20180215Amendment.pdf

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February 14,2018
Via Overnight delivery
Ms. Diane Hanian, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise, Idaho 83720-007 4
Case No.: QWE-T-16-04
Application for Approval of Amendment to Interconnection Agreement
Dear Ms. Hanian
Enclosed for filing is an Application for Approval of Interconnection Agreement along
with an original and two (2) copies of the Routing of Traffic Through a Third Party Transit
Provider Amendment to the Interconnection Agreement between Qwest Corporation dba
CenturyLink QC and Commio, LLC for the State of Idaho. Centurylink respectfully requests
that this matter be placed on the Commission Decision Meeting Agenda for expedited approval.
Please contact Maura Reynolds, Regulatory Paralegal, at [phone] should you
have any questions regarding this submission. Thank you for your assistance in this matter.
Sincerely,
J G
Legal Assistant III
Enclosure(s)cc: Service List
Re:
1600 7th Avenue, Room 1506
Seattle, Washington 98191
206-733-5236
iosie.addinqton (@centurvlink.com
Lisa A. Anderl (WSBA#13236)
CenturyLink
1600 7th Ave, Room 1506
Seattle, Washington 98191
Telephone: [phone]
lisa. [e-mail]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.: QWE-T-16-04
APPLICATION FOR APPROVAL OF
AMENDMENT TO INTERCONNECTION
AGREEMENT
Qwest Corporation dba CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the Interconnection Agreement. The Interconnection Agreement
was approved by the Idaho Public Utilities Commission on June 7,2016 under Order No. 33353
(the "Agreement"). The Routing of Traffic Through a Third Party Transit Provider Amendment
("Amendment") between CenturyLink and Commio, LLC ("Commio") is submitted herewith.
This Amendment was reached through voluntary negotiations without resort to mediation
or arbitration and is submitted for approval pursuant to Section 252(e) of the Communications
Act of 1934, as amended by the Telecommunications Act of 1996 (the "Act").
Section 252(e)(2) of the Act directs that a state Commission may reject an amendment
reached through voluntary negotiations only if the Commission finds that: the amendment (or
portion(s) thereof) discriminates against a telecommunications carrier not a party to this
agreement; or the implementation of such an amendment (or portion) is not consistent with the
public interest, convenience and necessity.
AppLIclrrou FoR AppRovAL oF AMENDMENT To INTERCoNNECTToN
AcREEnaENT CoMMIo, LLC - Page I
CenturyLink
1600 76 Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
CenturyLink respectfully submits this Amendment provides no basis for either of these
findings, and, therefore requests that the Commission approve this Amendment expeditiously.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State of Idaho, the Commission, the United States Congress, and the Federal
Communications Commission. Expeditious approval of this Amendment will enable Commio to
interconnect with CenturyLink facilities and to provide customers with increased choices among
local telecommunications services.
CenturyLink further requests that the Commission approve this Amendment without a
hearing. Because this Amendment was reached through voluntary negotiations, it does not raise
issues requiring a hearing and does not concern other parties not a party to the negotiations.
Expeditious approval would further the public interest.
Respectfully submitted this 14th day of February,2018.
CENTURYLINK
Lisa A. Anderl
Attorney for Qwest Corporation dba Centurylink
QC
AppLtcauoN FoR AppRovAL oF AMENDMENT To INTERCoNNECTIoN
AcnpsusNr CoMMIo, LLC - Page 2
CenturyLink
I 600 7n Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
I hereby certify that on this 14th day of February, 2018, I served the foregoing
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION
AGREEMENT upon all parties of record in this matter as follows:
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 W est Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Diane. [e-mail]. gov
Sam Shiffman, President
Commio, LLC
11320 Hwy 620N, Suite A031
Austin, Texas 78726
[e-mail]
Hand Delivery
U. S. MailXX Overnight Delivery
FacsimileXX Email
Hand DeliveryXX U. S. Mail
Overnight Delivery
FacsimileXX Email
AppLIcauoII FoR APPRoVAL or AugNourNT To INTERCoNNECTIoN
AGREEMENT CoMMro, LLC - Page 3
CenturyLink
I 600 7s Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
CERTIFICATE OF SERVICE
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DocuSign Envelope I D: D5037B49-CgA4-477 E-B4EC-66C9A683239F
Routing of Traffic Through a Third Party Transit Provider Amendment
to the lnterconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
Commio, LLC
for the State of ldaho
This Amendment ("Amendment") is to the lnterconnection Agreement between Qwest
Corporation dba CenturyLink QC ("CenturyLink"), a Colorado corporation, and Commio, LLC
("WSP') collectively referred to as, the "Parties."
RECITALS
WHEREAS, the Parties entered into an lnterconnection Agreement ("Agreement"), for service in
the State of ldaho that was approved by the Commission, which states that terminating
compensation for lntraMTA traffic is treated on a "bill and keep" basis, pursuant to the terms of
the Agreement that was approved by the Commission; and
WHEREAS, WSP has requested the ability to allow a third party to transit traffic between the
Parties, subject to limitations and requirements of the Local Exchange Routing Guide ("LERG")
and other applicable requirements, including but not limited to the Agreement; and
WHEREAS, the Parties wish to amend the Agreement under the terms and conditions
contained herein.
AGREEMENT
NOW THEREFORE, in consideration of the mutual terms, covenants and conditions contained
in this Amendment and other good and valuable consideration, the receipt and sufficiency of
which is hereby acknowledged, the Parties agree as follows:
Amendment Terms
The purpose of this Amendment is to provide the conditions under which the Parties may use a
Third Party Transit Provider to exchange traffic between their networks (see Attachment 1).
This Amendment complies with sections 6.2.1.1 and 6.3.1 of the Agreement that requires an
amendment prior to such an exchange.
Effective Date
This Amendment shall be deemed effective upon approval by the Commission; however, the
Parties agree to implement the provisions of this Amendment upon execution.
Further Amendments
Except as modified herein, the provisions of the Agreement shall remain in full force and effect.
Except as provided in the Agreement, this Amendment may not be further amended or altered,
February 9, 20lSlnaplCommio/(L-Q)/lD/ Amendment to CDS-160304-0003
Wireless Routing of Traffic Through a Third Party Transit Provider Amd (Q) (v.05.30.2017)
DocuSign Envelope lD: D5037B49-C9A4-477E-B4EC-66C9A683239F
and no waiver of any provision thereof shall be effective, except by written instrument executed
by an authorized representative of both Parties.
Entire Agreement
The Agreement as amended (including the documents referred to herein) constitutes the full
and entire understanding and agreement between the Parties with regard to the subjects of the
Agreement as amended and supersedes any prior understandings, agreements, or
representations by or between the Parties, written or oral, to the extent they relate in any way to
the subjects of the Agreement as amended.
The Parties intending to be legally bound have executed this Amendment as of the dates set
forth below, in multiple counterparts, each of which is deemed an original, but all of which shall
constitute one and the same instrument.
Qwest Corporation dba CenturyLink QC
flgusionea uy:k by:
?io" (&L
Diane Roth
Signature
Sam Shiffman
sig
Name Printed/Typed
President & CEO
Name Printed/Typed
Director - Wholesale
Title
2/9/20L8
Title
2/L2/2OL8
Date Date
February 9, 2OlSlnaplCommio/(L-Q)/lD/ Amendment to CDS-160304-0003
Wireless Routing of Traffic Through a Third Party Transit Provider Amd (Q) (v.05.30.2017)
2
Commio, LLC
Docusign Envelope lD: D5037B49-C9A4-477E-B4EC-66C9A683239F
ATTACHMENT 1
Terms of Routing of Traffic Through a Third Party Transit Provider Amendment
SECTION 4.0 . DEFINITIONS
"lnterMTA" describes Wireless Telecommunications Services originating in one MTA and
terminating in another MTA.
"lntraMTA" describes Wireless Non-Access Telecommunications Traffic that originates and
terminates in the same MTA.
"Transit Service" is any tratfic that originates from one (1) Telecommunications Carrier's network
and/or its end use(s), transits another Telecommunications Carrier's network, and terminates to
yet another Telecommunications Carrier's network and/or its end use(s).
SECTION 6.0 - INTERCONNECTION
6.2 Exchange of Traffic
6.2.1.1.1 WSP may designate a Third Party Transit Provider to exchange lnterMTA and
lntraMTA traffic between the Parties' networks under the following conditions:
6.2.1.1.1.1 Prior to the use of a Third Party Transit Provider to exchange traffic
between the Parties, WSP will identify the transiting party ("Third Party Transit
Provider"), and CenturyLink will confirm that the Third Party Transit Provider Amendment
to the Third Party Transit Provider's current interconnection agreement with CenturyLink
has been completed.
6.2.1.1.1.2 Prior to the use of a Third Party Transit Provider to exchange traffic
between the Parties and after the effective date of the amendment required in Section
6.2.1.1.1.1., WSP must designate its NPA-NXX codes in the LERG as homing to a Third
Party Transit Provider's Tandem Switch in the LATA or a Third Party Transit Provider's
Tandem designation in the LERG for homing of local and/or intraLATA codes within the
LATA. Neither CenturyLink nor WSP will route through a Third Party Transit Provider's
Tandem Switch until and unless this designation is made. Upon this designation, WSP
must route its traffic originating from the NPA-NXX(s) designated under this Section
through the Third Party Transit Provider's Tandem Switch, at its sole expense, to reach
CenturyLink's network. CenturyLink may route its originating or transit traffic bound for
the NPA-NXX(s) designated under this Section to the Third Party Transit Provider's
Tandem Switch or may choose to route traffic directly to the WSP's end office. After the
Parties have established Direct lnterconnection between their networks, neither Party
may continue to transmit its originated lnterMTA, lntraMTA and transit traffic indirectly.
6.2.1.1.1.3 Each Party that originates the traffic is responsible for payment of any
charges incurred and/or billed by Third Party Transit Provider, for transit, transport
and/or termination compensation arrangements that may or may not be contained in
separate agreements with CenturyLink or WSP. This applies for each Party's originated
February 9, 2}lSlnaplCommio/(L-Q)/lD/ Amendment to CDS-160304-0003
Wireless Routing of Traffic Through a Third Party Transit Provider Amd (Q) (v.05.30.2017)
3
DocuSign Envelope lD: D5037B49-C9A4-477E-B4EC-66C9A683239F
traffic but not limited to traffic that transits the network of the other Party or the Third
Party Transit Provider. For traffic terminating to CenturyLink or WSP, the bill and keep
provisions of the Agreement will govern any compensation between CenturyLink and
WSP. WSP represents and warrants that it has an agreement with Third Party Transit
Provider that complies with the requirements of this Section 6.2.1.1.1 .3.
4 No other traffic shall be exchanged pursuant to the provisions of Section
and its subsections.
6.2.1.1.1.5 WSP will pass unaltered to the Third Party Transit Provider all signaling
information (e.9., originating Calling Party Number and destination called party number,
etc.) per 47 C.F.R. S 64.1601 and industry standards.
6.2.1.1.1.6 This Section 6.2.1.1.1 and accompanying sub-sections do not othena/se
modify or supersede the terms and conditions of any agreement that WSP may have
with CenturyLink, including tariffs, interconnection and/or access agreements.
6.2.1.1.1.7 WSP will be responsible to provide originating records, in EMI Category
11-01-XX format to CenturyLink, if Third Party Transit Provider is unable to provide
transit records.
February 9, 2OlSlnaplCommio/(L-Q)ilDl Amendment to CDS-160304-0003
Wireless Routing of Traffic Through a Third Party Transit Provider Amd (Q) (v.05.30.2017)
6.2.
6.2.
1.1.1
1.1.1
4