20220727Application.pdf

Juily27,2022
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Via Email Submission
s e cretaq@pu c. ida h o. gov
Ms. Jan Noriyuki, Secretary
Idaho Public Utilities Commission
I 1331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, ID 83714
CaseNo.: Q1oe- 7- }a- o 2.
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 Third Party Transit Provider Amendment between Qwest Corporation
dba CenturyLink QC ("CenturyLink") and Wide Voice,LLC for the 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,
Re:
O,*lrAq/fr
rti" [aaaetd
Legal Assistant
Attachments
cc: Service List
1600 7th Avenue, Floor 15
Seattle, Washington 98191
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
Amr,rc,lrroN oF Qwnsr Conron^luoN DBA
Cnxrunylrxr QC Fon AppnovAl oF Arr
AunNounNT To lxruncoxxEcTloN
Acnnnunnr wITH Wron vorcr, LLC
Punsu.rxr ro 47 U.S.C. $252(e)
BEFORE THE IDAIIO PTIBLIC UTILITIES COMMISSION
CASE NO.:
APPLICATION FOR APPROVAL OF
AMEI\DMENT TO INTERCONNECTION
AGREEMENT
Qwest Corporation dba CenturyLink QC ("CenturyLink") hereby files this Application
for Approval of Amendment to the Interconnection Agreement. The lnterconnection Agreement
was approved by the Idaho Public Utilities Commission on October 20,2016 under Order
No. 33632 (the 'Agreemenf'). The Third Party Transit Provider Amendment ("Amendment")
between CenturyLink and Wide Voice, LLC ("Wide Voice") is submitted herewith.
This Amendment was reached through voluntary negotiations without resort to mediation
or arbination 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 carier 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.
APPLTCETION FOR APPROVAL OP ATT,ISNDMENT TO INTENCONNECTION
AcRser,rsNr [Wna Vorce, LLC] - Page 1
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 Wide
Voice 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 zubmitted this 27ft day of July,2\22.
CENTURYLINK
William E. Hendricks, III
Attorney for Qwest Corporation dba
Centurylink QC
AppucauoN FoR AppRovAL oF AMENDMENTTo INTERCoNNECTIoN
Acneel{sNr [Wnr Vorcr,LLCI - Page 2
CERTIFICATE OF SERVICE
I hereby certiff that on this 27e day of July,2O22,I served the foregoing
APPLICATION FOR APPROVAL OF AMENDMENT TO THE INTERCONITECTION
AGREEMENT upon all parties of record in this matter as follows:
JanNoriyuki, Secretary
Idaho Public Utilities Commission
Via Email:
secretary@Fuc. idaho. gov
Via Email:
anickerson@widevoice. com
Andrew Nickerson, CEO
Wide Voice, LLC
Josie
Apprrcrq.rrox FoR AppRovAL oF AMENDMENT ro InrrncoNMCTIoN
AcREEMENT [Won VoIcr, LLC] - Page 3
Third Party Transit Provider Amendment
to the lnterconnection Agreement between
Qwest Corporation dba CenturyLink QC
and
Wide Voice, LLC
for the State of ldaho
This Amendment ("Amendment") is to the lnterconnection Agreement between Qwest
Corporation dba CenturyLink QC ('CenturyLink") and Wide Voice, LLC ('Third Party Transit
Provider"), 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, among other terms, required
each Pafi to provide for the termination of Exchange Service (EAS/Local) and ISP-Bound
traffic originated by the other Party on a "bill and keep" basls, without payment of terminating
compensation by either Party; and
WHEREAS, Third Party Transit Provider wishes to offer transiting services to other
telecommunications carriers and exchange that traffic with CenturyLink according to the terms
of this Amendment, subject to Iimitations and requirements of the Local Exchange Routing
Guide ('LERG') and other applicable requirements, including but not limited to the Agreement
and this Amendment; 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 specific terms under which Third Party Transit
Provider exchanges traffic with CenturyLink. See Attachment 1, Exhibit A and Exhibit H
attached and incorporated herein by this reference.
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,
and no waiver of any provision thereof shall be effective, except by wriften instrument executed
by an authorized representative of both Parties.
May 5, 2021 RjcM/ide Voie/lD/Amendment to C DS-1 6091 5400 1
Third Party Transit Provider Amd-Q (v.05.16.2018-2)
,l
Entlre 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
representiations by or between the Parties, written or ora!, 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 wtrich shall
constitute one and the same instrument.
Wlde Volce, LLC Qwest Corporatlon dba CenturyLlnk QC
Andrcw Niolorson
Andrew Nickerson (May 6, 2021 13:39 PDT)
,<rr/"r4 QKinbetly J. Povnk \W 6, 2ry6rt CoI )
Signature
Andv Nickerson
Signature
Kimberlv J. Povirk
Name Printed/Typed
cEo
Name Printed/Typed
Sr. Dir. Bus. Oos Wholesale Sales
Title
May 6, 2021
Title
May6,2O2L
Date Date
May 5, 2021 RjcM/ide Voioe/lD/Amendment to C DS- 1 6091 il00 1
Third Party Transit Provider Amd-Q (v.05. 1 6.201 &2)
2
ATTACHMENT 1
Terms of Third Party Transit Provider Amendment
Section 4.0 - DEFINITIONS
"Commercial Mobile Radio Service" or "CMRS" is defined in 47 U.S.C. S 332 and FCC rules
and orders interpreting that statute.
"lnterMTA" describes Wireless Telecommunications Services originating in one MTA and
terminating in another MTA.
"lnterMTA Factors' are factors that are used in intercarrier compensation to determine
lnterMTA and lnterMTA Roaming MOUs when CenturyLink's end user Customer is originating a
Land-Mobile ca!!to the WSP's end user customer in another MTA.
"lnternet Service Provider-Bound' or 'lSP-Bound' refers only to the traffic delivered to an
lnternet Service provider for which the FCC prescribed intercanier compensation in the
lntercarrier Compensation for ISP-Bound Traffic, CC Docket No. 99-68, Order on Remand and
Report and Order, 16 FCC Rcd 9151 (2001)(the "lSP Remand Orded'). Such traffic does not
include traffic delivered to an lnternet Service provider located in a different local calling area
than the calling party.
"lntraMTA" describes Wreless Non-Access Telecommunications Traffic that originates and
terminates in the same MTA.
"Major Trading Area (MTA)' is a geographic area established in Rand McNally 1992
Commercial Atlas and Marketing Guide and used by the FCC in defining CMRS license
boundaries for CMRS providers for purposes of Sections 251 and 252 of the Act.
"Transit Service" is any traffic that originates from one (1) Telecommunications Carrieds network
and/or its end user(s), transits another Telecommunications Carrier's network, and terminates to
yet another Telecommunications Carrier's network and/or its end user(s).
'VNXX Traffic" is all traffic originated by a Party's End User Customer and dialed with a local
dialing pattern that is not terminated to the other Party's End User Customer physically located
within the same CenturyLink Local Calling Area (as approved by the state Commission) as the
originating caller, regardless of the NPA-NXX dialed. VNXX does not include originating 8XX
traffic.
"VoIP-PSTN Traffic" includes any traffic previously refened to in the Agreement as 'VolP" or
"VolP Traffic" or "lP Enabled Voice Traffic', and is defined as traffic which is exchanged
between a CenturyLink end user and the CLEC end user in Time Division Multiplexing ("TDM")
format that originates and/or terminates in lnternet Protocol ('lP") format, as determined in the
Order, and terminates to a Party's End User Gustomer.
"Wireless Service Provide/ or'WSP'for purposes of this Agreement is a 2-way CMRS provider
of Telecommunications service.
May 5, 2021 kjcMide Voice/lD/Amendment to C DS-1 609 I il00 1
Third Party Transit Provider Amd-a (v.05.16.201&2)
3
Section 7.0 - INTERCONNECTION
7.1 lnterconnectionFacilityOptions
7.1.1.1 CenturyLink will provide to CLEC lnterconnection at least equal in quality to that
provided to itself, to any subsidiary, Affiliate, or any other party to which it provides
!nterconnection. Notwithstanding specific language in other sections of this Agreement, all
provisions of this Agreement regarding lnterconnection are subject to this requirement.
CenturyLink will provide lnterconnection under rates, terms and conditions that are just,
reasonable and non-discriminatory. In addition, CenturyLink shall comply with all state
wholesale and retail service quality requirements. lf CenturyLink experiences issues in meeting
any service quality requirements as a direct result of CLEC's offering of Third Party Transit
Services, CenturyLink will provide notice to CLEC of such issues and CLEC agrees that it will
take actions necessary to remedy the issues CenturyLink identifies.
7.2 Exchange of Traffic
7.2.1.2.4.1 Pursuant to the terms of the Third Pafi Transit Provider Amendment, Third Party
Transit Provider wil! be exchanging Exchange Service (EAS/Local), lntraMTA, ISP-Bound,
lntraLATA LEC Toll, lnterMTA and Vo!P-PSTN traffic with CenturyLink for traffic originated by
and/or terminated to certain other telecommunications carriers ("Transit Custome/'). Prior to
Third Party Transit Provider exchanging this traffic with CenturyLink, it will identiff any Transit
Customers to CenturyLink and CenturyLink will confirm that any proposed Transit Customers
have entered into a "Routing Through a Third Party Transit Provider Amendment" with
CenturyLink, prior to the exchange of any traffic with CenturyLink.
7.2.1.2.4.1.1 Third Party Transit Provider will follow applicable procedures of the
LERG and the Third Party Transit Provider Agreement in order to identify the NPA-
NXX(s) which will be routed through 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 intral-ATA codes within the LATA.
7.2.1.2.4.1.2 Third Party Transit Provider will provide appropriate ca!! treatment per
industry standards/guidelines for traffic from CenturyLink to the Third Party Transit
Provider destined for its Transit Customers, where the appropriate network infrastructure
may not be in place between the Third Party Transit Provider and its Transit Customers.
7.2.1.2.4.1.3 The Parties do not intend to exchange traffic for lnterconnected VolP
Providers when CLEC acts as a Carrier Partner (as defined by the FCC in the VolP
Numbering Order) under this Amendment.
7.2.1.2.4.2 Third Party Transit Provider and CenturyLink will continue to exchange traffic
under the terms of the Third Party Transit Provider's Agreement, including treatment of traffic
terminating to CenturyLink end users. Solely for purposes of this Third Party Transit Provider
Amendment, alltraffic originated by parties utilizing Third Party Transit Provider and terminating
to CenturyLink end users will be treated as though originated by Third Party Transit Provider,
including but not limited to terminating intercarrier compensation and compensation for use of
local interconnection transport facilities.
May 5, 2021 l?1cM/ide Voice/lD/Amendment to C DS- 1 6091 S000 1
Third Party Transit Provider Amd-Q (v.05.16.2018-2)
4
7.2.1.2.4.2.1 Except as specifically described below, when CLEC acts as a Third Party
Transit Provider, alltraffic exchanged between CLEC and CenturyLink wil! be treated as
wireline traffic for billing purposes. CenturyLink and CLEC will not separately identiff
WSP traffic.
7.2.1.2.4.2.1.1 CenturyLink wi!! not pay CLEC any compensation for any
lnterMTA traffic. CenturyLink will bill Third Party Transit Provider for lnterMTA
traffic by using the lnterMTA Factor in Exhibit A which will be calculated against
al! CenturyLink originated MOU routing through the CLEC terminating to a WSP
end user. CenturyLink will bil! CLEC for such traffic at Originating lnterstate
Access Rates out of the CenturyLink Access Tariff. The lnterMTA Factor wil! be
identified on Exhibit A and will stay in place unless either Party conducts a traffic
study of CenturyLink originated traffic routed through the CLEC and terminating
to WSP's. A request to review traffic studies and revise the lnterMTA Factor is
limited to twice ayeat and any change wil! be documented in an amendment.
7.2.1.2.4.3 Compensation for transiting traffic to Transit Customer will not be paid by
CenturyLink to Third Party Transit Provider for CenturyLink end user originated traffic or transit
traffic routed to CenturyLink that CenturyLink sends through the Third Party Transit Provider to
terminate to Transit Customer.
7.2.1.2.4.4. The calculation of the RUF will be modified to include all traffic that is routed on
the Third Party Transit Provider Tandem to Tandem trunk groups to be CLEC's responsibility per
the attached Exhibit H for the Third Party Transit Provider.
7.2.1.2.4.5 When the Third Party Transit Provider utilizes CenturyLink's Tandem Switch for
the exchange of local traffic, where there is a DS1's worth of traffic (512 CCS) between the Third
Party Transit Provider's switch and CenturyLink's Tandem Switch for delivery to and from one (1)
of CenturyLink's End Office Switches, the Third Party Transit Provider shall order a direct trunk
group to CenturyLink's End Office Switch. Upon notice by CenturyLink or anticipation of such
traffic usage levels, the Third Party Transit Provider wi!! order, within 30 days, direct trunk group(s)
to the CenturyLink End Office Switch. Subsequently, unti! the Third Party Transit Provider orders
such direct trunk groups CenturyLink may not process or may reject the Third Party Transit
Provider's orders for new trunk groups or trunk group augments to CenturyLink's tandems. To the
extent that the Third Par$ Transit Provider has established a Collocation arrangement at a
CenturyLink End Office Switch location, and has available capacity, Transit Customer may, at its
sole option, provide two-way direct trunk facilities from that End Office Switch to Third Par$ Transit
Provider's Switch.
7.2.1.2.4.6 This Third Party Transit Provider Amendment does not othennrise modify or
supersede the terms and conditions of any agreement that Third Party Transit Provider may have
with CenturyLink, including tariffs, interconnection and/or access agreements.
7.2.1.2.4.7 This Third Party Transit Provider Amendment does not authorize Third Party
Transit Provider to bi!! CenturyLink on behalf of Transit Customer for any charges associated with
Loca! lnterconnection Services (LlS) interconnection or Type 2 lnterconnection facilities, including,
but not limited to any reciprocal compensation arrangements contained in separate agreements
with CenturyLink.
7.2.1.2.4.8 Third Party Transit Provider will not exchange VNXX traffic with CenturyLink.
May 5, 2021 RjcM/ide Voice/lD/Amend ment to C DS- 1 6091 5-000 1
Third Party Transit Provider Amd-Q (v.05.16.201&2)
5
7.2.1.2.4.9 Third Party Transit Provider wil! pass unaltered signaling information (e.9.,
originating Calling Party Number and destination called pafi number, etc.) pr 47 C.F.R. S
64.1601 and industy standards.
7.2.1.2.4.10 Third Party Transit Provider will be responsible to provide transit records, in EMI
Gategory 1'l-01-)fi format to CenturyLink, if required by CenturyLink.
May 5, 2021/kjc/rAlide Voica/lD/Amendmont to CDS-160S1 5{001
Third Party Transit Provirter Amd-Q (v.05.16.201&2)
6
,nbrEo|Urctotr Facmvffina,.t!lhrft
It ri r lh.ilrta Fdr to*
E'TTA
P.C. I otl
EXHIBIT H
For the Third Party Transit Provider Amendment
Twelve States
(Excludes MN and WA)
Calculation of the Relative Use Factor (RUF)
Minutes that are CenturvLink's responsibilitv (Al:
. All EAS/Loca!251(bX5) Minutes of Use (MOU) that CenturyLink sends to CLELo Al! CenturyLink Exchange Access MOU that CenturyLink sends to CLECo EAS/Local251(bXS) traffic that transits CenturyLink network and is terminated to
CLEC, for which CenturyLink receives compensation from the originating Carrier for
performing the local transiting function. Al! lntraLATA Tolltransit MOU that CenturyLink sends to CLECo All |SP-bound and FX MOU that CLEC sends to CenturyLink. Alljointly Provided Switched Access (unless joint NECA 4 billing percentages have
been filed) that CenturyLink sends to CLEC and that CLEC sends to CenturyLink
Minutes that are CLEG's responsibilitv (B):
. A!! EAS/Loca!251(bX5) MOU that CLEC sends to CenturyLinko All Exchange Access MOU that CLEC sends to CenturyLink. All EAS/Local 251(bxs) traffic that CLEC sends to CenturyLink for termination on
another Carrier's networko Al! lntraLATA Tolltransit MOU that CLEC sends to CenturyLinko Al! EAS/Loca!, lntraMTA, Exchange Access, Local and lntraLATA TollTransit and
lnterMTA MOU that CenturyLink sends to CLEC and CLEC sends to CenturyLink on
the Third Party Transit Provider's Tandem to Tandem trunk groups.
Non- Local Minutes that are CLEG's responsibilitv (C):
o All |SP-bound and VNXX MOU that CenturyLink sends to CLEC. AIIVNXX MOU that transits CenturyLink network and is terminated to CLECo All TollVo!P-PSTN MOU that CLEC sends to CenturyLink
The mathematicalequation for RUF is as follows:
CenturyLink Responsibility: (A) / (A+B+G) Rounded to nearest whole percentage
CLEC Responsibility: (B +C) / (A+B+C) Rounded to nearest whole percentage
Data used for the calculation will be the average of the most recent three (3) months'
usage determined not to be an anomaly.
Exhibit H - CenturyLink Twelve State Template Version
GenturyLink AllStates Except illinnesota and Washington (v.05.{6.20f 8)
,l