20190822Amendment.pdf

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August 21,2019 li-l,xti-ir,j PUELIC
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Ms. Diane Hanian, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise, Idaho 83720-007 4
Re:Case No.: QWE-T-19-04
Application for Approval of Amendment to Interconnection Agreement
Dear Ms. Hanian:
Enclosed for filing are the Application for Approval of Amendment to Interconnection
Agreement along with an original and two (2) copies of the Canier Partner for Interconnected
VoIP Provider Amendment to the Interconnection Agreement between Qwest Corporation dba
CenturyLink QC and Teliax, Inc. for the State of Idaho.
CenturyLink respectfully requests that these matters 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,r
J G.
Legal Assistant
Enclosurescc: Service List
1600 7th Avenue, Room 1506
Seattle, Washington 98191
206-733-5236
iosie. add ington @centu rvlin k.com
Lisa A. Anderl (WSBA#I3236)
CenturyLink
1600 7th Ave, Room 1506
Seattle, Washington 98191
Telephone: [phone]
lisa. anderl @centurylink. com
Appr,tcarroN oF Qwrsr ConponauoN DBA
CnNrunvl.rNr QC Fon AprnovAl oF AN
AnrnxovrcNT To INTnRcoxNECTIoN
AcnrBvrcNT wITH Tot IAx,INc. Punsu,q.Nr
ro 47 U.S.C. $252(e)
RECEIVED
2019 AUC 2A pH t: 00
tililii tjLiBLIC
IT iL IT} ES COfi,tMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.: QWE-T-19-04
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 August 12,2019 under Order No.
34407 (the "Agreement"). The Carrier Partner for Interconnection VoIP Provider Amendment to
the Interconnection Agreement ("Amendment") between Centurylink and Teliax, Inc.
("Teliax") 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
APPLICATIoN FoR APPRoVAI- on AUTNDUENT To INTERCoNNECTIoN
AGnEBueNt [Tnuex, lNc.) - Page I
CenturyLink
1600 76 Ave., Suite l5o6
Seattle. WA 98191
Telephone: [phone]
agreemen! or the implementation of such an amendment (or portion) is not consistent with the
public interest, convenience and necessity.
CenturyLink respectfully submits this Amendment provides no basis for either of these
findings, and, therefore requests that the Commission approve this Amendment expeditiously.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State of Idaho, the Commission, the United States Congress, and the Federal
Communications Commission. Expeditious approval of this Amendment will enable Teliax 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 21't day of August, 2019.
CENTURYLINK
Anderl
Attorney for Qwest Corporation dba
Centurylink QC
AppLtcetroN FoR AppRovAL oF AMENDMENT To INrnncouNsctroN
AcRssuENr [Ter;^1,x, INc.) - P age 2
CenturyLink
1600 76 Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
I hereby certify that on this 2l't day of August, 2019, 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 83720-0014
Diane. Hanian@puc. idaho. gov
Hand Delivery
U. S. Mail
XX Overnight Delivery
Facsimile
Email
David Aldworth, President & CEO
Teliax, Inc.
2150 West 29th Ave.
Denver, CO 80211
[e-mail]
Hand Delivery
U. S. Mail
Overnight Delivery
FacsimileXX Email
C,/w
APPLICATION FoR APPRoVAL oF AMENDMENT To INTERCoNNECTIoN
AGREEMENT [TELrAx, INC.) - Page 3
CenturyLink
1600 7'h Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
CERTIFICATE OF SERVICE
Lisa A. Anderl (WSBA#I3236)
CenturyLink
1600 7th Ave, Room 1506
Seattle, Washington 98191
Telephone: [phone]
li sa. anderl @centurylink. com
ApplrcarroN oF Qwnsr ConronauoN DBA
CnNruRvLrNK QC Fon AprnovAl oF AN
AITBxUITBNT To INTTncoNNECTION
AcnmvrBNT wrrlr Tnl,raxr INc. Punsu.l,Nr
ro 47 U.S.C. $252(e)
REC E IVE D
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.: QWE-T-19-04
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 Agreernent. The Interconnection Agreement
was approved by the Idaho Public Utilities Commission on August 12,2019 under Order No.
34407 (the "Agreement"). The Carrier Partner for Interconnection VoIP Provider Amendment to
the Interconnection Agreement ("Amendment") between CenturyLink and Teliax, lnc.
("Teliax") 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
AppLICATIoN roR AppRovel oF AMENDMENT To INrrRcouNecrloN
AcREEMENT [Trlnx,INc.) - Page I
CenturyLink
1600 76 Ave., Suite 15o6
seattle, wA 98191
Telephone: [phone]
agreement; or the implementation of such an amendment (or portion) is not consistent with the
public interest, convenience and necessity.
CenturyLink respectfully submits this Amendment provides no basis for either of these
findings, and, therefore requests that the Commission approve this Amendment expeditiously.
This Amendment is consistent with the public interest as identified in the pro-competitive
policies of the State of Idaho, the Commission, the United States Congress, and the Federal
Communications Commission. Expeditious approval of this Amendment will enable Teliax 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 21't day of August, 2019.
CENTURYLINK
Anderl
Attorney for Qwest Corporation dba
CenturyLink QC
APPUCaTIoN FoR APPRoVAL oF AMENDMENT To INTERCoNNECTIoN
AcnEEvrNr [Teuax, INc.) - Page 2
CenturyLink
1600 70 Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
CERTIFICATE OF SERVICE
I hereby certify that on this 2l't day of August, 2019, 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
47 2 W est Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Diane. Hanian@puc. idaho. gov
David Aldworth, President & CEO
Teliax, Inc.
2150 West 29h Ave.
Denver, CO 80211
[e-mail]
Hand Delivery
U. S. MailXX Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
FacsimileXX Email
C ,
/w
APPLICATION FoR APPRoVAL oF AMENDMENT To INTERCoNNECTIoN
AGREEMENT [TELrAx, tNc.) - Page 3
CenturyLink
1600 7o Ave., Suite 1506
Seattle, WA 98191
Telephone: [phone]
Carrier Partner for lnterconnected VolP Provider Amendment
to the lnterconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
Teliax, lnc.
for the State of ldaho
This Carrier Partner for lnterconnected VolP Provider Amendment (the "Amendment") is to the
lnterconnection Agreement between Qwest Corporation dba CenturyLink QC ("CenturyLink"),
and Teliax, lnc. ("CLEC"). CenturyLink and CLEC shall be known jointly as the "Parties".
RECITALS
WHEREAS, CenturyLink and CLEC entered into an lnterconnection Agreement ("Agreement") for
service in the state of ldaho concurrent with this Amendment that is also filed with the
Commission, which, among other terms, required each party to provide for the exchange of
Exchange Service (EAS/Local), lntraLATA LEC Toll, Transit, VolP-PSTN Traffic and Jointly
Provided Switched Access traffic; and
WHEREAS, CLEC wishes to act as a Carrier Partner for an lnterconnected VolP Provider, which
obtains their own number resources pursuant to FCC Report and Order 15-70 ("VolP Numbering
Order"), released June 22,2015. CLEC will provide a switch for its use and seeks to combine
CLEC's traffic with lnterconnected VolP Provider's VolP-PSTN Traffic and exchange such traffic
with CenturyLink according to the terms of this "Carrier Partner for lnterconnected VolP Provider
Amendment" (the "Carrier Partner Amendment"), subject to limitations and requirements of the
Local Exchange Routing Guide ('LERG") and other applicable requirements, including but not
limited to the Agreement and the Amendment; and
WHEREAS, the Parties wish to amend the Agreement under the terms and conditions contained
herein.
AGREEMENT
NOW THEREFORE, in consideration of the mutualterms, covenants and conditions contained in
this Amendment and other good and valuable consideration, the receipt and sufficiency of which
is hereby acknowledged, the Parties agree as follows:
Amendment Terms
The Agreement is hereby amended by adding specific terms and conditions under which CLEC
exchanges traffic with CenturyLink as set forth in Attachment 1 to this Amendment, attached
hereto and incorporated herein by this reference.
Effective Date
This Amendment shall be deemed effective upon approval by the Commission, or by being
permitted to go into effect by operation of law; however, the Parties may agree to implement the
provisions of this Amendment upon execution. To accommodate this need, CLEC must generate,
if necessary, updated customer documentation. ln addition, all system updates will need to be
completed by CenturyLink. Carrier Partner will be notified when all system changes have been
made. Actual order processing may begin once these requirements have been met.
April 17, 2}19lKlclCarrier Partner for lnterconnected VolP Provider Amd/Teliar/lD
Ame n dm e nt to C DS- 1 904 1 7 -0002 (v.0 1 .25.20 1 7 -2)
1
Further Amendments
Except as modified herein, the provisions of the Agreement shall remain in full force and effect.
The provisions of this Carrier Partner Amendment, including the provisions of this sentence, may
not be amended, modified or supplemented, and waivers or consents to departures from the
provisions of this Carrier Partner Amendment may not be given without the written consent thereto
by both Parties' authorized representative. No waiver by any Pafi of any default,
misrepresentation, or breach of warranty or covenant hereunder, whether intentional or not, will
be deemed to extend to any prior or subsequent default, misrepresentation, or breach of warranty
or covenant hereunder or affect in any way any rights arising by virtue of any prior or subsequent
such occurrence.
Entire Aqreement
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.
Teliax, lnc.Qwest Corporation dba CenturyLink QG
Da-rZ4Hr""rxd W
Signature
David Aldworth
Signature
Kimberly J. Povirk
Name Printed/Typed
President and CEO
Name Printedffyped
Director Sales Support
Title
Jun 4,2019
Title
Jun 4,2019
Date Date
April 17, 2}l9lljclCarrier Partner for lnterconnected VolP Provider Amd/Teliax/lD
Ame n d m e nt to C DS- 1 904 17 -0002 (v.0 1 .25.20 1 7 -2)
2
ATTACHMENT 1
ATTACHMENT 1
The followino lanquaoe is added to the existinq lanquaqe. in the Aareement, in its
entiretv:
Definitions
Carrier Partner is a Certified Local Exchange Carrier (CLEC) that provides the facilities and
trunking that an lnterconnected VolP Provider needs in order to exchange traffic with CenturyLink
and demonstrates facilities readiness as described in the VolP Numbering Order.
Denial of Service (DoS) is an action that prevents legitimate use(s)from using or being provided
service.
lnterconnected VolP Provider is an entity that provides interconnected VolP service, as that term
is defined in 47 C.F.R. S9.3 and that obtains numbering resources as described in the VolP
Numbering Order.
Terms of Carrier Partner Amendment
1. Pursuant to the terms of this Amendment, CLEC will be exchanging with CenturyLink
VolP-PSTN Traffic, Transit and Jointly Provided Switched Access traffic of lnterconnected VolP
Providers on the CLEC's interconnection trunks.
1.1 Prior to CLEC exchanging traffic for an lnterconnected VolP Provider with
CenturyLink, CLEC will notify CenturyLink and CenturyLink will confirm that the
lnterconnected VolP Provider has entered into an "lnterconnected VolP Provider
Numbering Agreement" with CenturyLink.
1.2 CLEC will notify CenturyLink when CLEC is no longer routing an lnterconnected
VolP Provider's traffic on CLEC's interconnection trunks.
1.3 CLEC will provide such notifications to their CenturyLink Customer Account
Manager (CAM).
1.4 CLEC will follow applicable procedures of the LERG and the CLEC Agreement in
order to identify the OCNs and NPA-NXX(s) of the lnterconnected VolP Provider
which will be associated with the CLEC's Switch and routed on the CLEC's
interconnection trunk groups.
1.5 The lnterconnected VolP Provider may use a POI CLLI for code entry in LERG 6
and they must also designate the responsible CLEC Carrier Partner's end office
CLLI as the Actual Switch lD in LERG 7 SHA.
2. CLEC and CenturyLink will continue to exchange traffic under the terms of the CLEC
Agreement, including treatment of traffic terminating to CenturyLink end users. Solely for purposes
of this Amendment, all traffic originated by parties utilizing CLEC and terminating to CenturyLink end
April 17, 2}19klclCarrier Partner for lnterconnected VolP Provider Amd/Teliax/lD
Ame n dm ent to C DS- 1 904 1 7 -0002 (v.0 1 .25.20 1 7 -2)
3
ATTACHMENT 1
users or transiting CenturyLink to other providers will be treated as though originated by CLEC,
including but not limited to terminating intercarrier compensation, Transit compensation,
compensation for use of interconnection transport facilities, and establishment of direct trunk groups.
3. No compensation for transiting traffic will be paid by CenturyLink to CLEC for traffic that
CenturyLink sends through the CLEC to terminate to lnterconnected VolP Provider. All CenturyLink
end user traffic will be treated as though it was terminated with the CLEC.
4. lnterconnected VolP Provider traffic will be included as the CLEC's responsibility in
accordance with applicable terms of the Agreement.
5. This Amendment does not otherwise modify or supersede the terms and conditions of any
agreement that CLEC may have with CenturyLink, including tariff, lnterconnection and/or other
agreements.
6. This Amendment does not authorize CLEC to bill CenturyLink on behalf of lnterconnected
VolP Provider for any charges associated with transit traffic, terminating traffic or interconnection
facilities, including, but not limited to any compensation arrangements contained in separate
agreements or tariffs with CenturyLink.
7. CLEC will pass unaltered signaling information (e.9., originating Calling Party Number and
destination called party number, etc.) for the lnterconnected VolP Provider's traffic per 47 C.F.R. 5
64.1601 and industry standards.
8. CLEC agrees that CenturyLink may discontinue accepting all traffic delivered over CLEC's
trunking where CenturyLink experiences from lnterconnected VolP Provider a Denial of Service
(DoS) attack or such lnterconnected VolP Provider traffic othenruise contributes to the degradation
of CenturyLink's network or CenturyLink's ability to provide service to its customers. CLEC agrees
to remove the inappropriate lnterconnected VolP Provider traffic from its network prior to
CenturyLink's subsequent acceptance of CLEC's other traffic. Following any such event, CLEC will
establish a separate trunk group for the lnterconnected VolP Provider's exclusive use for any
su bseq uent I ntercon nected Vo I P Provider traffic.
9. Where CLEC agrees to allow its interconnection trunks with CenturyLink to also be used
for the routing of lnterconnected VolP Provider's traffic, CLEC will ensure traffic routed over such
trunks is destined solely to the geographic area served by CenturyLink's switch as defined in the
LERG.
10. CLEC agrees that CenturyLink will not be responsible to provide 911 services directly to
the lnterconnected VolP Provider and that instead CLEC will be responsible as the Carrier Partner
to provide such 91 1 services in accordance with applicable terms of the Agreement.
11. lf CLEC chooses to obtain numbering from NANPA under a different OCN as an
lnterconnected VolP Provider, they must have both a Commercial lnterconnected VolP Provider
Numbering Agreement and this Amendment in order to route their lnterconnected VolP Provider
traffic associated with that OCN on CLEC's interconnection trunks.
April 17, 2O19ll<lclCarrier Partner for lnterconnected VolP Provider Amd/Teliax/lD
Amend m ent to C D S- 1 904'l 7 -0002 (v.0 1 .25.20 1 7 -2)
4