20090817Liberty Final Report Appendices.pdf

Qiv IE .: -oe -0 'I
Analysis
of
Qwests Performance Assurance Plans
Final Report
Appendices
Prepared for:
The Qwest Regional Oversight Committee
By:
65 Main Street
Quentin, Pennsylvania 17083
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June 30, 2009
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2009 AUG 17 AM II: 30
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Table of Contents
Appendix A: PAP Structure............................................................................................................ 1
A. Introduction..............................................................................................................1
B. Standard PAP Structure ................................................................. ..........................2
C. Differences............................................................................................................. 1 0
Appendix B: State-Specific Analysis............................................................................................21
A. Arizona................................................................................................... ...... ..........21
B. Colorado.................................................................................................................28
C. Iowa........................................................................................................................35
D. Idaho ......................................................................................................................42
E. Montana .........................................................................;.......................................49
F. Nebraska ................................................................................................................56
G. New Mexico...........................................................................................................63
H. North Dakota......................... ........................................ ........................ ...... ...........70
i. South Dakota. ................................................................ .............................. ...........77
J. Utah........................................................................................................................84
K. Wyoming................................................................................................................91
Appendix C: State-Specific Proposals ..........................................................................................98
A. Arizona...................................................................................................................98
B. Colorado...............................................................................................................100
C. Idaho ....................................................................................................................102
D. Iowa......................................................................................................................104
E. Montana ...............................................................................................................1 06
F. Nebraska..............................................................................................................108
G. New Mexico..................................................................................... ....................110
H. North Dakota........................................................................................................ 112
i. South Dakota................................................................................... ........ ........ .... .114
J. Utah......................................................................................................................116
K. Wyoming..............................................................................................................118
Appendix D: Glossary of Acronyms......................................................... .................. ................ 120
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Appendix A: PAP Structure
A. Introduction
Although many of the features of the PAPs are common throughout the 11 participating states,
there are some significant differences among them. This appendix provides a summary of the
provisions in the most common ("standard") PAP structure, and a listing of some of the key
differences that Liberty has identified from that structure in the PAPs ofthe participating states.
The following list provides PAP versions Liberty understands to be effective in the paricipating
states as of the date of this report:
. Arizona: SGA T Fourteenth Revision, Fourth Amended Exhibit K, dated June 22,
2007
. Colorado: SGA T Ninth Revision, Sixteenth Amended Exhibit K, dated January 2,
20091
. Idaho: SGA T Third Revised, Sixth Amended Exhibit K, dated June 26, 2007
. Iowa: SGA T Sixth Revision, Fifth Amended Exhibit K, dated June 26, 2007
. Montana: SGAT Fifth Revision, Fourth Amended Exhibit K, dated November 30,
2004
. Nebraska: SGAT Sixth Revision, Fifth Amended Exhibit K, dated June 26, 2007
. New Mexico: SGAT Eleventh Revision, Fifth Amended Exhibit K, dated June 26,
20072
. North Dakota: SGA T Exhibit K, dated June 22, 2007
. South Dakota: SGA T Exhibit K, dated June 22, 2007
. Utah: SGAT Seventh Revision, Fifth Amended Exhibit K, dated June 26, 20073
. Wyoming: SGAT Sixth Revision, Fifth Amended Exhibit K, dated June 26, 2007.
i This version of
the CPAP became effective after the end of the Study Period for Libert's analysis (January 2004
through October 2008).2 This version of the New Mexico PAP became effective on May i, 2009, after the end of the Study Period for
Liberty's analysis.3 In an order in Docket No. 07-049-3 i, issued June 30, 2008, the Public Service Commission of Utah approved the
changes to the Utah PAP recommended by the 2007 Stipulation, but only for those CLECs who were par to the
Stipulation. This amended version of the Utah PAP is the SGAT Seventh Revision, Fifth Amended Exhibit K, dated
June 26, 2007. More recently, in an order in Docket No. 08-049-50, issued February 4, 2009, the Commission
extended the applicabilty of the 2007 Stipulation changes to all CLECs. This order also added changes to
recognized Qwests replacement of the EDI interface by an XML interface. These changes are not yet reflected in
the SGAT Seventh Revision, Fifth Amended Exhibit K.
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B. Standard PAP Structure
1. Introduction and Plan Structure (Sections 1 and 2)
a. CLECs and Qwest voluntaily agreed to the terms.
b. It is a two-tiered, self-executing plan.
c. Tier 1 payments are made to each participating CLEC if Qwest does not provide
performance to the CLEC (as determined by the included PID measures) which is
at parity with a retail standard or does not meet a benchmark, depending on the
measure.
d. Tier 2 payments are made to a special state fund if Qwest does not provide, at a
CLEC-aggregate level1 parity with a retail standard or does not meet a benchmark.
e. Payment is generally on a "Per Occurrence" basis: a set dollar amount times the
"number of non-conforming service events." For some measures, payment is on a
"Per Measurement" basis: a set dollar payment.
f. Those measures designated as Per Occurrence are listed in Attachment 1, which
includes the following 27 measures:
(i) GA-7 Timely Outage Resolution following Softare Releases (Tier 2)
(ii) PO-3 LSR Rejection Notice Interval (Tier 1)
(iii) PO-5 Firm Order Confirmations On Time (Tierl/Tier2)
(iv) PO-6 Work Completion Notification Timeliness (Tier 1)
(v) PO-7 Biling Completion Notification Timeliness (Tier 1)
(vi) PO-8 Jeopardy Notice Interval (Tier 1)
(vii) PO-9 Timely Jeopardy Notices (Tier 1)
(viii) PO-16 Release Notifications (Tier 2)
(ix) PO-20 Manual Service Order Accuracy (Tierl)
(x) OP-3 Installation Commitments Met (Tierl/Tier2)
(xi) OP-4 Installation Intervals (Tierl/Tier2)
(xii) OP-5a, b New Service Quality (Tierl/Tier2)
(xiii) OP-6 Delayed Days (Tierl/Tier2)
(xiv) OP-8 Number Portbilty Timeliness (Tierl/Tier2)
(xv) OP-13a Coordinated Cuts On Time - Unbundled Loops (Tierl/Tier2)
(xvi) OP-17 LNP Disconnect Timeliness OP-17 (Tierl/Tier2)
(xvii) MR-3 Out of Service Cleared within 24 hours (Tier 1)
(xvii) MR-5 All Troubles Cleared within 4 hours (Tier 1)
(xix) MR-6 Mean time to Restore (Tier 1)
(xx) MR-7 Repair Repeat Report Rate (Tierl/Tier2)
(xxi) MR-8 Trouble Rate (Tierl/Tier2)
(xxii) MR-ll LNP Trouble Reports Cleared within Specified Timeframes
(Tierl/Tier2)
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(xxii) 81-1 Time to Provide Recorded Usage Records (Tierl/Tier2)
(xxiv) BI-3 Biling Accuracy-Adjustments for Errors (Tier 1)
(xxv) BI-4 Biling Completeness (Tierl/Tier2)
(xxvi) NI-l Trunk Blocking (Tierl/Tier2)
(xxvii) NP-l NXX Code Activation (Tierl/Tier2)
g. Two additional measures are also effectively Per Occurrence measures: the
collocation measures CP-2 (Collocations Completed within Scheduled Intervals)
and CP-4 (Collocation Feasibilty Study Commitments Met). Payments for these
two measures are specified in Section 6.3, Table 3.
h. Those measures designated as Per Measurement are listed in Section 7.4, which
includes the following eight measures:
(i) GA-l: Gateway Availabilty - IMA-GUI (Tier2)
(ii) GA-2: Gateway Availabilty - IMA-EDI (Tier2)
(iii) GA-3: Gateway Availability - EB-TA (Tier2)
(iv) GA-4: System Availabilty - EXACT (Tier2)
(v) GA-6: Gateway Availabilty - GUI-Repair (Tier2)
(vi) PO-i: Pre-Order/Order Response Times (Tier2)
(vii) OP-2: Call Answered within Twenty Seconds - Interconnect
Provisioning Center (Tier2)
(vii) MR-2: Calls Answered within Twenty Seconds - Interconnect Repair
Center (Tier2).
i. Payments also escalate based on the number of months of non-conforming
performance.
j. For parity measures, the plan uses statistical scoring using z-scores to assure that
the difference is significant.
k. For benchmark measures, a "stare and compare" approach is used.
2. Performance Measurements (Section 3)
a) Designated (in Attachment 1) as High, Medium, or Low and either Tier 1, Tier 2,
or both Tier 1 and Tier 2.
b) For any benchmark or non-interval parity performance measure, the "One
Allowable Miss Rule" applies (Section 3.1.2): one miss is allowable when the
results would otherwise require i 00 percent performance and if
i) At the CLEC-aggregate level, the performance standard is met
ii) The CLEC-aggregate performance must be 100 percent to meet the
standard but the standard is met after applying one allowable miss at the
aggregate leveL.
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c) Some measures are designated as not automatically subject to the payment
mechanisms of the PAP but subject to the Reinstatementlemoval Process.
Currently, there are 13 such PID measures (Section 3.2):
i) GA-3 / Gateway Availabilty EB-TA;
ii) GA-4 System Availability EXACT
iii) GA-7 Timely Outage Resolution following Software Releases
iv) PO-3 LSR Rejection Notice Interval
v) PO-5D Firm Order Confirmations (FOCs) On Time (ASRs for LIS
Trunks)
vi) PO-7 Billng Completion Notification Timeliness
vii) PO-8 Jeopardy Notice Interval
viii) PO-16 Timely Release Notifications
ix) OP-17 Timeliness of Disconnects Associated with LNP Orders
x) MR-ll LNP Trouble Reports Cleared within Specified Timeframes
xi) BI-4 Biling Completeness
xii) NI-l Trunk Blocking
xiii) NP-l NXX Code Activation
d) In the Reinstatementlemoval Process (Section 3.3), if any sub-measure of the
Pil does not meet the standard for three consecutive months, it is reinstated and
wil remain in the PAP until the sub-measure has met the standard for three
consecutive months. For this determination, the Pil wil be evaluated at the
lowest level of product aggregation on a CLEC-aggregated (or the equivalent)
basis. Retroactive payments including interest (at the prime rate) wil be made.
3. Statistical Tests (Sections 4 and 5)
a. A modified Z-test wil be made for average and percentage measures, when the
sample size is greater than 30, with non-conformance defined by the calculated Z-
score larger than the critical Z-scores (Section 4.2).
b. A permutation test wil be used for sample size less than 30.
c. Qwest wil be in conformance with benchmark standards when the performance
exceeds the benchmark (Section 4.3), subject to the one-allowable miss rule
(Section 3.1.2).
d. The critical Z-scores vary with sample size (Table 1 in Section 5), ranging from
1.645 (CLEC sample size 0: 151) to 4.3 (sample size )03000) (1.645 for 1-150,2.0
for 151-300,2.7 for 301-600,3.7 for 601-3000,4.3 above 3000). A special critical
Z-score (1.04) applies to LIS Trunks, UDITs, Resale, UBL-DSI and DS-3 (OP-3,
OP-4, OP-5A, OP-6, MR-5, MR-7, and MR-8) when the sample size 0: 11, except
for examining consecutive month misses and Zones (Zone 1 and Zone 2 are
combined instead).
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e. For permutations tests, the significant level of the test wil be .05 when the critical
Z-score is 1.654, and .15 when the critical Z-score is 1.04, as specified in the rule
above (Section 4.3.1).
4. Tier 1 Payments (Section 6)
a. Payment amounts depend on whether the measure is designated as High, Medium,
or Low.
b. The payment amounts are calculated and paid monthly using the dollar amounts
per occurrence or per measure shown in Table 2 (Section 6). The details of how to
perform the calculations are given in Section 8.2 (per-occurrence PIDs) and
Section 8.3 (per-measurement Pils). These amounts escalate based on the
number of consecutive months of non-conformance. The payments range from
$150(H)/$75(M)/$25(L) per occurrence in month 1 to $800(H)/$600(M)/$400(L)
per occurrence in month 6 and then increase $100/mo in all three categories (H,
M, L) for every month of non-conformance thereafter. Once conformance is
reached after an escalation in payments, the amounts de-escalate based on the
number of consecutive months of conformance (Section 6.2.2).
c. Except for BI-3A, the PIDs listed in Attachment 2 are subject to a monthly cap
per CLEC, shown in Table 2. (These measures are 81-1, BI-3B, and BI-4.) The
caps range from $25K(H)/$1 OK(M)/$5K(L) in month 1 to
$150K(H)/$60K(M)/$30K(L) in month six and continue to escalate by
$25K(H)/$20K(M)/$5K(L) for every month after that. For BI-3A (Section 6.2.3),
the payments are based on size of the bil adjustments with the amounts and caps
given in Table 2A. No payments are required for adjustments less than $1. The
per occurrence payments range from $1 for adjustments $1 - $199.99 up to $25
for adjustments $lOOK and over. The corresponding caps for the same adjustment
levels range from $200 to $25K.
d. For collocation (Section 6.3), payments are based on CP-2 and CP-4 and depend
on the number of days the collocation jobs (CP-2) or collocation feasibilty
studies (CP-4) are late, with payments shown in Table 3. The payments range
from $150/day for completion dates i to 10 days late to $1 K/day for completion
dates more than 40 days late. The corresponding payments for feasibilty studies
range from $45/day to $300/day.
e. A minimum payment is made at the end of each year to CLECs with annual
ordering volumes of no more than 1,200 by adding amounts specified in Table 4
for each month in which there is at least one payment to that CLEC. (See Section
6.4) In Table 4, there is no specified minimum payment amount if the total
monthly payment is less than $200. The minimum payment is $1500 for total
monthly payments between $200 and $800, $2000 for total monthly payments
between $801 and $1400, and $2500 for total monthly payments over $1400. If
the payments for the year are less than the amount specified in Table 4, Qwest
wil make an additional payment equal to the difference.
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5. Tier 2 Payments (Section 7)
a. Tier 2 per-occurrence measures must have at least 10 data points per month to be
eligible for payments.
b. Payment amounts depend on whether the measure it is designated as High,
Medium, or Low. The details of how to calculate the payments are provided in
Section 9.0.
c. Non-conformance is based on aggregate CLEC results and follows the rules in
Section 4.2 (parity measurements) and Section 4.3 (benchmark measurements),
except that a critical Z-score of 1.645 is used for all parity measures except MR-2
and OP-2.
d. Except for region-wide Per Measurement measures (Section 7.4), Tier 2 payments
depend on performance in multiple months as follows:
l. For Tier 2 measurements with Tier 1 counterpars, payments are made
when there are three consecutive months of non-conformance or, if two
out of three months for the 12-month period are non-conformance, in the
second consecutive month.
ii. For Tier 2 measurements without Tier 1 counterparts, payments are made
when there are three consecutive months of non-conformance or, if two
out of three months for the 12-month period are non-conformance, in the
current month.
e. Some Tier 2 PIDs are calculated on a region-wide basis (Section 7.4). The
payments for these measures are based on Table 6. The measures are:
1. GA-l Gateway Availabilty - IMA-GUI
11. GA-2 Gateway Availabilty - IMA-EDI
111. GA-3 Gateway Availabilty - EB- TA
iv. GA-4 Gateway Availability - EXACT
v. GA-6 Gateway Availability - GUI-Repair
Vi. PO-l Pre-Order/Order Response Times
vii. OP-2 Calls Answered within Twenty Seconds - Interconnect
Provisioning Center
viii. MR-2 Calls Answered within Twenty Seconds - Interconnect Repair
Center
ix. GA-l has two sub-measurements (GA-IA and GA-ID). PO-L has two
sub-measurements (PO-IA and PO-IB), which are aggregated together.
f. The specifics of how the state fund is to be controlled and used are provided in
Section 7.5.
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6. Low Volume, Developing Markets (Section 10)
a. If a CLEC has monthly volumes between ten and 100, Qwest wil make special
payments for a failure to meet certain sub-measurements for specified measures.
Currently these are the ADSL qualified loop disaggregation for OP-3, OP-4, OP-
5a, MR-3. MR-5. MR-7, and MR-8.
b. If, for aggregate CLEC volumes, Qwest fails to meet the standards (parity or
benchmark), it wil make a total payment according to the rules of Section 8
(using the High, Medium, and Low payment values). If the amount is less than
$5,000, a $5,000 payment wil be made. The amounts wil be allocated to the
CLECs based on each CLEC's relative share of the number of total service
misses.
7. Payments (Section 11)
a. Tier 2 payments are made to the state's special fund one month after the due date
for the performance measurement report, with interest charged for late payments.
b. Tier 1 payments to the CLECs wil be made through bil credits.
c. The special fund wil be in an interest-bearing account and wil be used for PAP
administrative expenses and oversight activities. Other uses and directions for the
fund are specified. (Section 11.3)
8. Payment Caps (Section 12)
a. Qwest wil not have to make payments exceeding the maximum cap of 36 percent
of the state ARMIS Net Return in any given year, but this cap can be increased
under certain circumstances.
9. Limitations (Section 13)
a. Qwest is not obligated to make payments if non-conformance resulted from
i. A Force Majeure event (for benchmark measures)
ii. Acts or omissions by a CLEC in violation of interconnection agreement
obligations, law, or performed in bad faith
iii. Unavoidable problems resulting from third-party systems or equipment
b. The burden is on Qwest to demonstrate that such limitations apply to specific
cases
c. Various conditions are placed on a CLEC's acceptance of the PAP
d. Qwest may start a proceeding if payment to an individual CLEC exceeds $3
milion in a month to demonstrate why the payment should not be required.
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10. Reporting requirements (Section 14)
a. Monthly reports of CLEC-specific performance to each CLEC, subject to fines for
late reporting
b. Monthly reports of aggregate CLEC performance to the Commission, subject to
fines for late reporting, and can obtain CLEC-specific information through
Commission order
c. Payment recalculations wil be limited to the preceding three years.
11. Audits (Section 15)
a. Audits wil be conducted on a 2-year cycle under the auspices of participating
ROC commissions.
b. A ROC oversight committee wil pick the independent auditor.
c. Expenses for such audits wil be paid from the Tier-2 special fund.
d. CLECs and Qwest can also ask for an independent audit to settle disputes at the
initiating paries' expense.
12. Reviews (Section 16)
a. Regular reviews occur every six months (Section 16.1). These include a review
of:
i. What performance measurements should be included
ii. Whether benchmark standards should be modified or replaced by parity
stadards
iii. Whether to change the High, Medium, and Low and the Tier 1 and Tier 2
categorization of the performance measurements.
iv. The criterion for reclassification of a measurement wil be whether the
actual volume of data points was less or greater than anticipated.
b. Criteria for review of performance measurements wil be:
i. Whether there is an omission or failure to capture intended performance
ii. Whether there is duplication of another measurement
iii. No performance measurements may be added to the PAP unless they have
subject to observation as diagnostic measurements for six months.
c. Pil Administration Forum agreements can be implemented on Commission
approval outside of the 6-month review (Section 16.1.1).
d. Any party may submit a root cause analysis to the Commission requesting
removal of a PID or sub-measure from the PAP or requesting exemption of a PID
or sub-measure from the application of the trigger mechanism for reinstatement or
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subsequent removaL. In the analysis and recommendations concerning the root
cause analysis, the Commission is to consider, at a minimum, whether the root
cause analysis provides evidence of no harm, the same har as covered by other
Pil measures, non-Qwest related causes, or other factors which directly relate to
the harm or circumstances specific to the Pil or sub-measure being analyzed.
(Section 16.1.2)
e. Two years after Qwests Section 271 approval, the Commission can participate in
a joint independent third-party review of the effectiveness of the PAP. This
review wil not be for opening the PAP "generally for amendment, but would
serve to assist Commissions in determining existing conditions and reporting to
the FCC on the continuing adequacy of the PAP to serve its intended functions."
The expense ofthe review wil be paid by the Tier 2 special fund. (Section 16.2)
f. The PAP wil be available through the CLEC interconnection agreements until
Qwest eliminates its Section 272 affliate. At that point, the Commission and
Qwest wil review whether the PAP is stil necessary. (Section 16.3)
13. Other Provisions (Sections 17 and 18)
a. The PAP is a voluntary offer of Qwest (Section 17)
b. The SGAT, section 5.18, dispute resolution provisions wil be used to settle
disputes (Section 18)
14. Classification of Measures (Attachments 1 and 2)
a. Attachment 1 lists the Per Occurrence PIDs and indicates which measures are Tier
1, Tier 2, or both, and which are High, Medium, and Low. The footnotes include
some importnt details in how the measures are treated within the PAP. In
particular,
i. Footnote a: only PO-3a-l, PO-3b-l, and PO-3c are used for measure PO-3
(however, PO-3 is currently subject to the Reinstatement/emoval
Process).
ii. Footnotes band c define measure families; i.e.., measurements within a
family share a single payment opportnity with only the measurements
with the highest payments being paid. There are 7 such familes: (1) PO-
6a/O-7a and (2) PO-6bIPO-7b (footnote - however, PO-7 is now subject
to the Reinstatementlemoval Process); (3) OP-4a/OP-6-1, (4) OP-4b/OP-
6-2, (5) OP-4c/OP-6-3, (6) OP-4d/OP-6-4, and (7) OP-4e/OP-6-5
(footnote c).
iii. Footnote d: the One Allowable Miss Rule (Section 3.1.2) only applies to
OP-5b ifthere is no more than one count in OP-5a.
iv. Footnote e: OP-6a and OP-6b results are combined in PAP calculations
resulting in 5 combined OP-6 results - (1) OP-6-1 (within MSA), (2) OP-
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6-2 (outside MSA), (3) OP-6-3 (no dispatch), (4) OP-6-4 (Zone 1), and (5)
OP-6-5 (Zone 2).
v. Footnote f: MR-6d and e only apply to xDSL-I capable loops.
vi. Footnote g: the following 18 product disaggregations are not included for
payment calculations for OP-3, OP-4, OP-5a, OP-5b, OP-6, MR-3, MR-5,
MR-6a, MR-6b, MR-6c, MR-7, and MR-8:
1. Resale Centrex
2. Resale Centrex 21
3. Resale DSO (non-designed)
4. Resale DSO (designed)
5. Resale DSO
6. E911/911 Trunks
7. Resale Frame Relay
8. Resale Basic ISDN (non-designed)
9. Resale Basic ISDN (designed)
10. Resale Basic ISDN
11. Resale Primar ISDN (non-designed)
12. Resale Primar ISDN (designed), Resale Primary ISDN
13. Resale PBX (non-designed)
14. Resale PBX (designed),
15. Resale PBX, Sub-Loop Unbundling
16. UNE-P (POTS)
17. UNE-P (Centrex)
18. UNE-P (Centrex 21).
b. Attachment 2 lists the performance measurements subject to a per measurement
cap. These measures are:
i. Time to Provide Recorded Usage Records - BI-l (Tier l/Tier 2)
ii. Biling Accuracy - Adjustments for Errors - BI-3 (Tier 1)
ll. Billng Completeness - BI-4 (Tier l/Tier 2)
C. Differences
1. General
The PAPs for the participating states can be put into two main categories.
a. The Colorado PAP (CPAP)
b. The PAPs for the other states (QPAPs).
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Prior to the latest version of the CPAP, measures were categorized as Tier lA, Tier IB, Tier LC,
and Tier 2. Tier lA, IB and LC roughly correspond to the Tier i High, Medium, and Low
categories in the QPAPs. However, the categorization depends not only on the measure but also
on the product disaggregation. In addition, while Tier IB, Tier LC, and Tier 2 use the same basic
tests as the QPAP to determine conformance, Tier lA takes a somewhat different approach. In
the latest CPAP version, Tier 1 B, Tier 1 C, and Tier 2 have been eliminated.
There two basic existing versions of the QPAPs:
a. 2004 version without the 2007 Stipulation recommended provisions: Montana and
Utah for all CLECs except those parties to the Stipulation.
b. 2007 version including all are most of the 2007 Stipulation recommendations:
Arizona, Idaho, Iowa, Nebraska, New Mexico, North Dakota, South Dakota, and
Wyoming. This is also the version used in Utah for those CLECs who were party
to the Stipulation
2. Performance Measurements (Section 3)
PID ReinstatementIemoval Process
As described above, Section 3 contains measures are listed that "are not subject to the payment
mechanisms of the PAP; however, they are subject to the Pil Reinstatementlemoval Process."
The following table shows additional measures contained in certain states:
Measure Number
PO-2B
OP-7
CP-3
State s
NM
CO
AZ,CO
The latest version ofthe Colorado PAP contains only the following measures in this section: OP-
7, OP-17A, NI-l, NP-IA, and CP-3.
The original CPAP list was as follows:
. GA-3 Gateway Availability EB-TA
. GA-4 System Availability EXACT
. GA-7 Timely Outage Resolution Following Softare Releases
. PO-2B Electronic Flow-through4
. PO-3 LSR Rejection Notice Interval
. PO-5D Firm Order Confirmations (FOCs) On Time (ASRs for LIS Trunks)
. PO-7 Filing Completion Notification Timeliness
. PO-8 Jeopardy Notice Interval
. PO-16 Timely Release Notifications
4 PO-2B is evaluated on a quarterly basis and thus reinstatement is based on two consecutive quarers rather than
three consecutive months.
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.PO-19
OP-7
OP-17
MR-ll
81-4
NI-l
NP-l
CP-3
QX-l
.
.
.
.
.
.
.
Stand-Alone Test Environment (SATE) Accuracy
Coordinated "Hot Cut" Interval - Unbundled Loop
Timeliness of Disconnects Associated with LNP Orders
LNP Trouble Reports Cleared within25 Hours
Biling Completeness
Trunk Blocking
NXX Code Activation
Collocation Feasibilty Study Interval
Timely and Complete Notifications of Product/rocess Change.5
There is no Reinstatementlemoval process for the following PAPs: Montana, and Utah, except
for the paries to the 2007 Stipulation.
3. Statistical Tests (Sections 4 and 5)
Section 5 of the PAPs contains a table with the critical z-value based on the CLEC volume
(sample size).
In all states except Arizona and Colorado, the following table and note are shown:
TIER-l CRITICAL Z-V ALUE
CLEC volume (Sample LIS Trunks,UDITs,Resale,All Other
size)UBL-OSl and OS-3
1-10 1.04*1.645
11-150 1.645 1.645
151.300 2.0 2.0
301-600 2.7 2.7
601-3000 3.7 3.7
3001 and above 4.3 4.3
. .* The 1.04 applies for individual month testing for performance measurements involving LIS trunks and DS- I and
DS-3 that are UDlTs, Resale, or Unbundled Loops. The performance measurements are OP-3d/e, OP-4d/e, OP-5a,
OP-6-4/5, MR-5a/, MR-7d/e, and MR-8.
For purposes of determining consecutive month misses, i .645 shall be used. Where performance measurements
disaggregate to zone i and zone 2, the zones shall be combined for purposes of statistical testing.
The Arizona PAP has a similar table and note, but the critical z-value remains 2.0 for any CLEC
volume greater than 300.
The Colorado PAP does not contain the column on "LIS Trunks, UDITs, Resale, UBL-DSI and
DS-3". For these products the different z-value of 1.04 for a CLEC value of 1-10 is not shown.
The Colorado PAP also does not contain the note.
5 QX- 1 is not a PID measurement but is defined specifically for the CP AP.
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4. Tier 1 Payments (Section 6)
Tier 1 Payments to CLEC
The PAPs contains tables that show the Tier 1 payments to CLECs based on High, Medium, and
Low severity and the escalating payments per month.
The standard table is as follows:
Per Occurrence
Measurement Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Each following
Group month after
Month 6 add
High $150 $250 $500 $600 $700 $800 $100
Medium $ 75 $150 $300 $400 $500 $600 $100
Low $ 25 $ 50 $100 $200 $300 $400 $100
Per ~easuremBent
Cap
Measurement Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Each following
Group month after
Month 6 add
High $25,000 $50,000 $75,000 $100,000 $125,000 $150,000 $25,000
Medium $10,000 $20,000 $30,000 $ 40,000 $ 50,000 $ 60,000 $10,000
Low $ 5,000 $10,000 $15,000 $ 20,000 $ 25,000 $ 30,000 $ 5,000
TIER 1 PAYMENTS TO CLEC
Arizona has a cap at 6 months and the penalties do not increase by the last column shown above
for both Per Occurrence and Per Measurement failures.
Colorado has a Per Occurrence of$225 (instead of$150) in Month 1 for Tier lA (High).
And, although Wyoming does have the table shown above, its PAP also states that "BI-l, BI-3B,
and BI-4 biling measurements shall be subject to a maximum per measurement cap of $30,000
for a single CLEC per month."
Tier 1 Payments for BI-3A
The PAPs contain tables that show the payments liable to the CLECs for BI-3A.
The standard table is as follows:
Total Bil Adjustment Amount Per Occurrence Cap
Amount
$0 - $0.99 $0 $0
$1 -$199.99 $1 $200
$200 - $999.99 $10 $5,000
$1,000 - $9,999.99 $10 $10,000
$10,000 - $49,999.99 $15 $15,000
TIER 1 PAYMENTS TO CLECS FOR BI-3A
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$50,000 - $99 999.99
$100,000 and over
$20
$25
$20,000
$25,000
However, the PAPs for Montana and Utah do not contain the table above.
Tier 1 Payments for Collocation
The PAPs generally contain tables that show the payments liable to the CLECs for the
Collocation measures CP-2 and CP-4. The standard table is as follows:
Days Late Completion Date Feasibilty Study
1 to 10 days $150/day $45/day
lIto 20 days $300/day $90/day
21 to 30 days $450/day $135/day
31 to 40 days $600/day $180/day
More than 40 days $1,OOO/day $300/day
TIER-l COLLOCATION PAYMENTS TO CLECS
The Arizona and Colorado PAPs do not contain the above table. In Arizona CP-L (Collocation
Installation Interval) and CP-3 (Feasibilty Study Interval) are included in the PAP along with
CP-2 and CP-4, and all four measures are listed in Attachment 1 as Per Occurrence measures:
CP-L (Tier 1 Low), CP-2 (Tier 1 High, Tier 2 High), CP-3 (Tier 1 Low), and CP-4 (Tier 1 Low).
The CPAP has special rules related to the processes measured in all four Collocation measures
shown in CP AP Appendices A and B.
5. Tier 2 Payments (Section 7)
The PAPs contains tables that show the Tier 2 payments based on High, Medium, and Low
severity and the escalating payments per month.
The standard tables are as follows:
TIER 2 PAYMENTS TO STATE FUNDS
Per Occurence
Measurement Group
High $500
Medium $300
Low $200
P M tCereasuremenAip
Measurement Group
High $75,000
Medium $30,000
Low $20,000
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Instead of the set amount shown in the tables above, Arizona has an escalating Per Occurrence
and Per Measurement Cap. The Arizona Tier 2 payment schedule follows. The Month 3
schedules match the tables above.
Measurement Month 1 Month 2 Month 3 Month 4 Month 5 Month6&
Group each following
month
High $0 $0 $500 $600 $700 $800
Medium $0 $0 $300 $400 $500 $600
Low $0 $0 $200 $300 $400 $500
ARIZONA TIER-2 PAYMENTS
Per Occurrence
er easurement ap
Measurement Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 &
Group each following
month
High $0 $0 $75,000 $100,000 $125,000 $150,000
Medium $0 $0 $30,000 $ 40,000 $50,000 $ 60,000
Low $0 $0 $20,000 $ 30,000 $30,000 $ 40,000
P M C
Nebraska also has an escalating Per Occurrence and Per Measurement Cap. The Nebraska Tier 2
payment schedule follows. Again, the Month 3 schedules match the standard tables. Unlike in
Arizona, the Tier 2 payments begin with the 1 st failure month. The maximum cap is set at the
Month 6 Per Occurrence or Per Measurement amount as in Arizona.
Measurement Group Month 1 Month 2 Month 3 Month 4 Month 5 Month 6
High $150 $250 $500 $600 $700 $800
Medium $ 75 $150 $300 $400 $500 $600
Low $ 25 $ 50 $200 $300 $400 $500
NEBRASKA TIER-2 PAYMENTS
Per Occurrence
Per Measurement ap
Measurement Group Month 1 Month 2 Month 3 Month 4 Month 5 Month 6
High $25,000 $50,000 $75,000 $100,000 $125,000 $150,000
Medium $10,000 $20,000 $30,000 $ 40,000 $ 50,000 $ 60,000
Low $ 5,000 $10,000 $20,000 $ 25,000 $ 30,000 $ 35,000
C
Prior to the latest version of the CPAP, when Tier 2 was stil active, Colorado did not have
similar tables as those shown above. The Tier 2 measures in Colorado were calculated on a
variety of Per Measurement amounts based on performance, shown in Appendix A of the CPAP.
The Per Occurrence measures had been eliminated from the CPAP in 2006.
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6. Step by Step Calculation of Monthly Tier 2 Payments to
State Funds (Section 9)
The states have a variety of methods of determining whether non-conformance for Tier 2
measures results in payments. Generally, this involves whether the performance has been sub-
stadard for a certain period of time.
The table below details each state's approach to determining whether a Tier 2 measurement is a
candidate in the current month for a Tier 2 payment based on non-conformance. As noted above,
the Colorado PAP no longer contains Tier 2 measures, but in prior versions the candidacy was
based on non-conformance in any month.
State Rules for Tier 2 Payment Candidacy
Arizona Only 3 consecutive months: Rollng basis
Uta Any month
Idaho Tier 2 measurements with Tier 1 counterpars:
3 consecutive months OR
2 out of 3 months for the 12 month period AND an additional 2 consecutive months in the
current month.
Tier 2 measurements without Tier 1 counterpars:
Any month ,
Iowa 2 out 00 consecutive months for the 12 months period AND the current month
Montana,Tier 2 measurements with Tier 1 counterpars:
Nebraska, New 3 consecutive months OR
Mexico 2 out of 3 months for the 12 month period AND an additional 2 consecutive months in the
South Dakota,current month.
and Wyoming
Tier 2 measurements without Tier 1 counterpars:
3 consecutive months OR
2 out of 3 consecutive months for the 12 months period AND the current month
North Dakota Tier 2 measurements with Tier 1 counterparts:
2 out of3 for the 12 month period AND the current month (3'd month in any 12 month period)
Tier 2 measurements without Tier 1 counterpars:
lout of 12 month period AND current month (second month during any 12 month period)
7. Colorado Tier lA
The CPAP specifies special calculations for Tier lA ("High") Parity measures that do not exist
in the other states:
... the average performance Qwest gives ere in the current month shall be
compared to the average of prior six months retail performance, subject to a
variance factor (standard performance).
Only in Colorado is the retail performance averaged over the prior six months in order to conduct
a parity comparison for Tier lA ("High") measures.
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Also, in an attempt to "minimize the impact of smaller sample sizes on the ultimate calculation",
the variance factor modifies the calculated standard based on CLEC volume, measure, and
product. Only Colorado has a variance factor that modifies the stadard for Tier lA ("High")
measures.
8. Other Provisions
There are a number of detailed differences among the PAPs regarding payment methods,
payment caps, limitations, reporting requirements, use of Tier 2 funds, and audits.
In the review section (QPAP Section 16 and CPAP Section .18), there are also a number of
detailed differences. However, the principal differences are:
. In Arizona, there are no provisions for a two-year review or a review when Qwest
eliminates its Section 272 affliate.
. In Colorado, there are no provisions for a two-year review or a review when
Qwest eliminates its section 272 affliate. However, Colorado has provisions for a
three-year review. In addition, after six years the Tier IB, Tier LC, and Tier 2 sub-
measures are automatically removed from the CPAP. However, after five and
one-half years, there wil be a review with the objective of phasing-out the CPAP
entirely. This review wil focus on ensuring that phase-out of the CPAP is indeed
appropriate at that time, and on identifying any sub-measures in addition to the
Tier lA sub-measures that should continue as part of the CPAP.
. In Montana, there are no provisions for parties to submit a root cause analysis to
the Commission requesting removal of a PID or sub-measure from the PAP or
requesting exemption of a PID or sub-measure from the application of the trigger
mechanism for reinstatement or subsequent removaL.
. In New Mexico, there are no provisions for the review after Qwest eliminates its
Section 272 affliate. Instead, like Colorado, sub-measures are automatically
eliminated from the PAP after six years. The ones to remain are listed in
Attachment 3. Like Colorado, New Mexico calls for a review with the objective
of phasing-out the PAP after five and one-half years to ensure that any sub-
measures not listed in Attachment 3 should continue in the PAP.
. In South Dakota, the review when Qwest eliminates its Section 272 affiiate
begins after Qwest petitions to eliminate the PAP.
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9.Tier 1 and Tier 2 Measurements
(Attachments/Appendices) 6
8. Attachment 1 / Appendix A
Measures
Attchment 1 of Exhibit K contains the list of measures that are eligible for Tier 1 and/or Tier 2
payments along with whether they have High, Medium, or Low penalties.
Idaho, Iowa, Montana, Nebraska, North Dakota, South Dakota, Utah, and Wyoming have the
same list of measures and the same High, Medium, and Low assessments in this Attachment.
Arizona includes an additional four measures, PO-19, CP-L, CP-2, CP-3, and CP-4 along with
their High, Medium, and Low assessments. Additionally, Arizona has a High Tier 2 assessment
for measures OP-3, OP-4, OP-5a and b, OP-6, MR-7, and MR-8 while the states listed above
have a Medium Tier 2 assessment for these measures.
New Mexico includes an additional two measures, PO-2b and PO-19a along with their High,
Medium, and Low assessments.
The CPAP for Colorado has the most differences for the measures eligible for Tier lA payments.
As indicated previously, the Colorado PAP now only contains Tier lA (High) measures.
Colorado also includes OP-7A as a Tier lA measure. Also, in the CPAP disaggregations and
products for PO-5 and PO-9 are included as Tier 1 (High) while in other states they are Low.
Note Diferences on Families
Notes are included in Appendix A of the CPAP and Attachment 1 of the QPAPs.
There are differences in the familes of measures with payment opportnities.
For PO-6 and PO-7, all of the QPAPs have the same footnote:
PO-6 is included with PO-7 as two 'families:" PO-6a/PO-7a and PO-6b/PO-7b.
Measurements within each family share a single payment opportunity with only
the measurements with the highest payment being paid.
The CPAP, however, does not indicate this family relationship since PO-6 and PO-7 are not Tier
lA measures.
6 The QPAPs have attachments, usually Attchment i and Attachment 2. The CPAP has Appendix A and Appendix
B, which provides similar information.
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For OP-4 and OP-6, all ofthe QPAPs have the same footnote:
OP-4 is included with OP-6 as five "familes:" OP-4a/OP-6-1, OP-4b/OP-6-2,
OP-4c/OP-6-3, OP-4d/OP-6-4, and OP-4e/OP-6-5. Measurements within each
family share a single payment opportunity with only the measurement with the
highest payment being paid.
The CP AP has the equivalent condition but with somewhat different language:
Submeasures for OP-4 are included with OP-6 as "familes" OP-4A with (OP-
6A-1 & OP-6B-1 combined); OP-4B with (OP-6A-2 & OP-6B-2 combined); OP-
4C with (OP-6A-3 & OP-6B-3 combined); OP-4D with (OP-6A-4 & OP-6B-4
combined); and OP-4E with (OP-6A-5 & OP-6B-5 combined). Submeasures
within each family share a single payment opportunity with only the sub measure
(OP-4 or OP-6A & OP-6B combined) with the highest payment being paid.
For OP-6, all of the QPAPs have the same footnote:
For purposes of the PAP, OP-6a and OP-6b wil be combined and treated as one.
The combined OP-6 breaks down to OP-6-1 (within MSA), OP-6-2 (outside
MSA), OP-6-3 (no dispatch), OP-6-4 (zone 1), and OP-6-5 (zone 2).
However, the CP AP does not have any such combination rule for OP-6.
The Arizona PAP extends the family concept to the OP-3 measure while no other states do:
OP-3 is included as three "familes:" OP-3a/3b, OP-3c, and OP-3d/e. Measurements within each
family share a single payment opportnity with only the measurement with the highest payment
being paid.
Product Disaggregation Exclusion Diferences
In all states except Colorado, Montana, and Utah there is a note indicating the product
disaggregations that are excluded from measures OP-3, OP-4, OP-5 (A,B), OP-6, MR-3, MR-5,
MR-6 (A,B,C), MR-7, and MR-8.
The products listed are:
Resale Centrex, Resale Centrex 21, Resale DSO (non-designed), Resale DSO (designed), Resale
DSO, E9ll/91l Trunks, Resale Frame Relay, Resale Basic ISDN (non-designed), Resale Basic
ISDN (designed), Resale Basic ISDN, Resale Primary ISDN (non-designed), Resale Primary
ISDN (designed), Resale Primary ISDN, Resale PBX (non-designed), Resale PBX (designed),
Resale PBX, Sub-Loop Unbundling, UN-P (POTS), UN-P (Centrex), and UNE.P (Centrex
21).
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In Colorado, the PAP does not include any of the above products for this list of measures, except
for Sub-Loop Unbundling which is applicable for OP-3A, OP-3B, OP-4A, OP-4B, OP-6A-l,
OP-6B-l, OP-6A-2, and OP-6B-2.
Additionally, in all states except Arizona and Colorado, MR-6D and MR-6E have a note that
they are "Applicable only to xDSL-I capable loops." For these measures in Arizona, they are
"Applicable only to EELs-DSl level and xDSL-I capable loops." The Colorado PAP does not
contain this note and products for MR-6D and MR-6E include LIS Trunks, Unbundled Analog
Loops, Unbundled Non-loaded Loops (2-wire), Unbundled Non-loaded Loops (4-wire),
Unbundled DSI-Capable Loops, Unbundled xDSL-I Capable Loops, Unbundled ISDN-Capable
Loops, Unbundled Loops ofDS3 and Higher, and Enhanced Extended Loops (DSI Level).
b. Attachment 2
Attachment 2 of Exhibit K lists the Performance Measurements Subject to Per Measurement
Caps. These include BI-l, BI-3, and BI-4. The Wyoming PAP includes a note that "81-1, BI-3B
and BI-4 shall be subject to a maximum per measurement cap of $30,000 for a single CLEC per
month." The Colorado PAP does not include an Attachment 2 and has an overall payment (not
based on per measurement caps).
c. Attachment 3
Among the participating states,7 only New Mexico has an Attachment 3, which lists the
Performance Measurements Subject to Continuation Beyond Six-Year Review.
d. Appendix B
Only Colorado has an Appendix B which provides "any modifications to the definitions,
formulas, or standards, or other aspects of the business rules set forth in the PIDs in Exhibit B, as
well as the definitions and business rules for any measurements, that apply uniquely to the
CPAP."
7 The Washington PAP has a similar Attchment 3.
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Appendix B: State-Specific Analysis
A. Arizona
Arizona's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were erratic, but slowly dropped over time, especially in 2008. In late 2004 and early
2005, payments were in excess of $100,000 in many months. Since early 2008, payments have
averaged less than $30,000 per month. The figure below shows total payments in Arizona, with
Tier 1 and Tier 2 in red and black, respectively. Tier 2 payments fell more than Tier 1 payments
over time, partly because Tier 2 payments only begin at the third month of non-conforming
service whereas Tier 1 payments begin in the first month of non-conformance. Occasional
failures, resulting in Tier 1 payments, continued to occur through 2008, but consistent failures
(three or more months in a row) all but ended by that time.
Fi ure 1: Arizona Pa ment Totals
AZ :Tier 1 and 2 Payments Totals
$150,000
$100.000
$50,000
$0
8 ..8 ....io io io io g (0 (0 (0 r-r-r-r-co co .co88888888888888888NNNNNNNNNNNNNNNNNNNNi:..i:a.0 ..i:li 0 la i:li 0 la i:a.0 ..i:a.II II ::(1 (1 II ::~::(1 ::(1 ~II ::(1'"::'"(J Cl ::'"(J ::'"(J Cl ::'"(J ::'"(J
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The next figure shows Arizona Tier 1 payments by domain. While payments related to Biling
dominated in the early part of the Study Period, payments related to Provisioning and
Maintenance & Repair quickly grew, so that by late 2004, most payments were related to OP and
MR measures. After December 2004, OP and MR payments typically accounted for 80 to 90
percent of total Tier 1 payments.
Fi ure 2: Arizona Tier 1 Pa
AZ :Tier 1 Payments by Domain
$120,000
$100,000
. 81
. PO
. OP
. MR
. OTHER
$ 80,00
$60,000
40.000
$20,000
$ 0
§§§§§~~~~~~áiæ§li~æ§,~~æ§..:2 .. t/ .. :2 .. w 0 :2 ..
~ ~ ~
l ~ ~
~ ~ ~§ li ~.. t/ ..
gs gs gssa.~ ~ "
~ ~ l
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Tier 2 payments for Arizona were dominated by MR measures until early 2006, when OP
measures became responsible for most of Tier 2 payments. Prior to 2006, Tier 2 payments for
Arizona frequently totaled more than $40,000; in 2008, however, Tier 2 payments were usually
far less than $20,000 per month. The figure below details Tier 2 payments for Arizona by
domain.
Fi
p. :Tier 2 Payments by Domain
$ 80,000
. BI
. PO
. OP
. MR
. OTHER
$ 60,000
$40,000
$20,000
$°
"l "l "l "l
~
U'U'U'U'i.
~8 i.r-r-r-r-co
~
co88~0
~8 8 8 8 8 8 8 8 8 8 ~0NNN N N N N N N N N N N NC..c ár li ..c ár 0 ..c ár ~
..c ár 0 ..c árltlt::lt ::~lt ::lt ::~lt ::..:E ..(f ci :E ..(f :E ..(f :E ..(f :E ..(f
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Arizona's overall monthly order volumes have declined significantly over the course of the
Study Period as shown in Figure 4. These losses were driven primarily by the TROITRRO
decisions, which removed the requirement for Qwest to offer UNE.P and Line Sharing as
unbundled network elements under Section 251 of the 1996 Telecommunications Act. Volume
for both LNP and UNE Loop orders have also declined somewhat during this timeframe. Resale
order volumes in Arizona were never very significant. LNP orders are by far the currently
dominant ordering type.
50.000
40,000
41
E:: 30000Õ .;:..41
"Eo
Figure 4: Arizona Ordering Volumes
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
im LNP
20,000
10,000
a
-. -.-.-.-.I!I!I!I!to to to to I'I'I'I'eo eo eo0000000000000000000000000000000000000000NNNNNNNNNNNNNNNNNNNN1:..I:a.(,..I:a.(,..I:a.(,..I:a.(,..I:a.
(0 (0 ::\I \I (0 ::\I \I (0 ::\I \I (0 ::\I \I (0 ::\I.. :;..(J Cl :;..(J Cl :;..(J Cl :;..(J Cl :;..(J
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Performance Assurance Plans
As shown on Figure 5, UN-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRO decisions. Arizona also experienced declining volumes of Resale
lines during the Study Period. UNE Loops and lines provided thröugh other services have held
relatively constant throughout this period.
500,000
400,000
CI(.
Æ 300,000
.5
:ßi: 200,000~
100,000
Figure 5: Arizona Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
0
"'"'"'"'"'1.1.1.1.(0 (0 (0 (0 I'I'I'I'co co co000880808088008888000000000000NNNNNNNNNNNNNNNNNNNNi:..i:a-u ..i:a-u ..i:a-u ..i:a-u ..i:atlOlO::(I (I lO ::(I (I lO ::(I (I lO ::(I lU lO ::..::..(/Cl :a ..(J Cl ::..(J Cl ::..(/Cl ::..(J
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Table 1 shows the monthly CLEC aggregate order volumes for Arizona from January 2007
through October 2008 for the six products Libert recommends for removal from the OP
measures in the PAP. Orders for Loops with Condition exceeded ten transactions per month only
in July 2008. All the other products had very low order volumes.
Date UBL-DS3 UDIT-UBL4W Loops with UBL-ISDN Line
Loop Above DSI Non-Loaded Conditioning Capable Sharing
Loop Loop
Jan 2007 0 0 0 3 4 0
Feb 2007 0 1 0 3 4 0
Mar 2007 0 3 0 9 2 0
Aor 2007 0 3 0 S 2 0
Mav 2007 0 2 0 7 3 0
June 2007 0 2 0 10 6 0
July 2007 0 3 0 7 3 0
Aug 2007 0 1 0 4 2 0
Seo 2007 0 2 0 6 3 0
oct 2007 0 1 0 4 4 0
Nov 2007 0 0 0 i 3 0
Dec 2007 0 2 0 2 2 0
Jan 200S 0 4 0 5 0 0
Feb 200S 0 2 0 2 2 0
Mar 200S 0 1 0 2 0 0
Aor 200S 0 0 0 3 4 0
May 200S 0 0 0 10 0 0
June 200S 0 0 0 3 1 0
July 200S 0 0 0 15 1 0
Aug 200S 0 0 0 4 1 0
Sep 200S 0 0 0 3 0 0
Oct 200S 0 0 0 3 0 0
Table i
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Arizona
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Table 2 shows the monthly trouble report volumes in Arizona for the four products (UBL-DS3
Loop, UDIT-Above DSl, UBL 4-Wire Non-Loaded Loop and Line Sharing) that Liberty
recommends for removal from the MR measures in the PAP. Also shown are the volumes for the
UBL-ISDN Capable Loop product. Liberty believes that the trouble report volumes for this
product are sufficiently high that it should remain as a product disaggregation for MR measures
in Arizona. Liberty also notes that this product disaggregation in the MR measures produced
$24,937 in Tier 1 and $66,800 in Tier 2 penalty payments in Arizona from January 2007 through
October 2008.
UBL4W UBL-
Date UBL DS3 UDIT-Non-ISDN Line
Above DSl Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 35 5
Feb 20070 1 0 31 3
Mar 2007 0 0 0 34 6
Apr 2007 0 0 0 2S 3
May 2007 0 1 0 27 3
June 2007 0 2 0 24 1
July 2007 0 3 0 59 3
Aug 2007 0 2 0 52 3
Sep 20070 4 0 39 1
Oct 2007 0 3 0 29 4
Nov 2007 0 1 0 20 2
Dec 2007 0 1 0 23 3
Jan 200S 0 2 0 27 1
Feb 200S0 0 0 17 3
Mar 200S 0 3 0 25 0
Apr 200S 0 1 0 11 0
May 200S 0 0 0 16 0
June 200S 0 1 0 is 1
July 200S 0 1 0 21 3
Aug 200S 0 0 0 23 5
Sep 200S0 I 0 25 2
Oct 200S 0 2 0 24 5
Table 2
Trouble Report Volumes for Selected Products
January 2007 through October 2008
Arizona
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B. Colorado
Colorado's Tier 1 and Tier 2 payments were frequently above $200,000 per month in 2004. Until
April 2006, Tier 2 payments were a significant portion of total payments and frequently the
majority. However, as discussed in the report, changes instituted in the CPAP in 2006 caused
Tier 2 payment to all but disappear after April 2006.
The figure below shows CPAP payments during the Study Period, by month,'By the middle of
2006, payments rarely exceeded $50,000 per month. Payments in 2008 were the lowest of any
year and exceeded $25,000 once, in August.
Fi ure 6: Colorado Pa ment Totals
$600,000
$400,000
$200,000
CO :Tier 1 and 2 Payments Totals
$°
""""""""""i.i.
~
i.((((((¡g ........00 00 0000800~~~0 0 0 0 0 0 0 0 0 0~0 0 0 0 0 0 0 0 ~0 ~0 0 0(\(\(\(\(\(\(\(\(\(\(\(\(\c ..C 0.(.l¡c !i u (a C 0.U A;C 0.(.~C 0.lI lI :i Gl Gl :i Gl :i !I !I :i !I l1 :i !I..:æ ..(j c::æ ..(f c::æ ..(f c::æ ..(f c::æ ..(f
June 30,2009 Page 28~,~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
The next figure shows Colorado Tier 1 payments by domain. Payments related to Biling and
Maintenance & Repair (BI and MR) dominated throughout the Study Period, while OP payments
were occasionally substantiaL.
Fi ure 7: Colorado Tier 1 Pa
CO :Tier 1 Payments by Domain
$300,000 . BI
. PO
. OP
. MR
. OTHER$250,000
$200,000
$150,00
$ 50,000
$100.000
$ °
88 8 8 8 8 8 8 8 ~ 8 ~N8 N8 ~N8 ~ N8 N8 N8 N8 N8NN N N N N N N N N N . n
¡¡~ § g-oál~ § g-ij æ §'~o:r~""§'~oál æ §,~..:æ .. (í "".. (í 0 :æ .. YJ "' YJ :æ.. w
June 30. 2009 ~,~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Tier 2 payments for Colorado were dominated by PO and MR measures until early 2006, when
Tier 2 payments virtually ended, due to the structural CP AP change described in the report. The
figure below details Tier 2 payments for Colorado by domain.
Fi Domain
CO :Tier 2 Payments by Domain
$500,00
. 61
. PO
. OP
. MR
. OTHER
$400,000
$300,000
$200,000
$100,000
$°
88 ~"'~8 to g 8 ig 8 i.8 8 I'I'8 00 ~~8 8 8 8 0 8000000 0 0NNNNNNNNNNNNNNNNNNNN
i: ..i:Q.u ..i:a.u ..i:a.u ..i:a.u ..i:Q.tt tt :i (1 (1 tt :i (1 ~tt :i (1 ~tt :i (1 (1 tt ::(1.. ::..(J Q ::..(J ::..(J ::..(J Q ::..(J
Colorado's overall monthly order volumes have declined significantly over the course of the
Study Period as shown in Figure 9. These losses were driven primarily by the TROITRRO
decisions, which removed the requirement for Qwest to offer UNE-P and Line Sharing as
unbundled network elements under Section 251 of the 1996 Telecommunications Act. Colorado
experienced a significant increase in the order volumes for UN Loops in the middle of 2005,
but since then UNE Loop order volumes have declined. Resale order volumes have also
declined, but these orders have never been a significant component of orders in Colorado. LNP
order grew significantly in 2005 and then declined. Since the middle of 2006, the LNP volumes
have been fairly constat.
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
30,000
(J
§ 20,000Õ::
ij
;5
10.000
Figure 9: Colorado Ordering Volumes
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
fD LNP
o
June 30, 2009 Page 31~~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwest's
Peñormance Assurance Plans
As shown on Figure 10, UNE-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Colorado also experienced declining volumes of Resale
lines during the Study Period. UN Loops and lines provided through other services have held
relatively constant throughout this period.
500.000
400,000
CI().~
CI 300,000
U)
.5
II
CIi: 200,000::
100,000
Figure 10: Colorado Lines in Service
. UNE LOOPS 8. OTHER
. UNE-P 8. LINE SHARING
. RESALE
0
'I 'I 'I 'I 'I i.i.i.i.to to to to t-t-t-t-eo eo eo0000000000000000000000000000000000000000"'N "'"'"'"'"'"'"'"'"'"'"'"'"'"'"'"'"'"'i= ..i=a.(...i=c.(...i=a.(...i=a.(...i=a.m m :¡\l \l m :¡\l \l m :¡\l \l m :¡\l \l m :¡\l..~..(j 0 ~..(j 0 ~..(j 0 ~..(j 0 ~..(j
June 30, 2009 Page 32~~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 3 shows the monthly CLEC aggregate order volumes for Colorado from January 2007
through October 2008 for the five products Libert recommends for removal from the OP
measures in the CPAP. Line Sharing was removed from the CPAP in 2006. However, Liberty
reexamined the volumes for this product in Colorado, and confirmed the appropriateness of
removing this product. The table shows that Line Sharing order volumes exceeded ten
transactions per month in only three months during this period. These months were early in
2007, with significant reduction in volumes since July 2007, presumably because of the
TROITRRO phase-out mechanism.
Date UBL-DS3 UDIT-UBL4W Loops with UBL-Line Sharing
Loop Above DSI Non-Loaded Conditioning ISDN
Loop Capable
Loop
Jan 2007 0 0 0 4 2 10
Feb 2007 0 5 0 0 3 40
Mar 2007 0 i 0 2 5 7
Apr 2007 i 7 0 4 3 36
May 2007 0 5 0 4 3 9
June 2007 0 i 0 4 1 20
July 2007 0 1 0 6 4 i
Aug 2007 0 3 0 3 0 i
Sep 2007 0 4 0 1 i 0
Oct 2007 0 2 0 i 0 3
Nov 2007 0 1 0 2 0 3
Dec 2007 0 0 0 5 0 1
.Jan 200S i 1 0 0 0 3
Feb 200S 0 3 0 5 i i
Mar 200S 0 0 0 i 3 3
Apr 200S 0 i 0 2 i 0
May 200S 0 0 0 i 3 1
June 200S 0 i 0 0 2 2
July 200S 0 2 0 4 5 i
Aug 200S 0 2 0 4 5 1
Sep 200S i 4 0 i i i
Oct 2008 0 4 0 2 i 1
Table 3
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Colorado
June 30. 2009 ~~
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Final Report Appendices Analysis of Qwest's
Peñormance Assurance Plans
Table 4 shows the monthly trouble report volumes in Colorado for the three products (UBL-DS3
Loop, UDIT-Above DS1, and UBL 4-Wire Non-Loaded Loop) that Liberty recommends for
removal from the MR measures in the CPAP. Also shown on the table are the Colorado volumes
for Line Sharing and the UBL-ISDN Capable Loops. Liberty believes that the trouble report
volumes for UBL-ISDN Capable Loops are suffciently high that it should remain as a product
disaggregation for MR measures in Colorado. Liberty also notes that this product disaggregation
in the MR measures produced $34,132 in Tier 1 penalty payments in Colorado.
UDIT-UBL4W UBL-ISDN LineDateUBL-DS3 Above DSI Non-Loaded Capable SharingLoopLoop
Jan 2007 0 1 0 . 39 6
Feb 2007 0 1 0 14 5
Mar 2007 0 3 0 22 S
Apr 2007 1 1 0 21 2
May 2007 0 2 0 15 6
June 2007 0 3 0 20 7
July 2007 0 1 0 is 7
Aug 2007 0 4 0 31 1
Sep 2007 0 5 0 14 3
Oct 2007 0 2 0 16 7
Nov 2007 0 3 0 16 4
Dec 2007 0 3 0 11 0
Jan 200S 1 2 0 16 4
Feb 200S 0 2 0 16 2
Mar 200S 0 3 0 14 6
Apr 200S 0 2 0 10 1
May 200S 0 3 0 13 4
June 200S 0 2 0 10 2
July 200S 0 4 0 14 3
Aug 200S 0 3 0 14 S
Seo 200S 1 4 0 6 4
Oct 200S 0 3 0 3 4
Table 4
Trouble Report Volumes for Selected Products
January 2007 through October 2008
Colorado
June 30, 2009 ~,~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
C. Iowa
Iowa's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were erratic, but slowly dropped over time, especially in 2008. In late 2004 and early
2005, payments were in excess of $20,000 for many months. Since early 2008, payments have
averaged less than $20,000 per month. The figure below shows total payments in Iowa, with Tier
1 and Tier 2 shown in red and black, respectively. Occasional failures, resulting in Tier i
payments, continued to occur through 2008.
Fi ure 11: Iowa Pa ment Totals
IA :Tier 1 and 2 Payments Totals
$20,000
$60,000
$40,000
$°"l "l "l "l ~8 in in in (0 (0 ig 8 ~~~~~~co00000gg0gg000
ia ia 0 0 0 ia ia ia 0 0 ia ia ia ia iaNNNNNNNNc:L C 0.:i æ c Q.:i ..c Q.U ..C Q.:i æ c Q.ie\1 ::Q)::Q)\1 ::Q)Q)\1 ::~::~.. :E ..CI 0 :E ..CI 0 :E ..CI 0 :E ..0 :E ..
June 30, 2009 ~,~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
The next figure shows Iowa Tier 1 payments by domain. While payments related to Biling
dominated in the early part of the Study Period, payments related to Provisioning and
Maintenance & Repair quickly grew, so that by late 2004, most payments were related to OP and
MR measures. After December 2004, OP and MR payments typically accounted for 80 percent
oftotal Tier 1 payments, but occasionally Biling accounted for significant payments, even in the
later years.
Fi
IA :Tier 1 Payments by Domain
$60,000
. 81
. PO
. OP
. MR
. OTHER
$40,000
$20,000
$0 .. ......c'io io io io to to to to b b r-r-~~~00 ~0 ~~8 0 0 0 0 0 0 ~ia i;0 i;0 ~~ia i;i;i;i;ia i;iaNNNi:..i:a.:6
..i:0-ál (¡i:0-ál
..i:a.:6 æ i:0-R! R!::Q)R!::Q)::Q)R!::Q)::Q).. :E ..(J Cl :E ..(J Cl :E ..(J Cl :E ..(J Cl :E ..(J
June 30,2009 ~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Tier 2 payments for Iowa were dominated by MR measures, with OP measures occasionally
responsible for a significant percentage of payments. Overall Tier 2 payments have rarely been
above $10,000 in recent months. The figure below details Tier 2 payments for Iowa by domain.
Fi
IA :Tier 2 Payments by Domain
$20,000
$15.000
. BI
. PO
. OP
. MR
. OTHER
$10,000
$ 5.000
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Iowa's overall monthly order volumes have declined significantly over the course of the Study
Period as shown in Figure 14. These losses were driven primarily by the TROITRRO decisions,
which removed the requirement for Qwest to offer UNE-P and Line Sharing as unbundled
network elements under Section 251 of the 1996 Telecommunications Act. Iowa experienced a
brief increase in the order volumes for UNE Loops in 2005 and for Resale in 2005 and 2006.
Since that time, order volumes have dropped off significantly for Resale, and UNE Loop
volumes have been fairly constant. LNP orders have remained fairly constant since 2005.
Figure 14: Iowa Ordering Volumes
25,000
. UNE LOOPS & OTHER
. UNE-P & LINE SHAR ING
. RESALE
fi LNP
20,000
II
E:iÕ;:"-II
;5
15,000
10.000
5.000
o
.. .;.;.;.;i.i.i.i.CD CD CD CD I'I'I'I'eo eo eo0000000000000000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi: ..i:c.u ..i:c.u ..i:a-u ..i:a-u ..i:a-\\ \\::(J (J \\::(J (J \\::(J (J \\::(J (J \\::(J"" ::""(/ci ::""(/ci ::""(/ci ::""(J ci ::""(J
June 30,2009 ~,~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
As shown on Figure 15, UNE-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Iowa also experienced declining volumes of Resale lines
during the Study Period. UN Loops and lines provided through other services have also
declined during this period, but more slowly.
200,000
~ 150,000.~
(JCI
.5
ID 100,000i::.
50,000
Figure 15: Iowa Lines in Service
. UNE LOOPS 8. OTHER
. UNE~P & LINE SHARING
. RES,ALE
0
""""""""""i.i.i.i.(0 (0 (0 (0 """"""""o:o:o:0 0 0 0 8 8 0 0 0 0 8 8 8 0 0 0 8 0 8 00000000000000C\C\C\C\C\C\C\C\C\C\C\C\C\C\C\N N C\C\C\i:..i:c.(,..i:c.(,..i:fi (,..i:c.(,..i:c.lI lI :J Q)Q)ro :J Q)Q)lI :J Q)lI :J Q)Q)lI :J Q)..:E ..C/Cl ::..C/Cl ::..C/Cl ::..C/Cl :;..C/
June 30,2009 Page 39~~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Table 5 shows the monthly CLEC aggregate order volumes for Iowa from Januar 2007 through
October 2008 for the six products Liberty recommends for removal from the OP measures in the
PAP. Orders for Loops with Conditioning exceeded ten transactions per month only twice. The
volumes in the other months were very low. Order volumes for all the other products were
generally very smalL.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAboveDSlLoopConditioningCapable
Loop
Jan 2007 0 1 0 0 lO 0
Feb 2007 0 2 0 0 5 0
Mar 2007 0 2 1 0 lO 0
Apr 2007 0 0 0 4 5 0
May 2007 0 2 0 1 lO 0
June 2007 0 0 0 1 6 0
July 2007 0 1 0 0 4 0
Aug 2007 0 1 0 0 3 0
Sep 2007 0 0 0 0 2 0
Oct 2007 0 0 0 2 6 0
Nov 2007 0 0 0 1 4 0
Dec 2007 0 0 0 0 2 0
Jan 200S 0 0 0 i 4 0
Feb 200S 0 0 0 0 3 0
Mar200S 0 0 0 0 3 0
Apr 200S 0 0 0 0 1 0
May 200S 0 0 0 is 3 0
June 200S 0 0 0 0 1 0
July 200S 0 0 0 0 2 0
Aug 200S 0 0 0 0 2 0
Sep 200S 0 0 0 12 lO 0
Oct 200S 0 1 0 0 5 0
Table 5
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Iowa
Table 6 shows the monthly trouble report volumes in Iowa for the five products that Liberty
recommends for removal from the MR measures in the PAP. None of the products had more than
eight troubles in a month at the CLEC aggregate leveL.
Table 6
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Iowa
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
Above DSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 1 0 7 0
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Feb 2007 0 0 0 1 0
Mar 2007 0 i 0 6 0
Apr 2007 0 2 0 6 0
May 2007 0 I 0 3 0
June 2007 0 0 0 S 0
July 2007 0 i 0 5 0
Aug 2007 0 0 0 7 0
Sep 2007 0 0 0 5 0
Oct 2007 0 0 0 3 0
Nov 2007 0 0 0 i 0
Dec 2007 0 0 0 4 0
Jan 200S 0 0 0 7 0
Feb 2008 0 0 0 5 0
Mar 200S 0 0 0 4 0
Apr200S 0 0 0 6 1
May 200S 0 0 0 2 0
June 200S 0 0 0 6 i
July 200S 0 0 0 5 0
Aug 200S 0 i 0 7 0
Sep 200S 0 0 0 S 0
Oct200S 0 0 0 2 0
June 30, 2009 ~,~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
D. Idaho
Idaho's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were erratic, but slowly dropped over time. In late 2004 and early 2005, payments were
in excess of $5,000 in many months. S'ince early 2008, payments have averaged less than $5,000
per month. The figure below shows total payments in Idaho, with Tier 1 and Tier 2 shown in red
and black, respectively. Occasional failures, resulting in Tier 1 payments, continued to occur
through 2008, but few Tier 2 payments occurred after March 2007.
Fi ure 16: Idaho Pa ment Totals
10 :Tier 1 and 2 Paymnts Totals
$5,000
$10,000
$0
"" """"""
~
10 8 ~
10 (!
~~
(!........co co ~88 8 8 0 ~0 8 8 8 8 8 8 ~0 0 0C\ C\C\C\C\C\C\C\C\C\C\C\C\C\c: ..c:äl u ..c:Co li ..c:Co li ..c:äl u ..c:Coti ti ::ci ti ::CD ti ::CD ti ::CD tt ::CD..~..(J 0 ~..(J 0 ~..(J 0 ~..(J 0 ~..(J
June 30, 2009 ~,~
The Liberty Consulting Group
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Filial Report Appendices Analysis of Qwests
Peñormance Assurance Plans
The next figure shows Idaho Tier 1 payments by domain. Payments related to Biling are
substantial throughout the Study Period, as are payments related to Maintenance & Repair. In the
early part of the Study Period, significant payments were made related to PO measures (pre-
ordering functions).
10 :Tier 1 Payments by Domain
$15,00
. BI
. PO
. OP
. MR
. OTHER
$10,000
$5,000
$0
8 """"8 ""l£l£l£l£lO lO lO lO I'8 I'I'co co co8888~8 8 8 8 8 8 8 8 8 8 8 8NNNNNNNNNNNNNNNNNNN
c:..c:¡¡u ..i:¡¡u ..c:l ál
..c:¡¡u ..c:¡¡II II :¡Ql II :¡Q)II :¡II :¡Ql II :¡-,::-,(J 0 ::-,(J 0 ::-,0 ~-,(J 0 ::-,(J
June 30,2009 ~~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Tier 2 payments for Idaho were dominated by MR measures, with OP measures occasionally
responsible for a significant percentage of payments. Overall Tier 2 payments have rarely been
above $4,000. The figure below details Tier 2 payments for Idaho by domain.
ID :Tier 2 Paymnts by Domain
$ 8,00
. 81
. PO
il OP
il MR
il OTHER
$6,000
$4,000
$0
"' "'~"'"'0.:g :g
~
U):g :g :g ..b b ..~~~00 0 8 0 0 0 0
¡; ¡;0 ¡;¡;¡;¡;¡;¡;¡;¡;¡;¡;¡;0 ¡;0 0NNNNNc: ..I:a.
~
l-I:a.:i ..I:a.:i ..I:a.u ..I:a.!I !I ::CI !I ::~!I ::CI !I ::CI ~!I ::~.. ::..(f ::..Cl ::..(f Cl ::..(f ::..
Idaho's overall monthly order volumes have shown peaks and valleys over the course of the
Study Period as shown in Figure 19. A large decrease in order volumes from 2004 to 2005 was
driven primarily by the TROITRRO decisions, which removed the requirement for Qwest to
offer UNE-P and Line Sharing as unbundled network elements under Section 251 of the
Telecommunications Act. Idaho experienced a large increase in the ordering volumes for UNE
Loops in mid-2005. Since then, UN Loop volumes have remained fairly constant with some
minor month-over-month variabilty. Resale volumes were never very significant in Idaho. LNP
orders have remained fairly constant since 2006.
June 30,2009 ~~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Figure 19: Idaho Ordering Volumes
6.000 . UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
fí LNP5.000
4,000Q)E:JÕ::
l¡
"Eo
1,000
i- i- i- i- C( C(888888NNNNNN..cO"O..c(O::Q)(\l'::::-'(10::-'
3,00
2.000
June 30,2009 ~~
The Liberty Consulting Group
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
As shown on Figure 20, UN-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Idaho also experienced declining volumes of Resale
lines during the Study Period. UNE Loops and lines provided through other services have
remained fairly constant.
60.000
41o.~
~ 40,000
.5
CI
41i=::
20,000
Figure 20: Idaho Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
o
'O 'O0000
C\ C\
i: i-\' \'-: .:i
~~~~8~8~~~~~~~~~~~~ ~ ~ ~ C\ ~ C\ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~§ß-M~§ß-)1æ§JR.lõæ§ß-lræ§ß--: (/ ~ ~ -: (/ ~ :i -: w Q :i -: (/ Q :i -: (/
June 30, 2009 Page 46~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Table 7 shows the monthly CLEC aggregate order volumes for Idaho from January 2007 through
October 2008 for the six products Liberty recommends for removal from the OP measures in the
PAP. Orders for Loops with Condition exceeded ten transactions per month only in April 2008.
The CLEC aggregate monthly volumes for the other months were extremely low. Order volumes
for all the other products were also very smalL.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAbove DSI Conditioning CapableLoopLoop
Jan 2007 0 0 0 0 4 0
Feb 2007 0 0 0 0 1 0
Mar 2007 0 0 0 0 3 0
Apr 2007 0 1 0 0 5 0
May 2007 0 0 0 0 2 0
June 2007 0 0 0 3 1 0
July 2007 0 0 0 0 0 0
Aug 2007 0 0 0 1 3 0
Sep 2007 0 0 0 0 1 0
Oct 2007 0 0 0 0 0 0
Nov 2007 0 0 0 1 0 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 1 1 0
Feb 200S 0 1 0 3 2 0
Mar 200S 0 5 0 0 2 0
Apr200S 0 0 0 11 1 0
May 200S 0 2 0 0 1 0
June 200S 0 0 0 0 0 0
July 200S 0 0 0 0 0 0
Aug 200S 0 0 0 0 0 0
Sep 200S 0 0 0 0 0 0
Oct 200S 0 1 0 I 1 0
Table 7
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Idaho
Table 8 shows the monthly trouble report volumes in Idaho for the five products that Liberty
recommends for removal from the MR measures in the PAP. As the table shows, the number of
trouble reports was extremely low for all products. It was usually zero and never exceeded four
per month.
June 30, 2009 ~,~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 8
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Idaho
UBL4W UBL-
Date UBL-DS3 UDlT-Non-ISDN Line
AboveDSI Loaded Capable Sbaring
LooD LOOD
Jan 2007 0 0 0 3 0
Feb 2007 0 0 0 i 0
Mar 2007 0 0 0 i 0
Apr 2007 0 0 0 1 0
May 2007 0 0 0 4 0
June 2007 0 0 0 4 0
July 2007 0 0 0 0 0
Aug 2007 0 0 0 i 0
Sep 2007 0 0 0 i 0
Oct 2007 0 0 0 0 0
Nov 2007 0 0 0 i 0
Dec 2007 0 0 0 2 0
Jan 200S 0 0 0 0 0
Feb 200S 0 0 0 0 0
Mar 200S 0 i 0 o .0
Apr200S 0 2 0 3 0
May 200S 0 0 0 1 0
June 200S 0 0 0 I 0
July 200S 0 0 0 0 0
Aug200S 0 0 0 0 0
Sep 200S 0 0 0 3 0
Oct 200S 0 0 0 0 0
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
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E. Montana
Montana's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were erratic, but slowly dropped over time. In late 2004 and early 2005, payments were
in excess of $10,000 in many months. Since early 2008, payments have averaged about $6,000
per month. The figure below shows total payments in Montana, with Tier 1 and Tier 2 shown in
red and black, respectively.
Fi ure 21: Montana Pa ment Totals
MT :Tier 1 and 2 Payments Totals
$30,000
$25,000
$0 ~~8 (l ~~~~lS 8 q:8 8 8 I:r-8 co co co800088088880000000NNNNNNNNNNNNNNNNNNNNi:..i:Q.(...i:Q.u ..i:Q.u l;i:Q.
~
..i:litttt:i Q)~tt ::Q)~tt ::Q)~tt ::Q)tt :i...::..IJ ::..IJ ::..IJ ::..IJ ::-,IJ
$20,000
$15,000
$10,000
$5,000
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
The next figure shows Montana Tier 1 payments by domain. Payments related to Biling are
substantial throughout the Study Period, and payments related to Maintenance & Repair and
Provisioning grew more significant in 2007 and 2008.
Fi ure 22: Montana Tier i Pa
MT :Tier 1 Payments by Domain
$25,000
. 81
. PO
. OP
. MR
. OTHER
$20,000
$15,000
$5,000
$10,000
$0 .. ........LO LO LO LO (£(£(£:g i-i-i-i-co co co000000000000000000800000~0 0 0 0 0 0 0 0 0 0 0 0 0"IN "I "I "I "I "I "I "I "I "I "I "I "I "I "I "I "I "I
i: ..i:c.ij ..i:0.
~æ i:0.
~æ i:0.ij ..i:0.(1 (1 ::Q)(1 ::~::~::~(1 ::~.. :¡..C/Cl :¡..:¡..:¡..Cl :¡..
June 30, 2009 ~,~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Tier 2 payments for Montana were dominated by MR measures, with OP measures responsible
for a significant percentage of payments in two months in 2008. Overall Tier 2 payments have
rarely been above $2,500. The figure below details Tier 2 payments for Montana by domain.
MT :Tier 2 Paymnts by Domain
$15,000
. BI
. PO
. OP
. MR
. OTHER
$10,000
$ 5,00
8 8 ~.~~8 ~~
LO (,
~
(,¡g 8 b ..b ~
co ig000000i;¡a ¡a 0 0 ¡a 0 i;¡aNNNNNNN
s:'-s:ij l Ii s:ci l '-s:ci l '-s:ci (,l;s:ij(l (l ::::(J (l ::(J II ::(J (J (l ::..::-'.fI :E ..fI :E ..fI ::..fI 0 :E ..fI
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
As shown in Figure 24, Montaa's overall monthly order volumes declined significantly from
their peak in 2004 to 2005 driven primarily by the TROITRRO decisions, which removed the
requirement for Qwest to offer UNE-P and Line Sharing as unbundled network elements under
Section 251 of the 1996 Telecommunications Act. In the middle of2005, Montana experienced a
significant increase in order volumes, driven primarily by orders for number ports. LNP orders
have dominated since then and remained fairly constant after 2005. Resale order volumes have
continued to decline while ON Loop volumes have remained relatively constant throughout the
Study Period.
Figure 24: Montana Ordering Volumes
500
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
!' LNP
2,000
1.500lI
E::Õ;:..lI"to
1,000
'V 'V 'V 'V 'V l(l(:g l((0 (0 (0 (0 I'I'I'I'eo eo eo000000000000000000000000000000000000000C\ C\C\C\C\C\C\C\C\N C\C\C\C\N C\N C\C\C\i:'-i:i:(.'-i:i:(.'-i:i:(.'-i:i:(.'-i:i:\t \t ::(J I1 \t ::(J I1 \t ::(J c!
\t ::(J (J \t ::(J..::..(/Cl ::..(/Cl ::..(/::..(/Cl ::..(/
June 30, 2009 ~~
The Liberty Consulting Group
Page 52
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
As shown on Figure 25, UN-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Montana also experienced declining volumes of Resale
lines during the Study Period, which has been offset by gains in UN Loops and lines provided
through other services.
Figure 25: Montana Lines in Service
o
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
40,000
30.000
~.~
(J
.5 20,000
lßi:::
10,000
888(' (' ('
ti § ar
:: .. U)
June 30,2009 ~,~
The Liberty Consulting Group
Page 53
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 9 shows the monthly CLEC aggregate order volumes for Montana from January 2007
through October 2008 for the six products Libert recommends for removal from the OP
measures in the PAP. Order volumes for all the products were extremely small and never
exceeded four per month for all CLECs.
UBL4W UBL-
Date UBL-DS3 UDlT-Non-Loaded Loops with ISDN Line SharingLoopAboveDSlLoopConditioningCapable
Loop
Jan 2007 0 0 0 2 1 0
Feb 2007 0 0 0 4 0 0
Mar 2007 0 0 0 i 3 0
Apr 2007 0 0 0 0 3 0
May 2007 0 0 0 4 1 0
June 2007 0 0 0 3 0 0
July 2007 0 0 0 2 0 0
Aug 2007 0 0 0 i 2 0
Sep 2007 0 0 0 1 0 0
Oct 2007 0 0 0 3 0 0
Nov 2007 0 0 0 i 0 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 0 0 0
Feb 200S 0 0 0 2 3 0
Mar 200S 0 0 0 0 2 0
Apr200S 0 0 0 0 i 0
May 200S 0 0 0 0 0 0
June 200S 0 0 0 i 0 0
Julv 200S 0 0 0 0 0 0
Aug200S i 0 0 2 0 0
Sep 200S 0 0 0 0 0 0
Oct 200S 0 0 0 1 I i 0
Table 9
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Montana
June 30,2009 ~,~
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Final Report Appendices Analysis of Qwests
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Table 10 shows the monthly trouble report volumes in Montana for the five products that Liberty
recommends for removal from the MR measures in the PAP. The number of trouble reports was
extremely small for all the products and never exceed two per month.
Table 10
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Montana
UBL4W UBL-
Date UBL-DS3 UDlT-Non-ISDN Line
Above DSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 0 0
Feb 2007 0 0 0 0 I
Mar 2007 0 0 0 0 0
Apr 2007 0 0 0 1 0
May 2007 0 0 0 1 0
June 2007 0 0 0 1 0
July 2007 0 0 0 0 0
Aug 2007 0 0 0 1 0
Sep 2007 0 0 0 2 0
Oct 2007 0 0 0 0 0
Nov 2007 0 0 0 2 0
Dec 2007 0 0 0 2 0
Jan 200S 0 0 0 1 0
Feb 200S 0 0 0 1 0
Mar 200S 0 0 0 0 0
Apr200S 0 0 0 1 0
May 200S 0 0 0 2 0
June 200S 0 0 0 0 0
July 200S 0 0 0 1 0
Aug 200S 0 0 0 0 0
Sep 200S 0 0 0 1 0
Oct 200S 0 0 0 1 0
June 30,2009 ~,~
The Liberty Consulting Group
Page 55
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
F. Nebraska
Nebraska's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were larger in 2004, but slowly dropped over time. In late 2004 and early 2005,
payments were in excess of $1 0,000 in many months. Since early 2008, payments have averaged
less than $5,000 per month. The figure below shows total payments in Nebraska, with Tier 1 and
Tier 2 shown in red and black, respectively. Unlike several other states, Tier 2 payments
continued to be an occasional, but significant percentage of payments throughout the Study
Period.
Fi ure 26: Nebraska Pa ment Totals
$60,000
$50,000
$40,000
$30,000
$20,000
$10,000
NE :Tier 1 and 2 Payments Totals
$0 gg g "'"'8 8 g io ig ~ig ig b b r-r-~~80~0 0 000~~0 0 ~~~~~~~~0 ~NN N N N N Ni:..i:a.u ..i:a.u ..i:a.u ..i:a.u ..i:a.tt tt ::Q)Æ tt ::~Q)tt ::Q)Q)tt ::Q)Q)m ::~.. :2 ..(J :2 ..0 :2 ..(J 0 :2 ..(J 0 :2 ..
June 30,2009 Page 56~,~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
The next figure shows Nebraska Tier 1 payments by domain. Payments related to Biling were
substantial through 2005. Payments related to Maintenance & Repair were smaller and fell off
after 2005.
Fi Domain
NE :Tier 1 Payments by Domain
$30,000
. BI
. PO
. OP
. MR
. OTHER
$10.000
$20,000
$
(5. .(5 (5 (5 "'on on on on 8 8 8 8 15 r-15 r-co fÆ fÆ0000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi:i.c:li u ..c:a-u (a c:li u ..c:a-~
..c:,(Ø II ::t3
II ::~Q)::Q)II ::~l\::.. :l ..(J :l ..Cl :l ..(J Cl :l ..:l ..
June 30, 2009 ~,~
The Liberty Consulting Group
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Tier 2 payments for Nebraska were dominated by Biling measures in the early period and MR
and OP measures in the later period. Overall Tier 2 payments have rarely been above $5,000.
The figure below details Tier 2 payments for Nebraska by domain.
Fi Domain
NE :Tier 2 Payments by Domain
$30,000
$25,000
. BI
. PO
. OP
. MR
. OTHER
$20,000
$15,000
$10,000
$5,000
$°gg g "'"'LO LO LO in (,ig ig (,f'f'f'f'co co ig00~~~0 0 0 0 0 8 0 0 0
gi gi 0 0 gi gi 0 gi gi gi gi gi 0 0 gi 0NNNNNNN
i: ..i:a.e...i:a.lr ..i:a.lr ..i:a.e...i:a.
(I (I ::dl ~(I ::~(I ::~(I ::dl dl (I ::dl.. ::..(J ::..0 ::..0 ::..(J 0 ::..(J
June 30,2009 ~~
The Liberty Consulting Group
Page 58
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
As shown in Figure 29, Nebraska's overall monthly order volumes declined from their peaks in
2004 to 2005, driven primarily by the TROITRRO decisions,whic h removed the requirement for
Qwest to offer UNE-P and Line Sharing as unbundled network elements under Section 251 of
the 1996 Telecommunications Act. Since the start of 2005 there has not been too much
variabilty in the total monthly order volumes in Nebraska with the exception of a single-month
spike in June 2005. Nebraska has experienced a generally gradual decline in Resale orders, and
to a lesser extent in UN Loop orders, throughout the Study Period. There has been a slight
decline in LNP orders but this ordering type dominates.
Figure 29: Nebraska Ordering Volumes
8,000
. UNE LOOPS & OTHER
. UNE~P & LINE SHARING
. RES,ALE
!l U~P
6,000$
E::Õ:;
l6
~
4,000
2,000
0
'V 'V 'V 'V 'V 1.1.1.1.(0 (0 (0 (0 i-i-i-i-co co co080000000000000800000000000~0 0 0 0 0 0 0 0 ~0NNN(\N N N N N N N N N N N N N Ni:æ i:li 0 ..i:li 0 ..i:li 0 ..i:0-0 ..i:0-ro ::Q.ro ::Q.ro ::Q.ro ::Q.Q.ro ::Q...::..(f 0 ::..(f 0 ::..(f 0 ::..(f 0 ::..CJ
June 30, 2009 ~~
The Liberty Consulting Group
Page 59
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
As shown on Figure 30, UN-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Since 2005, Nebraska's UNE Loop volumes have
experienced a gradual decline. Resale lines, which were never very significant, have continued to
decline during the course of the five year period.
120,00
100,000
CI 80,000().~
CI(J
.S;
II
CIi:::
Figure 30: Nebraska Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
40.000
20.000
0
oq oq oq oq oq i.i.:g i.(0 (0 (0 (0 I'I'I'I'co co coaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaNNNNNNNNNNNNNNNNNNNN
c:..c:0-U ..c:0-U ..c:0-U ..c:0-U ..c:0-Ct Ct ::(I (l tt ::(I (l tt ::II (I Ct ::(I II Ct ::II.,~.,(f 0 ~.,(f 0 ~.,(J 0 ~.,(f 0 ~.,(J
June 30,2009 Page 60~,~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 11 shows the monthly CLEC aggregate order volumes for Nebraska from January 2007
through October 2008 for the six products Liberty recommends for removal from the OP
measures in the PAP. Orders for UBL - ISDN Capable Loops product exceeded ten transactions
per month in only one month. The volumes in the other months were extremely low. The
monthly volumes of the other products were also very small.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAbove DSI Conditioning CapableLoopLoop
Jan 2007 0 0 0 0 5 0
Feb 2007 0 0 0 0 0 0
Mar 2007 0 0 0 0 12 0
Apr 2007 0 1 0 0 0 0
May 2007 0 0 0 5 0 0
June 2007 0 0 0 4 0 0
July 2007 0 0 0 0 0 0
Aug 2007 0 1 0 0 4 0
Sep 2007 0 0 0 0 4 0
Oct 2007 0 1 0 0 1 0
Nov 2007 0 1 0 5 4 0
Dec 2007 0 0 0 0 1 0
Jan 200S 0 0 0 1 3 0
Feb 200S 0 0 0 io 1 0
Mar 200S 0 0 0 0 1 0
Apr200S 0 0 0 2 0 0
May 200S 0 0 0 0 2 0
June 200S 0 0 0 0 0 0
July 200S 0 0 0 0 0 0
Aug 200S 0 0 0 0 0 0
Sep 200S 0 0 0 0 3 0
Oct 200S 0 0 0 0 0 0
Table 11
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Nebraska
Table 12 shows the monthly trouble report volumes in Nebraska for the five products that
Liberty recommends for removal from the MR measures in the PAP. The monthly number of
trouble reports for all CLECs was generally very small and never exceeded eight for any of the
products.
June 30, 2009 ~~
The Liberty Consulting Group
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 12
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Nebraska
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
Above DSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 2 0
Feb 2007 0 0 0 i 0
Mar 2007 0 0 0 3 0
Apr 2007 0 1 0 5 0
May 2007 0 0 0 2 0
June 2007 0 0 0 2 0
July 2007 0 0 0 4 0
Aug 2007 0 0 0 S 0
Sep 2007 0 0 0 i 0
Oct 2007 0 0 0 4 0
Nov 2007 0 3 0 2 0
Dec 2007 0 0 0 1 0
Jan 200S 0 4 0 1 0
Feb 200S 0 i 0 1 0
Mar 200S 0 0 0 0 0
Apr200S 0 1 0 2 0
May 200S 0 i 0 4 0
June 200S 0 0 0 i 0
July 200S 0 0 0 2 0
Aug200S 0 0 0 5 0
Sep 200S 0 0 0 1 0
Oct 200S 0 2 0 2 0
June 30,2009 ~,~
The Liberty Consulting Group
Page 62
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
G. New Mexico
New Mexico's Tier 1 and Tier 2 payments followed the pattern found in most states in that
payment amounts were somewhat erratic, but slowly dropped over time. In late 2004 and early
2005, payments were in excess of $20,000 in many months. Since early 2008, payments have
averaged less than $5,000 per month. The figure below shows total payments in New Mexico,
with Tier 1 and Tier 2 shown in red and black, respectively.
Fi ure 31: New Mexico Pa ment Totals
$120,000
$100,000
$80,000
$60,000
$ 40,000
$20,000
$ °
NM :Tier 1 and 2 Payments Totals
~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ § § § § ~c:'- c: Q. Co æ c: 0. U '- c: c. u.. c: Q. (,..~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~ ~
~ l
June 30,2009 Page 63~~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
The next figure shows New Mexico Tier 1 payments by domain. Payments related to Billng are
substantial throughout the Study Period, as are payments related to MR and OP. In the early part
of the Study Period, significant payments were made related to PO measures (pre-ordering
functions). OP measures dominated Tier 1 payments after 2006.
Fi Domain
NM :Tier 1 Payments by Domain
$30,000 . 81
. PO
. OP
. MR
. OTHER$25,000
$10,000
$ 5,00
$0
88 8 "'"'lO lO lO g to to to to l-I-l-I-CX co ::8 8 8 8 8 8 8 8 8 8 8 8 8 8 00 0NNNNNNNNNNNNNNNNNNNN
c:..c:a.u ..c:a.~..c:a.u ..c:a.u ..c:0.ti II ::(1 ¿:\t ::II \t ::(1 (1 \t ::(1 (1 \t ::(1.. :a ..C/::..C/Cl :a ..C/Cl :a ..C/Cl :a ..C/
June 30, 2009 ~,~
The Liberty Consulting Group
Page 64
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
The largest Tier 2 payments for New Mexico were for Biling measures. Additionally, Pre-
Ordering measures. played an important early role while Maintenance & Repair measures became
more important in 2007 and 2008. Overall Tier 2 payments have rarely been above $10,000 in
recent years. The figure below details Tier 2 payments for New Mexico by domain.
Fi Domain
NM :Tier 2 Payments by Domain
$80,000
. BI
. PO
. OP
. MR
. OTHER
$100,000
$60,000
$40,000
$20,000
$0
""""""
~~
io io io io ID ID ID ID l"I"l"I"eo eo eo
~~~8 8 8 8 8 ~8 8 8 ~~~8 ~~N N N N N N N N N
æ l-e:li l.l-e:li l.l-e:li l.l-e:li l.l-e:li1t::Q)1t ::Q)1t ::~1t ::Q)1t ::..::..(f 0 ::..(f 0 ::..(f ::..(f 0 ::..(f
June 30,2009 ~~
The Liberty Consulting Group
Page 65
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
As shown in Figure 34, New Mexico's overall monthly order volumes declined from their peaks
in 2004 to 2005, driven primarily by the TROITRRO decisions, which removed the requirement
for Qwest to offer UNE-P and Line Sharing as unbundled network elements under Section 251
of the i 996 Telecommunications Act. Since the start of2005 New Mexico has experienced some
variability in its order volumes with some peaks in UNE Loop orders in mid-2005 and a peak in
Resale orders in mid-2006. However, New Mexico has generally experienced a gradual decline
in both UNE Loop and Resale orders. LNP order volumes in the state have become fairly
consistent since mid 2007 and now dominate.
Figure 34: New Mexico Ordering Volumes
10,000
8.000
. UNE LOOPS & OTHER
. UNE~P & LINE SHAR ING
. RESALE
II LNP
I\E 6,00::Õ;;
li"t 4.000o
2,000
a ~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ø ø ø
~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~....~ ~ l~ j ~ l~ ~ ~ l~ ~ ~ l~ j ~ l
June 30,2009 ~~
The Liberty Consulting Group
Page 66
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
As shown on Figure 35, UNE-P and Line Sharing lines in service fell off sharly after 2004, as a
result of the TRO and TRRO decisions. Since 2005, New Mexico's UNE Loop volumes have
generally experienced a gradual decline. Resale lines, which were never very significant, have
continued to decline during the course ofthe Study Period.
100.000
80,000
~.~ 60,000
$lJ
.5:
II~ 40,000
:.
20,000
Figure 35: New Mexico Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
o
~.~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~...~~~~l~~~~~~
tDI'I'I'I'COCO((8g8gg~~~N N N N N '" '" '"lr æ i: liu æ § lio :; ~ (J ~ :! -. (J
June 30, 2009 Page 67~~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
Table 13 shows the monthly CLEC aggregate order volumes for New Mexico from January 2007
through October 2008 for the six products Liberty recommends for removal from the OP
measures in the PAP. The ordering volumes were extremely low for all products and never
exceeded four in a month.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAboveDSILoopConditioningCapable
Loop
Jan 2007 0 1 0 i i 0
Feb 2007 0 i 0 0 0 0
Mar 2007 0 0 0 0 i 0
Apr 2007 0 1 0 0 i 0
Mav 2007 0 0 0 0 i 0
June 2007 0 2 0 0 0 0
July 2007 0 0 0 0 2 0
Aug 2007 0 1 0 0 3 0
Sen 2007 0 0 0 0 0 0
Oct 2007 0 0 0 0 4 0
Nov 2007 0 0 0 0 i 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 0 2 0
Feb 200S 0 0 0 0 2 0
Mar 200S 0 3 0 0 0 0
Apr200S 0 0 0 0 i 0
Mav 200S 0 0 0 0 i i
June 200S 0 0 0 0 1 0
July 200S 0 0 0 0 i 0
Aug 200S 0 0 0 0 0 0
Sen 200S 0 i 0 0 1 0
Oct200S 0 0 0 0 3 0
Table 13
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
New Mexico
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
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Table 14 shows the monthly trouble report volumes in New Mexico for the five products that
Libert recommends for removal from the MR measures in the PAP. The number of monthly
troubles was low for all volumes and never exceeded ten in a month.
Table 14
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
New Mexico
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
Above DSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 i 0 6 0
Feb 2007 0 0 0 7 0
Mar 2007 0 0 0 4 0
Apr 2007 0 i 0 4 0
May 2007 0 0 0 7 3
June 2007 0 0 0 4 0
July 2007 0 0 0 S 0
Aug 2007 0 0 0 2 4
Sep2007 0 I 0 9 2
Oct 2007 0 1 0 4 0
Nov 2007 0 I 0 io 2
Dec 2007 0 0 0 S 2
Jan 200S 0 2 0 6 1
Feb 200S 0 1 0 3 0
Mar 200S 0 i 0 1 0
Apr200S 0 1 0 3 i
May 200S 0 2 0 2 i
June 200S 0 0 0 2 1
July 200S 0 1 0 5 0
Aug 200S 0 2 0 3 0
Sep 200S 0 0 0 2 1
Oct 200S 0 i 0 2 1
June 30, 2009 ~~
The Liberty Consulting Group
Page 69
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
H. North Dakota
North Dakota's Tier 1 and Tier 2 payments followed the pattern found in most states in that
payment amounts were erratic, but slowly dropped over time. In late 2004 and early 2005,
payments were in excess of$10,000 in many months. Since early 2008, payments have averaged
less than $5,000 per month. The figure below shows total payments in North Dakota, with Tier 1
and Tier 2 shown in red and black, respectively. Occasional failures, resulting in Tier 1
payments, continued to occur through 2008, but few Tier 2 payments occurred after March 2007.
Fi ure 36: North Dakota Pa ment Totals
$50,000
$40,000
$30,000
$20,000
$10,000
$0 'I 'I 'I 'I 'I io io io 8 :3 ~~:3
r-r-r-r-eo eo 888~0 0 8 8 ~~0 8 8 0 800¡a 0NNNNNNNNNNNN N Nc: ..c:li 0 ..c:Q.U ..c:li 16
..c:Q.0 æ c:lil' l'::ci l'::ci ci l'::l'::ci ci ::.. ::..(/0 ::..(/0 ::..(/0 ::..(/0 ::..(/
June 30, 2009 Page 70~~
The Liberty Consulting Group
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
The next figure shows North Dakota Tier 1 payments by domain. Payments related to Biling are
substantial throughout the Study Period, and payments related to Maintenance & Repair and
Provisioning were importnt in 2004.
Fi ure 37: North Dakota Tier 1 Pa Domain
NO :Tier 1 Paymnts by Domain
$50,000 . 81
. PO
. OP
. MR
. OTHER$40,000
$30,000
$20,00
$10,000
$0
;g """""";g l3 i.i.i.~~~~l:l:8 l:co co ~0 0 0 0 0 0 0 0000000000000000000 0NNNNNNNNNNNNNNNNNNNNi:i;i:c."..i:c."..i:.ai "li e c.&l
..i:ai(I ::Q)~II ::c1
Q)tt ::Q)tt ::Q)II ::..:a ..(/:a ..0 :a ..(/0 :a ..(/0 :a ..(/
June 30,2009 ~~
The Liberty Consultng Group
Page 71
Final Report Appendices Analysis of Qwest's
Peñormance Assurance Plans
Tier 2 payments for North Dakota were dominated by MR measures, with OP measures
occasionally responsible for a significant percentage of payments. Overall Tier 2 payments have
rarely been above $4,000. The figure below details Tier 2 payments for North Dakota by domain.
Fi Domain
NO :Tier 2 Paymnts by Domain
$15,000
. 81
. PO
. OP
. MR
. OTHER
$10,000
$5,000
$°
~~"'"'~8 io io io \0 ig ig ig I'I'I'I'co co cog00g~0 0 0 0 0 0 0 000~0 ~~~~~~~~~~~0 0NNNNNNN
i: ..i:a.u æ i:0.:i li i:ãl u ..i:a.
~
..i:a.(l (l ::(1 ~::aJ ::(1 (l ::(1 (l ::aJ.. ::..If ::..0 ::..If 0 ::..If ::..
June 30, 2009 ~~
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Page 72
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
North Dakota's overall monthly order volumes declined significantly in early 2005 from their
monthly 2004 rates as shown on Figure 39. This decline was driven primarily by the TRO/TO
decisions, which removed the requirement for Qwest to offer UNE-P and Line Sharing as
unbundled network elements under Section 251 of the 1996 Telecommunications Act. Since the
star of2005, with the exception of June 2005 during which there was a spike in both UNE Loop
and LNP orders, order volumes remained fairly constant until December of 2006. At that that
time, there was a large increase in LNP orders that lasted through June 2007 but has generally
declined since then. Orders for both Resale services and, to a much lesser extent, UNE Loops
have been declining since 2006.
Figure 39: North Dakota Ordering Volumes
5,000
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESll,LE
f! LNP
6,000
4,000~
E::Õ;:..~
e
1,000
3.000
2.000
o ~~~~~i.i.i.i.~(0 (0 (0 r-r-r-r-~tQ tQ0000008000000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi:..i:0-(J ..i:0-(J ..i:0-(,..i:0-(J ..i:0-ro ro ::(J (J ro ::(J (J ro ::(J (J ro ::(J (J ro ::(J..:2 ..(/0 :2 ..(/0 :2 ..(/0 :2 ..(/0 :2 ..(/
June 30,2009 ~~
The Liberty Consulting Group
Page 73
Final Report Appendices Analysis of Qwests
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As shown on Figure 40, UNE-P and Line Sharing lines in service fell off sharly after 2004, as a
result of the TRO and TRO decisions. Since 2005, North Dakota's UN Loop and Resale line
volumes have experienced a gradual decline.
Figure 40: North Dakota Lines in Service
20,000
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
60,000
Glo.~
~
.5
UI
Gli:::
o
'O 'O00
?a ?ac ..
(U (U
-, :2
ggg~~~~~~~~~~~~øøø?a ?a ?a ?a ?a ?a ?a ?a ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
§,t~ ai § ß-o~ ai § ß-o~ ai § ß-~~ § ß--'wo:2-,(I :2-,(1 :2-,(IO~-'(i
June 30, 2009 ~~
The Liberty Consulting Group
Page 74
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Table 15 shows the monthly CLEC aggregate order volumes for North Dakota from January
2007 through October 2008 for the six products Liberty recommends for removal from the OP
measures in the PAP. UBL - 4-Wire Non-Loaded Loop order volumes exceeded ten transactions
per month only in March 2007. Monthly volumes for the other months were extremely low. The
volumes for the other products were always zero.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAbove DSl Conditioning CapableLoopLoop
Jan 2007 0 0 1 0 0 0
Feb 2007 0 0 4 0 0 0
Mar 2007 0 0 1l 0 0 0
Apr 2007 0 0 5 0 0 0
May 2007 0 0 0 0 0 0
June 2007 0 0 I 0 0 0
July 2007 0 0 0 0 0 0
Aug 2007 0 0 1 1 0 0
Sep 2007 0 0 0 0 0 0
Oct 2007 0 0 0 0 0 0
Nov 2007 0 0 1 0 0 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 0 0 0
Feb 200S 0 0 0 0 0 0
Mar 200S 0 0 1 0 0 0
Apr 200S 0 0 0 0 0 0
May 200S 0 0 1 0 0 0
June 200S 0 0 0 0 0 0
July 200S 0 0 2 0 0 0
Aug 200S 0 0 0 0 0 0
Sep 200S 0 0 1 0 0 0
Oct200S 0 0 0 0 0 0
Table 15
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
North Dakota
Table 16 shows the monthly trouble report volumes in North Dakota for the five products that
Liberty recommends for removal from the MR measures in the PAP. The monthly number of
trouble reports was always very small, never exceeding three in a month.
Table 16
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
North Dakota
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
AboveDSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 1 0
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Feb 2007 0 0 0 0 0
Mar 2007 0 0 0 i 0
Apr 2007 0 0 0 0 0
May 2007 0 0 0 i 0
June 2007 0 0 0 i 0
July 2007 0 0 0 i 0
Aug 2007 0 0 0 0 0
Sep 2007 0 0 0 0 0
Oct 2007 0 0 0 3 0
Nov 2007 0 0 0 0 0
Dec 2007 0 0 0 i 0
Jan 200S 0 0 0 0 0
Feb 200S 0 0 0 0 0
Mar200S 0 0 0 1 0
Apr200S 0 0 0 0 0
May 200S 0 0 0 0 0
June 200S 0 0 0 0 0
July 200S 0 0 0 1 0
Aug 200S 0 0 0 i 0
Sep 200S 0 0 0 0 0
Oct 200S 0 0 0 i 0
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I. South Dakota
South Dakota's Tier 1 and Tier 2 payments followed the pattern found in most states in that
payment amounts were high at first, but slowly dropped over time. In late 2004 and early 2005,
payments were in excess of $20,000 in many months. Since early 2008, payments have averaged
less than $5,000 per month. The figure below shows total payments in South Dakota, with Tier 1
and Tier 2 shown in red and black, respectively. Occasional failures, resulting in Tier 1
payments, continued to occur through 2008, but few Tier 2 payments occurred after March 2007.
Fi ure 41: South Dakota Pa ment Totals
$80,000
$60,000
$ 40,000
$ 20,000
$ 0
SD :Tier 1 and 2 Payments Totals
June 30,2009 Page 77~~
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The next figure shows South Dakota Tier 1 payments by domain. Payments related to Biling are
substantial throughout the Study Period, while payments related to Maintenance & Repair and
Provisioning are more episodic.
Fi ure 42: South Dakota Tier 1 Pa Domain
SO :Tier 1 Payments by Domain
$60,000
. 81
. PO
. OP
. MR
. OTHER$50,000
$40,000
$20,000
$30,000
$10,000
$ 0 ~~~~~10 10 10 10 ((((8 ((r-r-b r-eo eo eo00000000008000000000~0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0NNNNNNNNNNNNNNNNNNNt:..t:Co li ..t:0-U æ t:0-:i æ t:Co U ..t:0-(I (I :i (J (I :i (J (J :i (J :i (J (J (I :i ~-, :E ..ø 0 :E ..ø 0 :E ..ø 0 :E ..ø 0 :E ..
June 30,2009 ~~
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Tier 2 payments for South Dakota were dominated by MR measures, with OP measures
occasionally responsible for a significant percentage of payments. An exception is November
2005, where South Dakota received a payment of more than $30,000 related to Biling. Overall
Tier 2 payments have rarely been above $10,000. The figure below details Tier 2 payments for
South Dakota by domain.
Fi ure 43: South Dakota Tier 2 Pa Domain
SO :Tier 2 Payments by Domain
$40,000
. BI
. PO
. OP
. MR
. OTHER
$30,000
$20,000
g ~8 8 ¡g on on on on ¡g .~¡g :g r:r:8 8 ~~~0 0 0 ~0 0 ia ia 0 0 0 ia ia 0 ia iaNNNNNNNNNNi:..i:c.l...i:c.:r ..i:c.l.le i:i l...i:iIIto::(I ~to ::~to ::~Q)::Q)to ::..::..en ::..0 ::..0 ::..en 0 ::..
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As shown on Figure 44, South Dakota's overall monthly order volumes declined significantly in
early 2005 from their monthly 2004 rates. This decline was driven primarily by the TROITRRO
decisions, which removed the requirement for Qwest to offer UNE-P and Line Sharing as
unbundled network elements under Section 251 of the 1996 Telecommunications Act. Resale
ordering increased from mid 2005 through mid 2006 but decreased markedly after that time.
There was also some UNE order activity from 2004 through late 2006 that also tapered off to just
a handful of orders in 2007 and 2008. As shown on the graph, since late 2006 order volumes in
South Dakota are dominated by LNP orders.
Figure 44: South Dakota Ordering Volumes
6,000 . UNE
. UNE-P & LINE
. RES,ALE
IW LNP5,000
1,000
4.000II
E::Õ:;..II
"Eo
3.00
2.000
o
oq oq oq oq oq i.:g i.i.(0 (0 (0 (0 f'f'f'f'co co co000000000000000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi: ..i:0.u ..i:0.u ..i:0.u ..i:0.u ..i:0.(t(t ::(I (I (t ::(I ~(t ::(I (I (t ::(I (I a:::(I-- ::--(f 0 ::--(f ::--(f 0 ::--(f 0 ::--(f
June 30,2009 ~~
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As shown on Figure 45, UNE.P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. South Dakota's UN Loop and Resale line volumes
have experienced a gradual decline over the entire Study Period.
60,000
50,000
41U.~
II(J
.5
VI
41c:::
40,000
30,000
20.000
10,000
Figure 45: South Dakota Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RES,ALE
o
-.-.-.-.-.10 10 10 10 (,(,(,(,,.,.,.,.co co co0000000000000000000000~0 0 0 ~~~~~~0 0 0 0 ~~~0NNNNNNNNNN
c:..c:0-(.Ji c:0-(...c:0-(...c:0-(.æ c:0-(\(\::Q)Q)(\::Q)Q)(\::Q)Q)(\::~Q)::Q)..~..C/0 ~..C/0 ~..C/0 ~..0 ~..C/
June 30, 2009 Page 81~,~
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Table 17 shows the monthly CLEC aggregate order volumes for South Dakota from January
2007 through October 2008 for the six products Libert recommends for removal from the OP
measures in the PAP. All the volumes are extremely small, never exceeding two in a month.
UBL4W UBL-
Date UBL-DS3 UDIT-Non-Loaded Loops with ISDN Line SharingLoopAbove DSI Loop Conditioning Capable
Loop
Jan 2007 0 0 0 0 2 0
Feb 2007 0 0 0 0 0 0
Mar 2007 0 0 0 0 2 0
Apr 2007 0 0 0 0 0 0
May 2007 0 0 0 0 0 0
June 2007 0 0 0 0 2 0
Julv 2007 0 0 0 0 0 0
Aug 2007 0 0 0 0 1 0
Sep 2007 0 0 0 0 1 0
Oct 2007 0 0 0 0 0 0
Nov 2007 0 0 0 0 0 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 0 1 0
Feb 200S 0 0 0 0 0 0
Mar 200S 0 0 0 0 i 0
Apr 200S 0 0 0 0 1 0
May 200S 0 0 0 0 0 0
June 200S 0 0 0 0 0 0
July 200S 0 0 0 0 0 0
Aug 200S 0 0 0 0 1 0
Sep 200S 0 0 0 0 0 0
Oct 200S 0 0 0 0 0 0
Table 17
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
South Dakota
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Table 18 shows the monthly trouble report volumes in South Dakota for the five products that
Libert recommends for removal from the MR measures in the PAP. The monthly number of
troubles for these products is extremely small, rarely exceeding zero and never more than one.
Table 18
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
South Dakota
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
AboveDSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 0 0
Feb 2007 0 0 0 0 0
Mar 2007 0 0 0 i 0
Apr 2007 0 0 0 0 0
May 2007 0 0 0 0 0
June 2007 0 0 0 0 0
July 2007 0 0 0 0 0
Aug 2007 0 0 0 0 0
Sep 2007 0 0 0 0 0
Oct 2007 0 0 0 0 0
Nov 2007 0 0 0 1 0
Dec 2007 0 0 0 0 0
Jan 200S 0 0 0 0 0
Feb 200S 0 0 0 0 0
Mar 200S 0 0 0 0 0
Apr200S 0 0 0 0 0
May 200S 0 0 0 0 0
June 200S 0 0 0 0 0
July 200S 0 0 0 0 0
Aug 200S 0 0 0 0 0
Sep 200S 0 0 0 0 0
Oct 200S 0 0 0 0 0
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J. Utah
Utah's Tier 1 and Tier 2 payments followed the pattern found in most states in that payment
amounts were erratic, but slowly dropped over time. In late 2004 and early 2005, payments were
in excess of $25,000 in many months. Since early 2008, payments have averaged less than
$10,000 per month. The figure below shows total payments in Utah, with Tier 1 and Tier 2
shown in red and black, respectively.
Fi ure 46: Utah Pa ment Totals
UT :Tier 1 and 2 Paymnts Totals
$60,000
$80,000
$40,000
$20,000
June 30,2009 ~~
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The next figure shows Utah Tier 1 payments by domain. Payments related to Biling are
substantial throughout the first two years, while payments related to Maintenance & Repair and
Provisioning are substantial throughout the Study Period.
Domain
$40,000
$30,000
$20,000
$10,000
$ 0
UT :Tier 1 Payments by Domain
. Bt
. PO
II OP
. MR
ii OTHER
l
June 30,2009 Page 85~,~
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Tier 2 payments for Utah were dominated by MR measures, with OP measures occasionally
responsible for a significant percentage of payments. In addition, two months had very
substantial (more than $30,000) related to Biling. Overall Tier 2 payments have rarely been
above $10,000. The figure below details Tier 2 payments for Utah by domain.
Fi
UT :Tier 2 Payments by Domain
$50,000
. 81
. PO
. OP
. MR
. OTHER
$30,000
$20,000
$10,000
$0
88 "!"!"!10 10 10 10 lD lD lD lD I'I'I'I'co co co88888880888880000800000C' C'C'C'C'C'C'C'C'C'C'C'C'C'C'C'C'C'C'C'c: ..'"i:0.u ..i:li u ..i:0.u ..i:0.u ..i:litI tI ::Q)Q)tI ::Q)tI ::Q)~tt ::Q)Q)tt ::.. :E ..(J c::E ..(J c::E ..(J :E ..(J c::E ..(J
June 30, 2009 ~~
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As shown in Figure 49, Utah's overall monthly order volumes declined from their peaks in 2004,
driven primarily by the TRO/TRRO decisions, which removed the requirement for Qwest to
offer UNE-P and Line Sharing as unbundled network elements under Section 25 i of the 1996
Telecommunications Act. After another set of peaks in 2005, Utah's order volume was relatively
constant until April 2008, when a small increase in volumes occurred and has held through the
end of the study in October 2008. Utah's Resale and UNE Loop order volumes have generally
decreased over time and LNP orders have gradually increased.
Figure 49: Utah Ordering Volumes
25,000
20,000
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESALE
¡¡ LNP
~ 15,000
::Õ::
Q¡"0 10,000o
5,000
0
oq oq oq oq oq It It It It ((~8 ((l"I"l"I"~~co000000000000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi:.ii i:c.(,..i:c.(,..i:c.(,...i:c.(,~i:c.~~::(I (I ~::(I (I ~::(I (I ~::(I (I ~::(I..~..(J 0 ~..(J 0 ~..(J 0 ~..(J 0 ~..(J
June 30,2009 ~~
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As shown on Figure 50, UN-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Since 2005, Uta's UNE-Loop and Resale line volumes
have experienced a gradual decline over the Study Period.
250,000
200,000
CI("'0:~ 150,000
(f
.5
rJ
~ 100,000::
50,000
Figure 50: Utah Lines in Service
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
. RESA.LE
o ~~0000NNi: ..
(1 (1
.. :E
~ ~ ~ ~ ~ ~ ~ ID ID ID ID ~ ~ ~ ~ ~ ~ ~000000000000000000~~~~~~~~~~~~~~~~~~
§ arc:~ tñ § arc:~~ § li~ tñ § ar~~ § li""00 :2'00 .~'øc::E'øc:~""oo
June 30, 2009 Page 88~,~
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Table 19 shows the monthly CLEC aggregate order volumes for Utah from Januar 2007
through October 2008 for the six products Liberty recommends for removal from the OP
measures in the PAP. Orders for the UDIT-Above DSI product exceeded ten per month only in
July 2008. The monthly volumes for the other months were extremely low. The monthly
volumes for the other products were always small.
UBL4W UBL-
Date UBL-UDIT-Non-Loaded Loops with ISDN Line SharingDS3LoopAbove DSI Conditioning CapableLoopLoop
Jan 2007 0 3 0 0 3 0
Feb 2007 0 0 0 0 0 0
Mar 2007 0 6 0 i 2 0
Apr 2007 0 2 0 0 5 0
May 2007 0 2 0 I 2 0
June 2007 i 2 0 0 3 0
July 2007 i 0 0 4 i 0
Aug 2007 i S 0 0 1 0
Sep 2007 0 3 0 0 1 0
Oct 2007 0 4 0 6 1 0
Nov 2007 i 2 3 i 1 0
Dec 2007 0 2 0 0 0 0
Jan 200S 0 0 3 0 0 0
Feb 200S 0 2 i 0 0 0
Mar 200S 0 2 1 1 0 0
Apr200S 3 4 0 0 2 0
May 200S 0 7 2 1 0 0
June 200S 0 6 0 0 2 0
July 200S 2 16 0 0 0 0
Aug 200S i 2 0 0 0 0
Sep 200S i i 0 0 0 0
Oct 200S 0 2 0 0 0 0
Table 19
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Utah
June 3D, 2009 ~~
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Table 20 shows the monthly trouble report volumes in Utah for the five products that Liberty
recommends for removal from the MR measures in the PAP. The monthly number of trouble
reports never exceeded seven.
Table 20
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008
Utah
UBL4W UBL-
Date UBL-DS3 UDIT-Non-ISDN Line
AboveDSl Loaded Capable Sharing
Loop Loop
Jan 2007 0 3 0 3 3
Feb 2007 0 3 0 6 0
Mar 2007 0 i 0 2 2
Apr 2007 0 3 0 4 i
May 2007 0 2 0 4 i
June 2007 0 3 0 4 0
July 2007 0 i 0 6 0
Aug 2007 0 2 0 3 3
Sep 2007 0 4 0 5 i
Oct 2007 0 3 0 3 i
Nov 2007 0 5 i 4 i
Dec 2007 0 2 0 3 3
Jan 200S 0 2 i 5 0
Feb 200S 0 2 0 7 3
Mar 200S 0 1 0 5 0
Apr200S 0 2 0 3 1
May 200S 0 3 0 i 2
June 200S 0 6 0 2 4
July 200S 0 1 0 5 3
Aug 200S 0 2 0 1 2
Sep 200S 0 3 0 5 3
Oct 200S 0 3 i i i
June 30,2009 ~~
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K. Wyoming
Wyoming's Tier i and Tier 2 payments were fairly steady except for one very large Tier 2
payment in November 2005. Typical payments were $10,000 in 2004 and early 2005 and are less
than $5,000 now. The figure below shows total payments in Wyoming, with Tier 1 and Tier 2
shown in red and black, respectively.
WY :Tier 1 and 2 Payments Totals
$120,000
$100,000
$80,000
$60,000
$40,000
$ 0
~ ~
l ~
$ 20,000
June 30, 2009 ~~
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The next figure shows Wyoming Tier 1 payments by domain. Payments related to Biling are
substantial throughout the Study Period, while payments related to Maintenance & Repair and
Provisioning appear to drop off in the last two years.
Fi Domain
WY :Tler 1 Paymnts by Doin
$25,000
$20,000
. 81
. PO
. OP
. MR
. OTHER
$15,000
$ 5,000
$10,000
$0 .. ..~....io io io io ig ig ig 8 i-i-i-i-co co co00000000000000g000000000~0 ~0 0 0 0 0 0NNNNNNNNNNNNNNNNN Ni:..i:Q.u ..i:Q.:i li i:Q.:i li i:Q.:i ..i:Q.(I (I :i Jj Q)(I :i Jj :i Q):i Jj (I :i Jj.. ::..0 ::-,0 ::-,C/0 ::-,0 ::-,
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Tier 2 payments for Wyoming were dominated by MR and OP measures, with one very
substantial ($100,000) Billng payment in November 2005. The figure below details Tier 2
payments for Wyoming by domain.
Domain
WY :Tier 2 Payments by Domain
$120,000
$100.000
. 81
. PO
. OP
. MR
. OTHER
$80.000
$60,000
$ 40.000
$20,000
l
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Wyoming's overall monthly order volumes declined from their peaks in early 2004 through the
middle of 2005 as shown in Figure 54. This decline was driven primarily by the TROITRRO
decisions which no longer required Qwest to offer UN-P and Line Sharing as UNs under
Section 251 of the 1996 Telecommunications Act. In mid-2005, Wyoming experienced an
increase in its order volumes, driven by LNP orders. From mid-2005 until the end of the Study
Period there has been a continuing decline in Resale order volumes. LNP volumes grew
dramatically from mid-2005 to mid-2006, have remained fairly constant since then, and now
dominate the Wyoming orders. UNE Loop orders, while never significant in Wyoming, have
remained at relatively constant volume levels throughout the five year study.
2.000
(1
E::Õ;:..(1"0
C
1,500
1,000
500
Figure 54: Wyoming Ordering Volumes
. UNE LOOPS & OTHER
. UNE-P & LINE SHARING
ll RES,A,LE
lE WP
0 "' "'"'"'"'i.i.i.i.(0 (0 (0 (0 r-r-r-r-eo co co0000000000000000000000000000000000000000NNNNNNNNNNNNNNNNNNNNi:..i:a.u ..i:a.u ..i:a.u ..i:a.u ..i:a.(1 (1 ::II II (1 ::II II (1 ::II II (1 ::II II (1 ::II..:2 ..(f Cl :2 ..(f Cl :2 ..(f Cl :2 ..(f Cl :2 ..(f
June 30, 2009 Page 94~~
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As shown on Figure 55, UNE-P and Line Sharing lines in service fell off sharply after 2004, as a
result of the TRO and TRRO decisions. Wyoming's UNE Loopsha ve experienced a gradual
increase in lines over the entire Study Period. Conversely, Wyoming's Resale line volumes have
experienced declining line volumes.
~ 30.000
'2
q¡CI
.5
:c 20,000i:::
10,000
Figure 55: Wyoming Line in Service
. UNE LOOPS &
. UNE-P & LINE
. RESALE
0
'O 'O 'O 'O 'O i.i.i.i.CD CD CD CD ........co co co000000000800000000000000000000000~0 0 0 0 0C' C'C'C'C'C\C'C'C'C'C'C'C'C\C'C'C'C\C\i: ..i:c.0 ..i:a.0 ..i:c.0 ..i:5r 0 ..i:tiii ii :J (1 (1 ii :J (1 (1 ii :J (J (J ii :J (J ii :J""2 ..(j 0 2 ..(j 0 2 ..(j 0 2 ..(j 0 2 ..(j
June 30, 2009 Page 95~~
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Table 21 shows the monthly CLEC aggregate order volumes for Wyoming from January 2007
through October 2008 for the six products Liberty recommends for removal from the OP
measures in the PAP. The ordering volumes were always very small and never exceeded two in a
month.
fyomin2
UBL4W UBL-
Date UBL-UDIT-Non-Loaded Loops with ISDN Line SharingDS3LoopAbove DSI Loop Conditioning Capable
Loop
Jan 2007 0 0 0 0 2 0
Feb 2007 0 0 0 0 i 0
Mar 2007 0 0 0 0 i 0
Apr 2007 0 0 0 0 0 0
May 2007 0 0 0 2 0 0
June 2007 0 0 0 0 0 0
July 2007 0 0 0 0 1 0
Aug 2007 0 0 0 0 1 0
Sep 2007 0 0 0 0 1 0
Oct 2007 i 0 0 0 0 0
Nov 2007 0 0 0 0 0 0
Dec 2007 0 0 0 0 0 0
Jan 200S 0 0 0 0 i 0
Feb 200S 0 0 0 0 i 0
Mar 200S 0 0 0 0 0 0
Apr200S 0 0 0 0 i 0
May 200S 0 0 0 0 2 0
June 200S 0 0 0 0 0 0
July 200S 0 i 0 0 i 0
Aug200S 0 0 0 0 i 0
Sep 200S 0 0 0 0 0 0
Oct200S 0 0 0 0 0 0
Table 21
Order Volumes for Products Recommended for PAP Removal
January 2007 through October 2008W .
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Table 22 shows the monthly trouble report volumes in Wyoming for the five products that
Libert recommends for removal from the MR measures in the PAP. The monthly number of
trouble reports was always small and never exceeded four.
Table 22
Trouble Report Volumes for Products Recommended for PAP Removal
January 2007 through October 2008W .'yomlO2
UBL4W UBL-
Date UBL-DS3 UDlT-Non-ISDN Line
Above DSI Loaded Capable Sharing
Loop Loop
Jan 2007 0 0 0 0 0
Feb 2007 0 0 0 0 4
Mar 2007 0 0 0 i 0
Apr 2007 0 0 0 3 1
May 2007 0 0 0 0 1
June 2007 0 0 0 i 3
July 2007 0 i 0 0 i
Aug 2007 0 0 0 1 0
Sep 2007 0 0 0 0 0
Oct 2007 0 0 0 i 0
Nov 2007 0 0 0 0 2
Dec 2007 0 0 0 0 0
Jan 200S 0 0 0 i 0
Feb 200S 0 0 0 1 i
Mar 200S 0 0 0 i i
Apr200S 0 0 0 0 3
May 200S 0 0 0 2 2
June 200S 0 0 0 i i
July 200S 0 0 0 0 3
Aug 200S 0 0 0 0 3
Sep 200S 0 0 0 0 1
Oct 200S 0 0 0 i 0
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Appendix C: State-Specific Proposals
A. Arizona
The following lists the specific applicabilty of Libert's recommendations to the Arizona PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
. PO-9 Timely Jeopardy Notices
. PO-19 Stand Alone Test Environment (SATE) Accuracy
· PO-20 Manual Service Order Accuracy
. CP-l Collocation Completion interval
. CP-2 Collocations Completed within Scheduled Intervals
· CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier-l Payments to CLECs" and Section 8.0
"Step by Step Calculation of Monthly Tier-l Parity Measurement Payments to
CLECs" to describe a new aggregation mechanism for small sample sizes
(Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
8
v. When either of these criteria has been met, the process stars again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availability - IMA-EDI with
GA-8: Gateway Availabilty- IMA-XML, and adopt the language changes in Pil
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
8 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
June 30, 2009 ~~
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PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Libert
Recommendation 3).
4. Add language to Sections 15.0 (Audits/Investigations of Performance Results)
and 16.0 (Reviews) to provide for necessary funding of activities through a direct
assessment of Qwest if the Tier 2 funds are exhausted (Liberty Recommendation
6).
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote e) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change footnote h of the table in Attachment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops (only for OR measures)
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (lSDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
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B. Colorado
The following lists the specific applicabilty of Liberty's recommendations to the CPAP.
1. Restore the Tier 1 B, Tier 1 C, and Tier 2 components of the CP AP, which were
eliminated in the most recent CP AP version, subject to the additional
recommendations below (Liberty Recommendation 8).
2. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
. PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
. CP-l Collocation Completion intervaL.
3. Add subsections to Section 6.0 "Tier lA Parity Calculations" and Section 7.0
"Tier 1 Calculation of Payments to CLEC for Tier lA, IB, and LC Submeasures"
to describe a new aggregation mechanism for small sample sizes (Liberty
Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
9
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
4. Add language to Sections 14.0 (Audits of Performance Results) and 18.0
(Effective Date, Reviews and Termination) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
9 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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5. Change Appendices A and B to replace OP-5a, b with OP-5T (eliminating
footnote e) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change Appendix B to add the following excluded products for OP and MR
measures (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4- Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops (only for OR measures).
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30, 2009 ~~
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C. Idaho
The following lists the specific applicabilty of Liberty' s recommendations to the Idaho PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
. PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ll. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
Il. Should the calculation determine that Qwest was out of compliance with
the stadard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold. 10
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availability - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit ProgramInvestigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
10 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change footnote g of the table in Attachment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
· Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (lSDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
· Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30. 2009 ~~
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D. Iowa
The following lists the specific applicabilty of Libert's recommendations to the Iowa PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
· PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then cary forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
1 i
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availabilty - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
ii Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
June 30, 2009 ~~
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5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Liberty Recommendation 3).
6. Change footnote g of the table in Attchment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30.2009 ~,~
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E. Montana
The following lists the specific applicabilty of Libert's recommendations to the Montana PAP.
1. Adopt the recommendations of the 2007 Stipulation (Liberty Recommendation
10). The remaining Liberty recommendations assume these recommendations
have been adopted.
2. Modify Section 3.2 (added as one of the 2007 Stipulation recommendations) to
add the following PIO measures to the Reinstatementlemoval List (Liberty
Recommendation 2):
. PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
3. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small saple sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
il. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold. 12
v. When either of these criteria has been met, the process stars again the
following month for that sub-measure.
4. In Section 7.4 and Table 6, replace GA-2: Gateway Availability - IMA-EDI with
GA-8: Gateway Availabilty - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Libert
Recommendation 3).
12 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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5. Add language to Sections 15.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
6. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
current footnote e) and change the PID to make OP-5T no longer diagnostic but a
parity measure with the same retail analogue as OP-5a (Liberty Recommendation
3).
7. Change the footnote to be added to the table in Attchment 1 as part of the 2007
Stipulation recommendation that lists low-volume excluded products to include
the following additional excluded products (Libert Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
8. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (lSDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
9. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30, 2009 ~~
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F. Nebraska
The following lists the specific applicabilty of Liberty' s recommendations to the Nebraska PAP.
1. Modify Section 3.2 to add the following PIO measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
· PO-9 Timely Jeopardy Notices
· PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold. 13
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availability - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
13 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
June 30,2009 ~~
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Performance Assurance Plans
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Liberty Recommendation 3).
6. Change footnote g of the table in Attchment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30, 2009 ~~
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G. New Mexico
The following lists the specific applicabilty of Liberty's recommendations to the New Mexico
PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
. PO-9 Timely Jeopardy Notices
· PO-19a Stand Alone Test Environment (SATE) Accuracy
. PO-20 Manual Service Order Accuracy
· CP-2 Collocations Completed within Scheduled Intervals
· CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the stadard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold. 14
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availability - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
14 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change footnote g of the table in Attchment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4- Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30,2009 ~~
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Final Report Appendices Analysis of Qwests
Peñormance Assurance Plans
H. North Dakota
The following lists the specific applicabilty of Liberty's recommendations to the North Dakota
PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
· PO-9 Timely Jeopardy Notices
· PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
· CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months unti either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
15
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availability - IMA-EDI with
GA-8: Gateway Availability - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit ProgramInvestigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
15 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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Peñormance Assurance Plans
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change footnote g of the table in Attachment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4- Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30, 2009 ~,~
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I. South Dakota
The following lists the specific applicabilty of Liberty's recommendations to the South Dakota
PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatement/emoval List (Liberty Recommendation 2):
· PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
· CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold. 16
v. When either of these criteria has been met, the process stars again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availabilty - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Liberty
Recommendation 3).
4. Add language to Sections 15.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
16 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Libert Recommendation 3).
6. Change footnote g of the table in Attachment 1 to add the following excluded
products (Liberty Recommendation 4):
· Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (lSDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
· Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
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J. Utah
The following lists the specific applicabilty of Liberty's recommendations to the Utah PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatement/emoval List (Liberty Recommendation 2):
. PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
. CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the stadard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
17
v. When either of these criteria has been met, the process stars again the
following month for that sub-measure.
3. Add language to Sectionsl5.0 (Integrated Audit ProgramInvestigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
4. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote e) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Liberty Recommendation 3).
17 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
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5. Change footnote h of the table in Attachment 1 to add the following excluded
products (Libert Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffce Transport (UDIT) - Above DS 1
. Unbundled 4-Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
6. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
7. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30, 2009 ~~
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Final Report Appendices Analysis of Qwests
Performance Assurance Plans
K. Wyoming
The following lists the specific applicability of Liberty's recommendations to the Wyoming
PAP.
1. Modify Section 3.2 to add the following PID measures to the
Reinstatementlemoval List (Liberty Recommendation 2):
· PO-9 Timely Jeopardy Notices
. PO-20 Manual Service Order Accuracy
· CP-2 Collocations Completed within Scheduled Intervals
. CP-4 Collocation Feasibilty Study Commitments Met.
2. Add subsections to Section 6.0 "Tier 1 Payments to CLEC" and Section 8.0 "Step
by Step Calculation of Monthly Tier 1 Payments to CLEC" to describe a new
aggregation mechanism for small sample sizes (Liberty Recommendation 1):
i. Aggregate transactions for all CLECs that have less than ten transactions
in a month for any given sub-measure disaggregation before determining
whether a payment is due.
ii. If the outcome of this CLEC aggregation equals or exceeds ten
transactions, use the aggregate result for these CLECs to calculate whether
penalty payments are required.
iii. Should the calculation determine that Qwest was out of compliance with
the standard for the sub-measure, payments wil be made to the aggregated
CLECs based on each CLEC's relative share of the total number of
misses.
iv. If the aggregate total does not exceed ten transactions, then carry forward
the aggregate result to the following two months until either the threshold
of ten aggregate transactions is met or three months of results data have
been used in an attempt to meet the minimum volume threshold.
18
v. When either of these criteria has been met, the process starts again the
following month for that sub-measure.
3. In Section 7.4 and Table 6, replace GA-2: Gateway Availabilty - IMA-EDI with
GA-8: Gateway Availabilty - IMA-XML, and adopt the language changes in PID
version 9.1, which replaces EDI with XML for following PID measures: PO-I,
PO-2, PO-3, PO-4, PO-5, PO-6, PO-7, PO-16, PO-19, and PO-20 (Libert
Recommendation 3).
4. Add language to Sectionsl5.0 (Integrated Audit Program/Investigations of
Performance Results) and 16.0 (Reviews) to provide for necessary funding of
18 Liberty recommends treating aggregation across months as if it were a single month for payment escalation
purposes.
June 30,2009 ~~
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Page 118
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
activities through a direct assessment of Qwest if the Tier 2 funds are exhausted
(Liberty Recommendation 6).
5. Change the table in Attachment 1 to replace OP-5a, b with OP-5T (eliminating
footnote d) and change the PID to make OP-5T no longer diagnostic but a parity
measure with the same retail analogue as OP-5a (Liberty Recommendation 3).
6. Change footnote g of the table in Attachment 1 to add the following excluded
products (Liberty Recommendation 4):
. Unbundled Digital Signaling Level 3 (DS-3) Loops
. Unbundled Dedicated Interoffice Transport (UDIT) - Above DS 1
. Unbundled 4- Wire Non-Loaded Loops
. Loops with Conditioning (applies only to OR measures)
. Unbundled ISDN Capable Loops
. Line Sharing.
7. Adopt changes to the PID to replace "retail Integrated Services Digital Network
Basic Rate Interface (ISDN-BRI) designed" with other retail products or with a
benchmark, after collaborative discussions determine the appropriate alternatives
(Liberty Recommendation 3).
8. Adopt the following changes to the PID (Liberty Recommendation 5):
. Limit MR-4 (All Troubles Cleared within 48 Hours) to service-affecting
troubles
. Add a diagnostic sub-measure to OP-4 (Installation Interval) to measure
performance on expedited orders
. Add a diagnostic sub-measure to MR-7 (Installation Interval) to measure
chronic troubles
. Add a diagnostic sub-measure to OP-3 (Installation Appointments Met) to
measure the percentage of coordinated appointments met.
June 30,2009 ~~
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Page 119
Final Report Appendices Analysis of Qwests
Performance Assurance Plans
Appendix D: Glossary of Acronyms
ADSL Asynchronous Digital Subscriber Line
ARMIS Automated Reporting Management Information System
ASR access service request
CLEC competitive local exchange carrier
CPAP Colorado Performance Assurance Plan
DSO Digital Signaling Level 0
DSI Digital Signaling Level 1
DS3 Digital Signaling Level 3
DSL Digital Subscriber Line
EB-TA Electronic Bonding-Trouble Administration
EDI Electronic Data Interchange
EEL Enhanced Extended Link
EXACT Exchange Access Control & Tracking
FCC Federal Communications Commission
FOC firm order confirmation
ILEC Incumbent Local Exchange Carrier
IMA Interconnect Mediated Access
IMA-EDI Interconnect Mediated Access-Electronic Data Interchange
IMA-XML Interconnect Mediated Access-eXtensible Markup Language
ISDN Integrated Services Digital Network
ISDN BRI Integrated Services Digital Network Basic Rate Interface
ISDN PRI Integrated Services Digital Network Primary Rate Interface
LIS Local Interconnection Service
LNP local number portability
LSR local service request
MLT mechanized loop test
NTF No Trouble Found
NXX telephone number prefix ("exchange")
PAP Performance Assurance Plan
PBX Private Branch eXchange
Pil Performance Indicator Definitions
POTS plain old telephone service
QLSP Qwest Local Services Platform
QPAP Qwest Performance Assurance Plan
QPP Qwest Platform Plus
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ROC Regional Operating Committee
SATE Stand Alone Test Environment
SGAT Statement of Generally Available Terms and Conditions
TOK Test Okay
TRO Triennial Review Order
TRRO Triennial Review Remand Order
UDIT Unbundled Dedicated Interoffce Transport
UNE Unbundled Network Element
UNE-P Unbundled Network Element - Platform
XML Extensible Mark-up Language
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