTSC Committee Associate cAker~atis.org
Nicole Butler, PTSC Committee Administrator nbutle~atis.org
Joe Scolaro, LSOP SME iscolaro~atis.org
1200 G Street, NW
Suite 500
Washington, DC 20005
www.atis.org
Packet Technologies and
Systems Committee
(PTSC)
Bob Hall
Chairman
bhall(Q).labs.sbc.com
Joe Zebarth
Vice Chairman
zebarth(Q).norteLcom
Jean-Paul Emard
ATIS Director, Industry Forums
+1 202~434-8824
jpemard(Q).atis. orq
Susan Carioti
ATIS Manager
scarioti(Q).atis. orq
Steve Barclay
A TIS Manager
sbarclaV(Q).atis.orq
Developing Standards
that Drive the Business
of Communications and
Information Technology
Exhibit No. 314
QWE-O5-
, Linse, Qwest
PTSC-2005-118R1
June 23, 2005
Syl- Vonna Mabie, OBF Billing Committee Co-Chair
Larry Martin, OBF Billing Committee Co-Chair
Subject: Response to your liaison: OBF Billing Committee Issue 2776 - Identification
of IP Originated, PSTN- Terminated Traffic for Intercarrier Compensation
Purposes, dated May 9th, 2005
Dear Syl-Vonna and Larry,
We offer you the following comments with respect to your three options, respectively:
1. The SS7 ISUP protocol is a mature protocol and in principle should not be
extended unless there is significant reason to do so. This includes new
encodings in existing parameters and fields. At this time, we do not recommend
modification of the SS7 ISUP protocol to address the identification ofVoIP
traffic.
2. We feel that a "down-stream" lookup process is an appropriate solution to the
problem stated.
3. From an architecture perspective, we feel that defining a new trunk type
including the associated signaling, OAM&P (provisioning) and overhead
(reduced trunking efficiencies), would make it an inefficient approach to
solving the problem, and thus do not recommend it.
Weare looking at this topic in a broader perspective and we will share more
information in the near future. We look forwarded to continued collaboration on these
matters.
Sincerely,IttU
(Signed original on file)
Bob Hall
Chairman, PTSC
CC: Dean Grady, OBF Co-Chair, MCI dean.gra v~mci.com
Dave Thurman, OBF Co-Chair, Sprint David.Thurman~mail.sprint.com
Khristine Natelli, OBF Billing Committee Administrator knatelli~atis.org
John Pautlitz, A TIS OBF Director illIDillitz~atis.org
Alissa Medley, OBF Project Manager ~ey~atis.org
Yvonne Reigle, OBF Team Manager yreigle~atis.org
Christine Wilde, OBF Registration cwilde~atis.org
Tom Goode, A TIS Attorney, tgoode~atis.org
Jean-Paul Emard, Director - Technical Committee, PTSC, A TIS ipemard~atis.org
Steve Barclay, PTSC Manager, A TIS sbarclay~atis.org
Nicole Butler, PTSC Committee Administrator nbutler~atis.org