20220801Qwest Amendment with Intrado Safety-UNE Resale.pdf

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August 1,2022
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Via Email Submission
s e cre tary@1t u c. i d, a h o. go v
Ms. Jan Noriyuki, Secretary
Idaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, D 83714
Re: Case No.:
Application for Approval of Amendment to Interconnection Agreement
Dear Ms. Noriyuki:
Attached for filing are an Application for Approval of Amendment to Interconnection
Agreement along with the Unbundled Network Elements (UNEs) - Resale Forbearance
Amendment to the Interconnection Agreement between Qwest Corporation dba CenturyLink QC
("CenturyLink") and Intado Safety Communications,Inc. forthe State of Idaho. CenturyLink
respectfully requests that this matter be placed on the Commission Decision Meeting Agenda for
expedited approval.
Please feel free to contact me with any questions regarding this submission. Thank you
for your assistance in this matter.
Sincerely
9ryAdf//t
Josie Addington /
Legal Assistant
Attachments
cc: Service List
1600 7r' Avenue, Floor 15
Seattle, Washington 981 91
206-806-7339
[e-mail]
William E. Hendricks, III (WSBA#29786)
Lumen
902 Wasco Street
Hood River, OR 97031
541-387-9439
Tre. hendricks@lumen. com
Arpr,rclrroN oF Qwnsr ConrourloN DBA
Cnm.rnylrNK QC Fon ArrnovAl or AN
AupuoupNT To lxrnncomvncrloN
Acnnpupur wITH Ixrupo Slrnrv
CouuuxrcATloNs, Iuc. Punsunnr ro 47
U.s.C. $2s2(e)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.:
APPLICATION FOR APPROVAL OF
AMENDMENT TO INTERCONNECTION
AGREEMENT
Qwest Corporation dba CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the lnterconnection Agreement. The Interconnection Agreement
was approved by the Idaho Public Utilities Commission on April 16,2010 under Order
No. 31051 (the "Agreement"). The Unbundled Network Elements (LJNEs) - Resale Forbearance
Ame,ndment ("Amendment") between CenturyLink and Intado Safety Communications, Inc.
('Intrado Safety") is submitted herewith.
This Amendment was reached through voluntary negotiations without resort to mediation
or arbihation 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
ApplrcanrcN FoR AppRovAL or AurNougNr ro INTencoNNECTIoN
AcnsrururICLEC] -Page I
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 Intado
Safety 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 concem other parties not a party to the negotiations.
Expeditious approval would further the public interest.
Respectfully submitted this I't day of August,2022.
CENTT'RYLINK
William E. Hendricks, III
Attorney for Qwest Corporation dba
CenturyLink QC
AppLICATIoN roR Appnovel or AMrNDr,IrNr ro IvrencoNNEcrroN
AcnrsurNr [CLEC] -Page 2
CERTIFICATE OF SERVICE
I hereby certit/ that on this l't day of August,2022,I served the foregoing
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONNECTION
AGREEMENT upon all parties of record in this matter as follows:
JanNoriyuki, Secretary
Idaho Public Utilities Commission
Stephe,n Cadden, President
Intrado Safety Communications, Inc.
Via Email:
secretary@puc. idaho. eov
Via Email:
Steve. caden@ intrado. com
A*/"aq//t
Josie,(ddidgton /
ApplrcerrcN roR Appnover oF AMENDMEI.IT To INTERcoNNECTIoN
Acneer"{ENr [CLEC] -Page 3
Unbundled Network Elements (UNEs) - Resale Forbearance Amendment
to the lnterconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
lntrado Safety Communications, lnc.
for the State of ldaho
This is an Amendment ("Amendment') to the lnterconnection Agreement between Qwest
Corporation dba CenturyLink QC ("CenturyLink"), a Colorado corporation, and lntrado Safety
Communications, lnc. (fl<a West Safety Communications, lnc.) ("CLEC'). CenturyLink and
CLEC shall be known jointly as the "Parties".
RECITALS
WHEREAS, the Parties entered into an lnterconnection Agreement ("Agreement') for service in
the state of ldaho which was approved by the Commission on April 16, 2010; and
WHEREAS, on July 12, 2019, the Federal Communications Commission (the, "FCC" or
"Commission") released Order FCC 19-66, a Report and Order on Remand and Memorandum
Opinion and Order in WC Docket Nos. 18-141, et al(the "UNE Transport Order'), which became
effective upon release; and
WHEREAS, on August 2,2019, the FCC released Order FCC 19-72, a Memorandum Opinion
and Order in WC Docket 18-141 (the "UNE Analog Loop and Resale Forbearance Order"),
which became effective upon release (together, with the UNE Transport Order, collectively
referred to as the 'Forbearance Orders"); and
WHEREAS, the Parties agree that the Forbearance Orders are changes in Applicable Law that,
pursuant to the terms of the Agreement, must be incorporated through an amendment to the
Agreement; and
WHEREAS, in order to implement the terms of the Forbearance Orders and consistent with the
terms of the Agreement regarding changes in Applicable Law, the Parties desire to amend the
Agreement further 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 Agreement is hereby amended by adding terms and conditions for Unbundled Network
Elements (UNEs) and Resale as set forth in Attachment 1 and Exhibit A to this Amendment,
attached hereto and incorporated herein by this reference. Any capitalized terms not defined
specifically in this Amendment are as defined in the Agreement.
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
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provisions of this Amendment upon execution. To accommodate this need, CLEC must
generate, if necessary, an updated Customer Questionnaire. The Parties agree that so long as
CenturyLink implements the billing changes and the true-up as set forth below, the CLEC's bills
shall be deemed accurate and adjusted without enor.
Further Amendments
Except as modifted herein, the provisions of the Agreement shall remain in fullforce and effect.
The provisions of this Amendment, including the provisions of this sentence, may not be
amended, modified or supplemented, and waivers or consents to departures from the provisions
of this Amendment may not be given without the written consent thereto by both Parties'
authorized representative. No waiver by any 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 wananty or covenant hereunder or
affect in any way any rights arising by virtue of any prior or subsequent such occurrence.
Entlre 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 shal!
constitute one and the same instrument.
lntrado Safety Communications, !nc.Qwest Corporatlon dba CenturyLlnk QC
.at ?
Stephe{adden (May 1o,2o2l tt 47 MDT)
Ktwbetlq 'z fut lLk
Kimberly J. Povirl'{May 12, 2021 l4:38 CDT)
Signature
Steohen Cadden
Signature
Kimberlv J. Povirk
Name Printedffyped
President
Name Printed/Typed
Sr. Dir. Bus. Oos Wholesale Sales
Title
May 10,2021
Title
May L2,202L
Date Date
May 6,20211nap//UNE-Resale ForbearancE Amd/lntrado Satsg Communications/lD
Q Amendment to CDS- 1 00 1 1 2-00 1 0 {v.01 .22.20204)
2
ATTACHMENT 1
ATTACHMENT 1
1. Resale Provisions - Pursuant to the Forbearance Orders, CLEC's ability to order new
services and retain existing services from CenturyLink for resale pursuant to Sections 6,
including Directory Listings and Directory Assistance that pertain to Resale, of the
Agreement are altered as follows:
a. Effective Date to February 2, 2020 - During the time period from the Effec{ive
Date of this Amendment until February 2,2020, CLEC may order any services
for resale pursuant to the applicable terms and conditions of the Agreement. ln
addition, CLEC may make changes in existing resold services, also pursuant to
the applicable terms of the Agreement, until February 2,2020.
b. February 2,2020 to August 2,2022 - After February 2,2020, CLEC cannot
order any services for resale from CenturyLink pursuant to the applicable
provisions of the Agreement. Any orders for new services for resale will be
pursuant solely to the terms of the applicable Tariff for the service including any
ICB agreements entered into under the applicable Tariffs.
i. For any services procured for resale under the terms of the Agreement
('Existing Resale Services') on February 2,2020 or prior, CenturyLink will
continue to provide such Existing Resale Services pursuant to the terms
of the Agreement, including any discounts delineated in Exhibit A of the
Agreement.
ii. CLEC cannot make any changes to such Existing Resale Services, as
they will be treated in a "grandfathered" status, with continued receipt or
disconnection of the Existing Resale Services the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
services, it will be treated as new services for resale and will be provided
solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it will no longer submit any orders for resale services
under the Agreement from CenturyLink after February 2,2020. CLEC
agrees that it is the CLEC's responsibility to ensure that no further orders
for resold services under the Agreement are submitted after February 2,
2020. lf resold services are ordered after February 2,2020 CLEC agrees
that the Agreement is no longer in effect and resold services are being
ordered per the applicable tariff at the full rates in the tariff.
1. ln order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on no more than quarterly basis, may
conduct an audit of CLEC's order activity after February 2,2020,
in order to identify any mistaken instances of attempting to order
resold services under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink may issue a bill using the effective date of the
changes that the applicable service was originally ordered
("Resale True-Up Bill") removing the discount for such services
and billing under the Tariffs at full tariffed prices. CLEC agrees
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ATTACHMENT 1
not to contest such Resale True-Up Bills unless such billing is not
consistent with the applicable Tarilf .
c. After August2,2O22 - The Parties agree that CenturyLink will no longer provide
any Existing Resold Services under the terms of the Agreement after August 2,
2022. CLEC is solely responsible for either disconnecting such Existing Resold
Services prior to August 2, 2022 or ordering them as new services under the
applicable Tariffs.
2. UNE Analog Loops - Pursuant to the terms of the Forbearance Orders, the terms and
conditions under which CLEC may order and maintain Analog Unbundled Loops, as
defined in Section 9.2.2 provided in the Agreement and Two-Wire/Four-Wire Unbundled
Distribution Loop, as provided in Section 9.3.2.1.1 of the Agreement (together, refened
to as "Analog Unbundled Loops') are altered as follows:
a. Effective Date to February 2, 2020 - During the time period from the Effective
Date of this Amendment until February 2, 2020, CLEC may order Analog
Unbundled Loops pursuant to the applicable terms and conditions of the
Agreement. ln addition, CLEC may make changes in existing Analog Unbundled
Loop arrangements, also pursuant to the applicable terms of the Agreement.
b. February 2,2020 to August 2,2022 - After February 2,2020, CLEC cannot
order any Analog Unbundled Loops from CenturyLink pursuant to the applicable
provisions of the Agreement.
i. For any Unbundled Analog Loops procured under the terms of the
Agreement ("Existing Analog Loops") on February 2, 2O2O or prior,
CenturyLink will continue to provide such Existing Analog Loops pursuant
to the terms of the agreement, including the applicable rates delineated in
Exhibit A of the Agreement.
ii. CLEC cannot make any changes to such Existing Analog Loops, as they
will be treated in a "grandfathered" status, with continued receipt or
disconnection of the Existing Analog Loops the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
services, it will be treated as a conversion to Special Access services
being provided solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it wi!! no longer submit any orders for Unbundled
Analog Loops under the Agreement from CenturyLink after February 2,
2020. CLEC agrees that it is the responsibility of the CLEC to ensure that
no further orders for such Analog Unbundled Loops under the Agreement
are submitted after February 2,2020.
1. ln order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on a no more than quarterly basis, may
conduct an audit of CLEC's order activity after February 2,2020,
in order to identiff any mistaken instances of attempting to order
Analog Unbundled Loops under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink will request CLEC to disconnect such services and
order them as new by ordering the Special Access service under
May 6,2021Inapl/UNE-Resale Forbearance Amd/lntrado Safety Communications/lD
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ATTACHMENT 1
the applicable Tariff, changing the applicable rate charged, and
CenturyLink may issue a bill using the effective date of the
changes that the applicable Unbundled Analog Loop was
originally ordered ("Analog Loop True-Up Bill"). CLEC agrees not
to contest such Analog Loop True-Up Bills unless such billing is
not consistent with the applicable Tariff.
iv. CLEC agrees that any provisions in the Agreement that provide for Line
Splitting or Loop Splitting are also removed and may no longer be
ordered, as they all involve an order of an Unbundled Analog Loop. Any
existing arrangements will be maintained during the time period of this
section.
c. After August2,2022 - The Parties agree that CenturyLink will no longer provide
any Unbundled Analog Loops under the terms of the Agreement after August 2,
2A22, including any arrangements for Line Splitting or Loop Splitting. CLEC is
solely responsible for either disconnecting such Analog Unbundled Loops prior to
August 2, 2022 or converting them to a service under the applicable Tariffs. For
any Analog Unbundled Loops in place as of August 2, 2022, CLEC agrees that
CenturyLink will convert any such Analog Unbundled Loops to the appropriate
SpecialAccess service under the applicable Tariff, and CLEC is then responsible
for such services under that Tariff. !n addition, should any charges be necessary
as part of that conversion, CLEC agrees that it is responsible for payment of such
charges and will not dispute application of such charges necessary for the
conversion. As Line Splitting and Loop Splitting are not available service under
CenturyLink's Tariffs, CLEC must convert to alternative arrangements that meet
its needs, as such arrangements will otherwise be terminated after August 2,
2022.
d. Alternative Analog Unbundled Loops Commercial Arrangements - The
Parties understand and agree that the Forbearance Orders specifically permit
alternative commercia! arrangements for the provision of UNEs that are impacted
by the Forbearance Orders. Nothing in this Amendment either requires
CenturyLink to enter into such alternative arrangements or prohibits the Parties
from reaching an agreement on terms and conditions of such alternative
arrangements. The Parties agree that nothing in such alternative arrangement
would ever be intended to change any of the obligations under this Agreement,
rather to be in parallel to the terms and conditions of the Agreement.
e. UNE Combinations - Any UNE Combinations provided under the Agreement
that might include UNE Analog Loop are also treated as UNE Analog Loops
under this Agreement.
3. UNE Transport - Pursuant to the terms of the Forbearance Orders, the terms and
conditions under which CLEC may order and maintain Unbundled Dedicated lnteroffice
Transport ('UDIT'), as provided in Section 9.6.1.1 of the Agreement and Enhanced
Extended Loop ("EEL"), os provided in Section 9.23.3.7 of the Agreement (together,
referred to as "UNE Transport') are altered as follows:
a. Effective Date to January 12, 2020 - During the time period from the Effective
Date of this Amendment until January 12,2020, CLEC may order UNE Transport
pursuant to the applicable terms and conditions of the Agreement. ln addition,
May 6, 2021lnap//UNE-Resale Forbearance Amd/lntrado Safe$ Communications/lD
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5
ATTACHMENT 1
CLEC may make changes in existing UNE Transport arrangements, also
pursuant to the applicable terms of the Agreement.
b. January 12, 2020 to July 12, 2022- After January 12, 2020, CLEC cannot order
any UNE Transport from CenturyLink pursuant to the applicable provisions of the
Agreement that has each endpoint in one of the Serving Wire Centers listed on
the Wholesale website: http://www.centurvlink.comlwholesale/clecs/nta.html#UNE-F
to thls Amendment ("Forbearance UNE Transport"). For any UNE Transport that
does not meet the definition of Forbearance UNE Transport, such UNE Transport
will continue to be available and provided under the terms of the Agreement,
including the terms under which it may be wtthdrawn.
i. For any Forbearance UNE Transport procured under the terms of the
Agreement ('Existing Forbearance UNE Transport') on January 12,2A20
or prior, CenturyLink will continue to provide such Existing Forbearance
UNE Transport pursuant to the terms of the Agreement, including the
applicable rates delineated in Exhibit A of the Agreement.
ii. CLEC cannot make any changes to such Existing UNE Transport, as they
wil! be treated in a 'grandfathered" stafus, with continued receipt or
disconnection of the Existing UNE Transport the only options under the
Agreement available to CLEC. lf CLEC issues an order to change such
seryices, it will be treated as a convercion to Special Access services
being provided solely under the Tariffs, rather than under the Agreement.
iii. CLEC agrees that it will no longer submit any orders for Forbearance
UNE Transport under the Agreement from CenturyLink after January 12,
2020. CLEC agrees that it is the CLEC's responsibility to ensure that no
further orders for such Forbearance UNE Transport under the Agreement
are submitted after January 12,2O2O.
1. !n order to ensure compliance with these provisions, the Parties
agree that CenturyLink, on a no more than quarterly basis, may
conduct an audit of CLEC's order activity after January 12,2020,
in order to identiff any mistaken instances of attempting to order
Forbearance UNE Transport under the terms of the Agreement.
2. Should such instances occur, the Parties further agree that
CenturyLink will convert such services to the Special Access
service under the applicable Tariff, changing the applicable rate
charged as needed, and issue a bill to make the effective date of
the charges be the date the applicable Forbearance UNE
Transport was originally ordered ("UNE Transport True-Up Bill').
CLEC agrees not to contest such UNE Transport True-Up Bills
unless such billing is not consistent with the applicable Tariff.
c. After July 12,2022 - The Parties agree that CenturyLink wil! no longer provide
any Forbearance UNE Transport under the terms of the Agreement afrer July 12,
2022. CLEC is solely responsible for either disconnecting such Forbearance
UNE Transport prior to July 12, 2022 or converting to Special Access service
under the applicable Tariffs. For any Forbearance UNE Transport in place as of
July 12, 2022, CLEC agrees that CenturyLink will convert any such Forbearance
May 6,20211nap//UNE-Resale Forbearance Amd/lntrado Safuty Communications/lD
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AfiACHMENT 1
UNE Transport to the appropriate Specia! Access service under the applicable
Tariff, and CLEC is then responsible for such services under that Tariff. ln
addition, should any charges be necessary as part of that conversion, CLEC
agrees that it is responsible for payment of such charges and will not dispute
application of such charges necessary for the conversion.
d. Alternative UNE Transport Commercial Arrangements The Parties
understand and agree that the Forbearance Orders specffically permit alternative
commercial arrangements for the provision of UNEs that are impacted by the
Forbearance Orders. Nothing in this Amendment either requires CenturyLink to
enter into such alternative arrangements or prohibits the parties from reaching an
agreement on terms and conditions of such alternative arrangements. The
Parties agree that nothing in such alternative arrangement would ever be
intended to change any of the obligations under this Agreement, rather to be in
parallel to the terms and conditions of the Agreement.
May 6, 2021/nap//UNE-Resale Forbearance Amd/lntrado Sabty Communications/lD
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9.6.3.3 ??ra *)321.34 B.D.E B.D.Ec634Orer 5O Miles t235.8{3.t4.83 B D.E BDE
9.23 IJNE Comblnatloni
.23.2 Enhancod Edenr :l)
E2321 EEL Lmo. DSO 2-Wirc Analm
FFI 2-WiE I mD lnstalatiM
5.23.2.1.1.1 lFiBt 3245.1 I D. E.'l
g 23.2 1 'l .2 I Eadr Addilional 3182 07 DF1
s.23.2.1.2 2-Wire Analoo Looo (see ratss in 9.2.1.1)
5.2ts.2.1.2.1 lzone 1 s15.65 D E-15??r1r2 lTo c?323 76 n F 15
9.23.2.'l-2.3 lzone 3 34{t_50 D. E. 15
9.23_2.2 4-WiEAmld
s.23.2.2.1 EEL +Wirs Lmo lnslallation
9)A??11 lFtEr j215 11
9.23.2.2.1.2 lEacfi Additional 3182.97 D.E-1
2a222 &Wire Analm Lmo lsm rales in g 2 I 3)
9-23-2.2-2.1 lzone 1 t30.70 D. E. t5
S-2?-2.2.2.2 lzore2 3z16-63 DE't5
9.23.2.2.2.3 lzone 3 37C a7 D. E. 15g2a)a FFI lmD. DSIa)ara,:l nS{ I md ln.lallrti6n
9"23.2.3.1-1 lFiBt s300.49 D. E. ,I
c2a 2 a 12 lFxrl Addilionel s2?5!DFI
s.23.2.3-2 DSI Ceabla Loo (se€ Etes in 9-2-3.3)E2a2321 lz]ffi1 346.t8 DF15
9.23.2.3.2.2 lzo/'te 2 $86.46 D. E. 15s2X2X.2l lzone 3 sgs 96 DE15
9.23.2.6 EEL Reananoemenl
E 23 2_4.1 DSO lt30-83 D. E. 12q)?ra,dh (:rMcilv Staa 5(l
g2a2e FEL Mulliolexino
s.23.2.DSI td DSO 3263 A6 j21892 EDF DF1
s.23.2.4.2 DS3 to DS1 3304.22 3246-92 B.D.E D-E.1o)?r9 I Chennal Perlomrnm
s.23.2.9.'.|DSo Low Side Channelizalion si3.10 B.D.E
823.2.9.2 DSI / DSo Lol r Side Chann€lization s7.17 B.D.E
9.25
9251 m Mur lie Anald
9.25.'t.'l LMC 2-W tlion
7 25 1.1.1 FiEt s225.67 D. E.1
,?5 r.}l A.lditid.l Slaa DF1
E25 12 2-Wire Anald Lm (se rates in 9.2-'l.l)
Zone 1 315 65 DE,t5
,.25.1.2.2 Zone 2 3r3 7A D F {5
q24123 Zone 3 t40.50 D. E" 15
9.25.2 Lmo Mux. 4-Wire AnE
s2521 0)ar1 El t2)5 A7 DF1
9-25-2-1-2 Eedr Additimel $148.96 D.E.1
9.25.2-2
9.25.2.2.1 rne I 330 7()
s25222 Zone 2 sll6.63 D. E. 15
Page 2 of 3
E rlbltA
ldaho
1A.25-2.2.3 lzona 3 37e a7 DE15
0.3.2 Premlum / PrivEcy LFtings G€n6rd
E)drerg€
Tarilt Rate,
Lesg
Whole3de
Dscounl
G€n€rd
Edrange
faril Rate,
Lesg
Wholerde
Discounl
D,E D,E
B Cost Dockat OWE-T{I-11 Order No- 29.lOB (Jenuaru 5- 2OO{) rata offedive Jrnufl 5- 2oolt-
D fhe Fedoral Communicstions Commi$ion (lh€, "FCC' or'Comd{sslon') releasod Ord6r FCC 1&66, a R€port d|d Order on Remand and Memorsndum
Opinion fid Order ln WC Docket Nos. 1&141, et al (th6 'UNE Trarspod Ord€f), and on Argust 2, 2019, rdoased Order FCC 1$72, a Memorandum
Oplnion and Order in WC Dock€t 1&'1.11 (lhe'UlC Arialog Loop and Resde Forteardlce Onter) which dt€r€d CenturyLink's obligdions to provide certain
unbundled neirvork elements. As a r$ult, any rato udlh this footrrole attacfied to it only appller to UNES and R6sold soMcos accordlng to lhe teIms of the
UNgResde Fofiearance Arendment of the Agreement. Any rde with this footnote is no longer applicable ln any way aner August 2, 2022, again
E fh€ rates in this table appv solely to seNicss ordered for UNE/R$ds on or b€fior€ Februsy 2, 2020. Any new 3eMc$ for UIE/Rosd€ lncomclly ordaredil€r February 2, 2020 will not have the discounts or rales applicdle in this table, but in3tsad wlll be subJed to the appllcabl€ ttif, pri:. lbt or cdalog
H
1 fELRlCratespropos€dinCo3tDocketQWE-i-01-11l€stimonyfrlodonNo\,6mb6r12,2003. Thecaseu,asbiturcatedandtheratssu3ingthisfootnoteare
h6md{ i^ thfi. , .rf lh. dl ,l.Fld,t)
l5 Flete was DElriildv ordered ltr lhis dmml In e difitrst mlim of Edlibit A
Page 3 of3