20120809Amendment.pdf

CenturyLink
S 1600 7th Avenue, Room 1506
Seattle, Washington 98191
[phone]
Facsimile [phone]
Maura E. Peterson
Paralegal
Regulatory Law
RECEVr:D TM
2012 MJG -7 PM 12: 554
UTLT1E )MMSSON
CenturyLi n kTM
Via Overnight delivery
August 6, 2012
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. QWB-T-08-01
Application for Approval of Amendment to the Interconnection Agreement
Bandwidth.com CLEC, LLC
Dear Ms. Jewell:
Enclosed for filing with this Commission on behalf of Qwest Corporation dba CenturyLink
QC ("CenturyLink") 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. Thank you for your
assistance in this matter.
Sincerely,
Maura E. Pe son
mep
Enclosure
cc: Service list
www.centurylink.com
• Lisa A. Anderl (WSBA#13236)
CenturyLink
1600 7th Ave, Room 1506
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
[e-mail]
RE CE'1 C
LAHO P!1iEL..
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
APPLICATION OF QWEST
CORPORATION dlbla CENTURYLINK
QC FOR APPROVAL OF AN
INTERCONNECTION AGREEMENT
PURSUANT TO 47 U.S.C. §252(e)
CASE NO.: QWE-T-08-01
APPLICATION FOR APPROVAL OF
AMENDMENT TO THE
INTERCONNECTION AGREEMENT
Qwest Corporation dlb/a CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the Interconnection Agreement ("Amendment") which was
approved by the Idaho Public Utilities Commission on April 4, 2008 (the "Agreement"). The
Amendment with Bandwidth.com CLEC, LLC ("Bandwidth") 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
portion(s) 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.
CenturyLink respectfully submits this Amendment provides no basis for either of these
findings, and, therefore requests that the Commission approve this Amendment expeditiously.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State of Idaho, the Commission, the United States Congress, and the Federal
is
Communications Commission. Expeditious approval of this Amendment will enable Bandwidth
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT - Page 1
BANDWIDTH.COM CLEC, LLC
• to interconnect with CenturyLink facilities and to provide customers with increased choices
among local telecommunications services.
CenturyLink 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 day of August, 2012.
Qwest Corpo a CenturyLink QC
Attorney for CenturyLink QC
fl
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT - Page 2
BANDWIDTH.COM CLEC, LLC
CERTIFICATE OF SERVICE
I hereby certify that on this day of August, 2012, 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
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]
Lisa Jill Freeman
VP Regulatory Affairs
Bandwidth.com CLEC, LLC
4001 Weston Parkway, Suite 100
Cary, NC 27513
Hand Delivery
U. S. Mail
X Overnight Delivery
Facsimile
Email
Hand Delivery
X U.S.Mail
Overnight Delivery
Facsimile
Leslie Johnson
is
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION AGREEMENT - Page 3
BANDWIDTH.COM CLEC, LLC
DowSign Ercvelope ID: 7D651 El 5-CA69-45F3-AF72-205442A79861
ICC VoIP Amendment
to the Interconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
Bandwidth.com CLEC, LLC
for the State of Idaho
This Amendment ("Amendment") is to the Interconnection Agreement between Qwest
Corporation dba CenturyLink QC ("CenturyLink"), a Colorado corporation, and Bandwidth.com
CLEC, LLC ("CLEC"), a Delaware LLC, (collectively, the "Parties").
RECITALS
WHEREAS, the Parties entered into an Interconnection Agreement, for service in the State of
Idaho, that was approved by the Commission in April 2008 ("Agreement"); and
WHEREAS, the Federal Communications Commission in Docket No. 01-92, In the Matter of
Developing a Unified Intercarrier Compensation Regime, issued an order that affects the Parties
rights and obligations with respect to the exchange of VoIP traffic between CLEC providers and
LECs in addition to revised call signaling rules effective December 29, 2011 ("FCC Order" or
"Order"); and
WHEREAS, the Parties agree to amend the Agreement in response to the FCC Order with the
terms and conditions contained herein.
AGREEMENT
NOW THEREFORE, in consideration of the mutual terms, covenants and conditions contained
in this Amendment and other good and valuable consideration, the receipt and sufficiency of
which is hereby acknowledged, the Parties agree as follows:
Amendment Terms
The Agreement is hereby amended by replacing and adding terms, conditions, and rates as set
forth in Attachment 1 and Exhibit A attached hereto and incorporated herein by this reference.
The provisions included in Attachment 1 are intended to supersede and replace the same
numbered provisions in the Agreement and be added to the Agreement to the extent that the
applicable numbered provision is not currently in the Agreement.
By signature on this Amendment, CLEC has elected to modify existing contract terms in order to
implement the applicable provisions of the above mentioned Order.
Effective Date
This Amendment shall be deemed effective upon Commission approval; however, pursuant to
the Parties Agreement change in law language, the Parties agree to implement the provisions of
this Amendment as of December 29, 2011.
June 7, 201 2lmms, bk/Bandwidth.com/ICC VoIP Amd/ID
Amendment to CDS-080225-0004
.
DocuSign Envelope ID: 7D651 El 5-CA69-45F3-AF72-205442A79861
Further Amendments

.
Except as modified herein, the provisions of the Agreement shall remain in full force and effect.
The provisions of this Amendment, including the provisions of this sentence, may not be
amended, modified or supplemented, and waivers or consents to departures from the provisions
of this Amendment may not be given without the written consent thereto by both Parties'
authorized representative. No waiver by any Party of any default, misrepresentation, or breach
of warranty or covenant hereunder, whether intentional or not, will be deemed to extend to any
prior or subsequent default, misrepresentation, or breach of warranty or covenant hereunder or
affect in any way any rights arising by virtue of any prior or subsequent such occurrence.
Entire Agreement
The Agreement as amended (including the documents referred to herein) constitutes the full
and entire understanding and agreement between the Parties with regard to the subjects of the
Agreement as amended and supersedes any prior, understandings, agreements, or
representations by or between the Parties, written or oral, to the extent they relate in any way to
the subjects of the Agreement as amended.
The Parties intending to be legally bound have executed this Amendment as of the dates set
forth below, which may be in multiple counterparts, each of which is deemed an original, but all
of which shall constitute one and the same instrument.
Bandwidth.com CLEC, LLC
DocuSigned by: r
—FCO863EE3C764FF...
Signature
Steve Leonard
Name Printed/Typed
EVP and General Manager inetwork
Title
7/11/2012
Qwest Corporation dba CenturyLink QC
05E9FC68BD57454
I rea
LDocusi9nd y: L I Christensen
Signature
L. T. Christensen
Name Printed/Typed
Director - Wholesale Contracts
Title
7/11/2012
Date Date
June 7, 2012Imms, bklBandwidth.com/ICc V0IP Amd/ID
Amendment to cDs-080225-0004 2 •
DopuSign Ertvelope ID: 7D651 El 5-CA69-45F3-AF72-205442A79861
0 Attachment I
ICC Voice over Internet Protocol (VoIP) Amendment
Notwithstanding anything set forth in the Agreement to the contrary, the following terms and
provisions shall govern the intercarrier compensation between the Parties for the exchange of
VolP-PSTN Traffic.
Section 4.0 - DEFINITIONS
"VoIP-PSTN Traffic" includes any traffic previously referred to in the Agreement as "VoIP" or
"VolP Traffic" or "IP Enabled Voice Traffic", and is defined as traffic which is exchanged
between a CenturyLink end user and the CLEC end user in Time Division Multiplexing ("TDM")
format that originates and/or terminates in Internet Protocol ("IP") format, as determined in the
Order, and terminates to a Party's End User Customer.
"Local V0IP-PSTN Traffic" is VoIP-PSTN Traffic that originates and terminates within the
geographic boundaries of the Local Calling Area as determined by the Commission.
"Toll VoIP-PSTN Traffic" is VoIP-PSTN Traffic that originates and terminates in geographically
different Local Calling Areas as determined by the Commission.
Section 7.0 - INTERCONNECTION
7.2 Exchange of Traffic
7.2.1.3 Local \JolP-PSTN Traffic and Toll VoIP-PSTN Traffic may be exchanged under
this Agreement.
7.2.1.3.1 Switched Access Traffic, including but not limited to InterLATA Traffic,
other than Toll VoIP-PSTN Traffic or Jointly Provided Switched Access Traffic, may not
be exchanged under this Agreement. In the event CLEC routes lnterLATA Traffic to
CenturyLink in violation of this section, CenturyLink shall be entitled to seek injunctive
relief and to recover damages, including without limitation, compensation for such traffic
at the rate that is then applicable to such access traffic.
7.3 Intercarrier Compensation
7.3.8 Signaling Parameters: CenturyLink and CLEC are required to provide each other the
proper signaling information (e.g., originating Calling Party Number (CPN), Charge Number
(ChN) and destination called party number, etc.) as required by Applicable Law and further
clarified by the FCC Order to enable each Party to issue bills in a complete and timely fashion.
All CCS signaling parameters will be provided unchanged including CPN, calling party category,
ChN and Originating Line Information Parameter (OLIP) on all calls. All privacy indicators will
be honored. The ChN is to be passed unaltered in SS7 signaling fields where it is different from
CPN; ChN must not be populated with a number associated with an intermediate switch,
platform, or gateway, or other number that designates anything other than a calling party's
charge number; and if MF signaling is used by the CLEC then the ChN must be included in the
ANI field if different from the CPN. Where SS7 connections exist, each Party shall pass all CCS
signaling parameters, where available, on each call carried over Interconnection trunks. If either
Party fails to provide valid originating information such traffic will be billed as Intrastate Switched
Access when the calls traverse an interconnection trunk. The Parties will coordinate and
exchange data as necessary to determine the cause of the CPN/ChN failure and to assist its
June 7, 2012/mms, bk/Bandwidth.com/ICC VoIP Amd/ID
Amendment to CDS-080225-0004 3
DocuSign Envelope ID: 713651 El 5-CA69-45F3-AF72-205442A79861
correction. Further, the Parties will work in good faith to resolve any instance of billing of
Intrastate Switched Access based upon the lack of originating information in a manner 0
consistent with applicable laws and regulations and Section 7.3.9 herein.
7.3.9 VolP-PSTN Traffic
7.3.9.1 Local VoIP-PSTN Traffic

7.3.9.1.1 CLEC and CenturyLink will exchange Local VoIP-PSTN Traffic on the
same basis and at the same rates as Exchange Service (EAS/Local) Traffic and such
Local VolP-PSTN Traffic will be identified as such by using the originating and
terminating call detail information of each call unless the Parties specifically agree
otherwise. This call jurisdiction method described herein is intended by the Parties as a
proxy to determine the jurisdiction of a call, i.e., the actual geographic end points of the
call, and the Parties acknowledge that there may be some circumstances where the
actual geographic end points of a particular call may be difficult or impossible to
determine because of inherent technical characteristics of IP technology. At any time
during the term of this Agreement, CLEC and CenturyLink may agree on alternate
methods to establish call jurisdiction based on regulatory or technological evolution. The
Parties acknowledge that the FCC has established a schedule to ultimately reduce
terminating intercarrier compensation for VoIP-PSTN traffic to Bill and Keep.
Nevertheless, the Parties agree it is in the best interest of both Parties to work together
to establish accurate jurisdictional data and such efforts shall not be reasonably withheld
by either Party.
7.3.9.2 Toll VoIP-PSTN Traffic

7.3.9.2.1 CLEC and CenturyLink will exchange Toll VoIP-PSTN Traffic at each
Party's interstate access rates and such Toll VoIP-PSTN Traffic will be identified as
lnterLATA Traffic or IntraLATA Toll Traffic by using the originating and terminating call
detail information of each call unless the Parties specifically agree otherwise. This call
jurisdiction method described herein is intended by the Parties as a proxy to determine
the jurisdiction of a call, i.e., the actual geographic end points of the call, and the Parties
acknowledge that there may be some circumstances where the actual geographic end
points of a particular call may be difficult or impossible to determine because of inherent
technical characteristics of IP technology. At any time during the term of this
Agreement, CLEC and CenturyLink may agree on alternate methods to establish call
jurisdiction based on regulatory or technological evolution. The Parties acknowledge
that the FCC has established a schedule to ultimately reduce terminating intercarrier
compensation for V0IP-PSTN traffic to Bill and Keep. Nevertheless, the Parties agree it
is in the best interest of both Parties to work together to establish accurate jurisdictional
data and such efforts shall not be reasonably withheld by either Party.
7.3.9.2.1.1 InterLATA Traffic which is Toll VolP-PSTN Traffic will be
exchanged at each Party's interstate access tariff rates. Any Transit Traffic
which is both interLATA and Toll VoIP-PSTN will be exchanged at each Party's
interstate switched access service rates. lnterLATA Traffic which is not Toll
VoIP-PSTN Traffic shall be subject to 7.2.1.3.1.
June 7, 201 2/mms, bk/Bandwidth.com/IcC VoIP Amd/ID
Amendment to CDS-080225-0004
DouSign Ercvelope ID: 7D651 El 5-CA69-45F3-AF72-205442A79861
7.3.9.2.1.2 IntraLATA Toll Traffic which is Toll VoIP-PSTN Traffic will be
exchanged at each Party's interstate access tariff rates. Both Parties will use the
Local Interconnection Service Percent VoIP Usage (LIS-PVU) factor in Exhibit A
to determine the amount of IntraLATA Toll Traffic that shall be deemed as Toll
VoIP-PSTN Traffic. The Parties shall also apply the LIS-PVU factor to any
Transit Traffic which is IntraLATA Toll Traffic, which shall be exchanged at
interstate switched access tariff rate. The LIS-PVU factor may be updated by a
further Amendment mutually negotiated by the Parties.
7.3.9.2.1.2.1 The LIS-PVU factor shall be the percentage of total
terminating IntraLATA Toll Traffic which is Toll VoIP-PSTN Traffic, that in
the absence of such LIS-PVU, would be billed at intrastate access rates.
The LIS-PVU factor shall be based on information such as the number of
the CLEC's retail V0IP subscriptions in the state (e.g., as reported on
FCC Form 477), traffic studies, actual call detail, or other relevant and
verifiable information which will be exchanged by the parties.
7.3.9.2.1.3 The portion of LIS facilities used for Toll VoIP-PSTN Traffic will be
billed at CenturyLink's interstate access tariff rates after the application of
Relative Use Factor. CenturyLink will use the Local Interconnection Service
Facilities Percent VoIP Usage (LIS-Facility-PVU) factor in Exhibit A to determine
the portion of Entrance Facility, Direct Trunk Transport, and MUX that shall be
deemed the portion of the facility used to carry Toll Vol P-PSTN Traffic.
. 7.3.9.2.1.3.1 The LIS-Facility-PVU factor shall be the percentage of
the total traffic CLEC routes to CenturyLink for termination which is Toll
VoIP-PSTN Traffic. The CLEC shall determine their Toll VoIP-PSTN
Traffic based on information such as the number of the CLEC's retail
VoIP subscriptions in the state (e.g., as reported on FCC Form 477),
traffic studies, actual call detail, or other relevant and verifiable
information which the parties will exbhange.
7.3.9.2.1.4 CenturyLink shall provide billing adjustments on a quarterly basis
until such time as billing system modifications can be implemented to apply the
applicable rate to all Toll VolP-PSTN Traffic on an automated basis. These
adjustments shall not be treated as billing errors under PID/PAP.
7.3.9.2.1.5 Any factors established by the Parties for the previous sections of
7.3.9.2 shall be based on the particular characteristics of the traffic exchanged
within the State between CLEC and CenturyLink and shall not be subject to
adoption by anyone not a Party to this Agreement, or apply to any other service
areas.
. June 7, 201 2/mms, bk/Bandwidth.com/ICC VoIP Amd/ID
Amendment to CDS-080225-0004
QpcuSign ftvelope ID: 7D651 El 5-CA69-45F3-AF72-205442A79861
Negotiation's Template
Exhibit A
Bandwidth.com (All 14 States)
EAS I Local Traffic
Reciprocal Compensation
Election
07.12 TottVoIP.PSTNTrSffIc
Notes
-
-
7.12.1 Toll V0IP-PSTN Traffic - - - CenturyLinks
Interstate
Access Tariff
CenturyLink's
Interstate
Access Tariff
- - -
-
- 7.12.2 Local Interconnection Service VOIP Percent of
IntraLATA Usage (LIS-PVU)
- - - - 100% 100% 3 3 -
- 7.12.3 Local Interconnection Service VOIP Percent of
Facilities (LIS-Facility-PVU)
- - - 0% 0% 3 3 -
NOTES:
3 ICB, Individual Case Basis -
4
Qwest Arizona Negotiation's Template Exhibit A 19th Revision
March 7, 2011 Page 1 of 1