HomeMy WebLinkAbout20070529Amendment.pdfQwest
1600 7th Avenue, Room 3206
Seattle, Washington 98191
(206) 398-2504
Facsimile (206) 343-4040
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Spirit of Service
Maura E. Peterson
Paralegal
Regulatory Law
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Via Overnight delivery
May 24, 2007
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. QWE-06-
Application for Approval of Amendment to the Interconnection Agreement
Verizon Business Network Services, Inc. (as successor in interest to MCI
World com Network Services, Inc.) and its affiliates MCI Communications
Services, Inc. and MCImetro Access Transmission Services LLC
Dear Ms. Jewell:
Enclosed for filing with this Commission on behalf of Qwest Corporation is an original and
three (3) copies of the Application for Approval of Amendment to the Interconnection
Agreement. Qwest respectfully requests that this matter be placed on the Commission
Decision Meeting Agenda for expedited approval.
Please contact me if you have any questions concerning the enclosed.
assistance in thiS/ er.
Sincerely,
v()v~U e-~.
Maura E. Pete
Thank you for your
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Enclosure
cc: Service list
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Adam L. Sherr (WSBA# 25291)
Qwest
1600 7th Ave, Room 3206
Seattle, WA 98191
Telephone: (206) 398-2507
Facsimile: (206) 343-4040
Adam.sherr~qwest.com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
APPLICATION OF QWEST
CORPORATION FOR APPROVAL OF
AN INTERCONNECTION AGREEMENT
PURSUANT TO 47 U.c. ~252(e)
CASE NO.: QWE-O6-
APPLICATION FOR APPROVAL OF
AMENDMENT TO THE
INTERCONNECTION AGREEMENT
Qwest Corporation ("Qwest") hereby files this Application for Approval of Amendment
to the Interconnection Agreement ("Amendment") on file with the Idaho Public Utilities
Commission under Case No. QWE-06-24 (the "Agreement"). The Amendment with Verizon
Business Network Services, Inc. (as successor in interest to MCI Worldcom Network Services
Inc.) and its affiliates MCI Communications Services, Inc and MCImetro Access Transmission
Services LLC ("Verizon ) is submitted herewith.
This Amendment was reached through voluntary negotiations without resort to mediation
or arbitration and is submitted for approval pursuant to Section 252( e) of the Communications
Act of 1934, as amended by the Telecommunications Act of 1996 (the "Act"
Section 252(e)(2) of the Act directs that a state Commission may reject an amendment
reached through voluntary negotiations only if the Commission finds that: the amendment (or
portiones) thereof) discriminates against a telecommunications carrier not a party to this
agreement; or the implementation of such an amendment (or portion) is not consistent with the
public interest, convenience and necessity. Qwest respectfully submits this Amendment provides
no basis for either of these findings, and, therefore requests that the Commission approve this
Amendment expeditiously.
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT - Page 1
MCIMETRO ACCESS TRANSMISSION SERVICES LLC
Business Escalation Agreement
The purpose of this Agreement is, generally, to improve the business-to-business
relations between the parties and agree to resolve business issues through standard escalation
processes.
Please note that the Agreement addresses a broad array of issues that would be subject to
its escalation procedures. Thus, the language of Section 4 in the Agreement, which states that
interconnection agreement "disputes" shall still be governed by the dispute resolution terms of
the existing interconnection agreement, addresses not all of the matters that could arise between
the parties that are within the scope ofthe Agreement. Further, the parties ' business-to-business
relationship pertains to Section 251 services as well as other services. For these reasons, Qwest
believes that the Agreement reflects changes and additions to its existing interconnection
agreement with Verizon and it is appropriate to file this Agreement pursuant to Section 252
filing requirements.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State ofIdaho , the Commission, the United States Congress, and the Federal
Communications Commission. Expeditious approval of this Amendment will enable MClmetro
to interconnect with Qwest facilities and to provide customers with increased choices among
local telecommunications services.
Qwest further requests that the Commission approve this Amendment without a hearing.
Because this Amendment was reached through voluntary negotiations, it does not raise issues
requiring a hearing and does not concern other parties not a party to the negotiations.
Expeditious approval would further the public interest.
Respectfully submitted this ;)r;fL.day of May, 200
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J,west
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APPLICA TION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT Page 2
MCIMETRO ACCESS TRANSMISSION SERVICES LLC
Business Escalation Agreement
CERTIFICATE OF SERVICE
I hereby certify that on this 9'::.day of May, 2007 , I served the foregoing
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION
AGREEMENT upon all parties of record in this matter as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, Idaho 83720-0074
i i ewell~puc.state.id. us
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
MCImetro
Peter H. Reynolds
Verizon Business
2200 1 Loudoun County Parkway
Ashburn, VA 20147
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
APPLICA TION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT - Page 3
MCIMETRO ACCESS TRANSMISSION SERVICES LLC
Business Escalation Agreement
OS/22/2007 01: 303895 7358 PAGE 01/03
BUSINESS ESCALATION AGREEMENT
This Business Escalation Agreement ("Agreement") is entered into this 4th day of
April , 2007, by and between Qwest Services Corporation and its affiliates
Owest") and Verizon Business Network Services, Inc. (as successor, in interest
to MCI WORLDCOM Network Services, Inc.) and its affiliates MCI
Communications Services, Inc. and MClmetro Access Transmission Services
LLC ("MCI"), , for consideration of the mutual promises herein and other good
and valuable consideration. The parties agree to: (1) arrange Executive-Level
meetings as necessary between executives of each company to address
unresolved and/or anticipated business issues; and (2) establish and fOllOw
escalation procedures designed to facilitate and expedite business-to-business
dispute solutions.
1. EXECUTIVE-LEVEL MEETINGS
The parties agree to continue to attend and participate in executive meetings as
necessary, the purpose of which will be to address and discuss issues, open
items or disputes, and future business needs. The participants in the meeting
will include executives from both companies at the executive director and/or
above level.
2. BUSINESS ESCALATION PROCEDURES
The parties wish to establish an improved business-to-business relationship and
agree that they will attempt to resolve business issues that may arise between
them , in accordance with the escalation procedures set forth herein. The parties
agree, subject to any subsequent written agreement between the parties, to: (1)
utilize the following escalation process and time frames to resolve such disputes;
(2) commit the time, r~sources and good faith necessary to meaningful dispute
resolution; (3) grant to one another, at the request of the other party, reasonable
extensions of time at Levels 1 and 2 of the dispute resolution process to facilitate
a business resolution.
Level Participants Time frame for discussions
LEVEL 1 Directors 15 business days
LEVEL 2 Executive Directors 10 business days
LEVEL 3 Vice Presidents or Above 5 business days
In the event mutually agreeable resolution is not achieved. either party may seek
legal, regulatory, or other relief.
"..---.".--.
-".--.- " .,...m.
OS/22/2007 1 : 33PM
OS/22/2007 01: 3038%7358 PAGE 02/03
NOTICES
Any notice requesting an escalation or meeting pursuant to this Agreement shaH
be made in writing and delivered by U.S. mail or facsimile to the following
persons:
If to Owest:
Steve Hansen
Vice President - Carrier Relationsth Floor
1801 California Street
Denver, Colorado 80202
Wholesale Legal Representative
Suite 900
1801 California Street
Denver Colorado 80202
If to Yerizon Business:
Michael A. Beach
Executive Director
Carrier Cost Management
6415 Business Center Drive
Highlands Ranch, CO 80130
Paul Collins
Associate Counsel
22001 Loudoun County
Parkway
Ashburn , VA, 20147
SCOPE OF AGREEMENT
The parties agree that the escalation procedures set forth in this Agreement do
not apply to disputes arising under any interconnection agreements ("ICAs
between the parties. Such lOA disputes shall be governed by the dispute
resolution terms of the ICAs rather than the terms of this Agreement.
Notwithstanding the above escalation procedures, the parties expressly reserve
the right to pursue legal, regulatory, and/or other reHef at any time before any
court, administrative agency, or other body as each party, in its sale discretion,
deems appropriate or necessary to protect its interests. In the event either party
avails itself of such right to reHef, the other party may, to the extent feasible,
accelerate the escalation process so as to reach Level 3' prior to the time at
which a responsive filing would be required of that party.
In the event either party pursues legal, regulatory, or other relief, both parties
agree that they will continue to use this escalation process in an attempt to
continue to seek settlement of that dispute and other disputes that may exist at
that time or subsequently arise between the parties.
...".-.---.----,.. . -.. -..,.".." ".." ."
OS/22/2007 1 : 33PM
OS/22/2007 01: 303895 7358
If the parties agree with the terms set forth above , they will each execute a copy
of this Agreement in the signature spaces provided on the last page. Upon
signature of both parties , the parties will be bound as of the date set forth above
by the terms set forth herein , through March 2010. Upon signature of bothparties, this Agreement shall supersede in its entirety a certain Business
Escalation Agreement entered into by the parties on February 20, 2004. This
Agreement may be executed in counterparts.
Qwest Services Corporation
and its affiliates
Verizon Business Network
Servic , Inc.
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Printed Name
Michael A. Beach
Executive Director
Carrier Cost Management
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Title
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OS/22/2007 1 : 33PM
PAGE 03/03