Wholesale: Products & Services

Open Product/Process CR PC012009-1 Detail

Description Of Change

Expected Deliverables:

Alternate Port Process to meet industry guidelines flows

Project Meetings

4/15/09 Product/Process CMP Meeting

Mark Coyne-Qwest said that Qwest sent out Level 1 Product notice on 4/1/09 to retract the LNP Port Cancellation process. Mark said that on 4/14/09, Qwest sent an e-mail to the oversight committee requesting that this issue be closed. Mark said that we will be sending a formal notice out to the CLEC Community.

Bonnie Johnson-Integra said that she responded to the e-mail sent that was sent out and indicated that the (4/24/09 Comments to minutes received from Integra) Oversight issue can be closed but they don’t agree with Qwest’s characterization and will be commenting on that. Bonnie said that she noticed that Qwest placed the CR in a deferred status and wanted to know the reasoning behind this status.

Mark Coyne-Qwest said that we wanted to leave it in a deferred status if at some point we wanted re-visit and re-look at those processes.

Liz Balvin-Covad said that she understands Qwest is retracting but they submitted questions on several instances of differing opinions on Qwest’s position. Liz wanted to know if Qwest would be responding to those questions before they defer the CR so they have it on record.

Mark Coyne-Qwest said that we will take a look at those questions and will respond if appropriate.

Susan Lorence-Qwest said that when we retract a notice, we don’t normally provide a response to comments. Susan said that there were extensive comments. Susan said that we can create a document and post it to the oversight issue where we can capture all the comments.

Liz Balvin-Covad said that would work as long as there is a way to reference all comments whether or not they were responded to.

Susan Lorence-Qwest said that we will capture them in a document and post it to the oversight issue.

4/14/09 Response received from Integra

Qwest/Susan,

While Integra may agree the Oversight issue may be closed, Integra does not agree with Qwest’s characterization of events below and will be responding.

Bonnie

Bonnie J. Johnson | Director Carrier Relations bjjohnson@integratelecom.com

4/14/09 Response from Qwest This is in regard to the CMP Oversight Issue related to the proposed LNP port cancellation process and Qwest CR# PC012009-1, Define LNP process for port cancellation by OLSP on behalf of or at the direction of the end user.

On April 1, 2009, Qwest issued Product notice PROD.04.01.09.F.06223.RetractLNPV61 to retract the proposed port cancellation changes with the following explanation: Over the past months, Qwest has worked to implement a port-cancellation process for resellers of Qwest services that supports an end user's right to choose to change their mind and cancel a pending port by working only through the Old/Current Service Provider. As part of its planned process, Qwest incorporated this lawful option which is recognized in the existing NANC LNP Cancellation Flow 9, as posted on the LNPA-WG Web site. Qwest acted in good faith as it prepared to put the process in place, repeatedly answering questions and engaging in open communication to address CLEC concerns via the CMP Process. Rather than continue the industry debate amongst carriers on the issue, Qwest has decided that it will not implement the proposed Port Cancel process at this time and is retracting this proposed LNP PCAT update. It is also Qwest's understanding, through the repeated representations made by the CLEC's, that they currently do not use and do not intend to use a process similar to the one Qwest had proposed.

Qwest believes this CMP Oversight issue is closed.

Susan Lorence Qwest CMP Manager 402 422-4999

- From: Cmp, Escalation [mailto:cmpesc2@qwest.com] Sent: Tuesday, January 20, 2009 3:37 PM To: 'Johnson, Bonnie J.'; Coyne, Mark; 'Quintana,Becky'; 'allendm@att.com'; 'jredman-carter@mcleodusa.com'; 'BrendaBloemke@cable.comcast.com'; 'Carolee Hall'; 'ebalvin@Covad.COM' Cc: Isaacs, Kimberly D.; Wells, Susie; Van Dusen, Janean; Callan, Maureen; Martinez, Denise; 'cmpesc@qwest.com' Subject: Qwest Response to CMP Oversight issue -- ISSUE SUBMISSION Integra;Comcast; AT&T andMcLeod d/b/a PAETEC

While Qwest is not obligated to do so, in order to maintain its current productive working relationship with the parties participating in CMP, Qwest will retract the Level 1 process option that allowed resellers acting as the OLSP to ask Qwest to cancel a port on their behalf at the request of their end user. Qwest will issue a Change Request to work with the CLEC community to address this alternative port process.

As indicated multiple times in response to this issue, the ability of an OLSP to cancel a port at the request of its end user is a longstanding industry established process as documented by the Number Portability Administration Center at the following link http://www.npac.com/cmas/documents.shtml#ProcFlows - specifically the Cancellation Flows for Provisioning Process. Qwest is aware that there is at least one CLEC on the Oversight Committee that has cancelled port requests as the OLSP.

CLECs participating on the CMP Oversight Committee have claimed that there are operational impacts in Qwest’s implementation of this existing industry process flow for resellers; however those CLECs have made no showing that these operational impacts are truly different from those that occurred when the process flows documented in the industry documentation were implemented.

Susan Lorence

Qwest CMP Manager

402 422-4999

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3/25/09 Postponement Request Integra and affiliates ("Integra"), tw telecom inc., McLeodUSA Telecommunications Services, Inc (d/b/a) PAETEC Business Services, XO Communications and Comcast jointly submit this request for postponement of the Qwest initiated changes Qwest sent in its 3/19/09 PROD.03.19.09.F.06186.LNPV61 notice. · The basis for the request for a postponement; The current process that was adopted 12 years ago by the industry for a customer to cancel a pending conversion to a new local service provider (NLSP) is for the customer to contact the NLSP. If the customer contacted the old local service provider (OSLP) then the OLSP would refer them to the NLSP to cancel the change in local service providers.

Qwest is changing that current process that has been accepted industry wide for over 12 years. Qwest asserts its only reason for its proposed process is to be consistent with the cancelation flow contained in the Inter-Service Provider LNP Operations Flow – Narratives (“LNP Flow”).

(See http://www.npac.com/cmas/codocs/NANCOpsFlowNarrativesv3.0.doc).

The LNP Flow was developed in 1997 in the early stages of telecommunications evolution. Also, these flows are not exact reflections of the current Industry cancelation practices governed by Industry Numbering Committee (INC) of the Alliance for Telecommunications Industry Solutions (ATIS) and practiced by all LECs except one CLEC, as purported by Qwest.

Because there has been no change of law or industry practice, CLECs do not agree that a change in process is required at all and that the current process adopted by the industry over 12 years ago meets industry needs and protects the customer from harm. However, even if Qwest had a valid basis for implementing a process based on the current LNP Flow, CLECs do not agree with Qwest’s interpretation of the cancelation LNP Flow or that Qwest’s proposed process accurately reflects the LNP Flow. As a result of discussion in CMP regarding the interpretation of the LNP Flow, Qwest referred CLECs to the LNPA Working Group (“LNPA-WG”), which Qwest asserts as the controlling body for the industry to request clarification and changes to the LNP Flow, even though Qwest and not CLECs, should have gone to the LNPA-WG for clarification and/or changes to the LNP Flow. Any changes to a process that was adopted by the industry, implemented by the industry and has been working well for over 12 years should be proposed, reviewed and approved by the proper governing body prior to implementation. (If Qwest want to make industry changes, they should be approaching the INC and NANC with their proposals.) Qwest should not be dictating changes to industry practices, and thus to NANC and INC, governing bodies. Rather, NANC and INC approved changes to the industry practices should be the basis for which Qwest implements such changes. Furthermore, if the industry collectively had determined another process was reflected in the Flow that was not implemented, and then found it necessary to do so, the industry would have recognized that need and taken action long before now and that change should not be based on a need for Qwest to create a “marketing opportunity” for itself.

Qwest claims it wants to implement this change "to be consistent with the industry flow as reflected in the LNP Flow charts." As described above, the LNP Flow chart on which Qwest bases its proposed process has been in existence since 1997. CLECs believe the current process is already consistent with the industry flow, has been working seamlessly for more than 12 years, and there has not been any incident or complaint justifying a significant process change as Qwest is proposing. Qwest said in the March 18th CMP meeting that the Qwest escalation group (CSIE) was getting calls asking to cancel the pending ports. Even upon query, Qwest did not indicate whether the calls were directly from the customer (in which case Qwest should deal with the OLSP for providing the CSIE contact information) or the OLSP. In any event, CLECs also receive those calls and per the process that has been in place for over 12 years, refer the customer to the NSLP to cancel their pending conversion.

The basis for postponement is to allow NANC, the governing body for the industry practices, to review and consider Qwest’s proposed process, specifically noting the concerns, issues and questions raised by the CLECs regarding the process, and provide clarification to the concerns, issues and questions and determine if the proposed process is appropriate for implementation in the industry.

· The extent of the postponement requested, including the portions of the proposed change to be postponed and length of requested postponement;

Qwest and CLECs have confirmed with the LNPA-WG Co-chair that there are no meeting minutes or members of the team that can verify the intent of the flow narratives so we are left with the LNP Flow language itself. Qwest’s proposed process is in conflict with the “language itself” and Qwest has documented its own interpretation of that language within the processes the CLECs would be bound to follow. Although Qwest should have contacted the LNPA-WG prior to proposing such changes to this process, Qwest imposed on the CLECs the responsibility to contact the LNPA-WG if it wanted to seek alternative interpretation to stop Qwest’s proposed changes. Though the CLECs do not agree with Qwest’s interpretations or position, the current CMP process allows Qwest to implement changes, such as this proposed flow, even if every CLEC objects, which is the case. Because CLEC’s concerns about the impact to the customer, to CLECs systems and processes, and to the industry are so great, the CLECs went to 1) the LNPA-WG to propose changes to the LNP Flow so that it is consistent with the industry flow; and 2) NANC and asked for their review of Qwest’s proposed cancelation flow.

CLECs ask that Qwest postpone or withdraw the implementation of this request and all related requests so that the LNPA and NANC can 1) review the process flow, 2) ensure that the flow, which was developed in 1997, accurately reflects an industry that has evolved over time, and 3) meets the needs of all involved, especially the customer. The LNP Flow has been available to Qwest for over 12 years and Qwest has not opted to implement its interpretation of an optional process until now. Accordingly, based on Qwest’s assertions that there is no pressing reason for the change, there should be no impact to Qwest to forestall the implementation until the above noted requests are completed.

· The harm that the CLEC will suffer if the proposed change is not postponed, including the business impact on the CLEC if the proposed change is not postponed;

If the changes are not postponed: As CLECs have communicated repeatedly to Qwest, the harm to the customer is the primary concern. Despite Qwest’s assertions to the contrary, interruptions in service are more likely, causing confusion and misunderstandings. There are also a variety of legal issues, such as what constitutes proper authority, compliance with Truth-in-Billing rules/regulations, CPNI privacy laws, 3rd Party Interference with a Contract, etc, which disputes will result in excessive costs, delays, and variant results to CLECs. CLEC’s internal processes have not been reviewed, much less updated, to accommodate Qwest’s proposed process, nor do CLECs have enough information or clarity of Qwest’s proposed process to determine the changes that are required for implementation. This is because Qwest’s proposed process does not reflect the flow or address all aspects of the impact of canceling a pending port. Qwest refuses to acknowledge that the port for many CLECs is the final step of larger process that may include equipment and other services.

If the changes are postponed: There should be no negative impacts on the CLECs or customers. Current processes will continue as they have for the last 12 years.

· Whether and how the CLEC alleges that the proposed change violates its interconnection agreement(s) or any applicable commission rules or any applicable law.

Applicable commission rules or applicable laws: As noted above, there are a variety of legal issues which have yet to be netted. Just as Qwest is imposing its interpretation of the flow on CLECs, likewise, Qwest is imposing its legal position regarding interpretation of the law, rules and regulations on CLECs. Consequently, Qwest has not been willing to acknowledge that any legal issues will be impacted, much less attempt to resolve these legal issues prior to implementation of their proposed process. CLECs disagree with Qwest’s interpretations and positions so far. CLECs feel that the proposed process will result in noncompliance or create ambiguity as to what is compliant with state and federal Truth-In-Billing regulations and rules, the CPNI privacy laws, laws regarding 3rd Party Interference with a contract, the Red Flag Rules, etc.

Also, regarding applicable laws and orders, there are still legal questions – and difference of interpretation from Qwest – as to: what constitutes proper authority in Qwest’s proposed process; when and under what circumstances can a LEC contact a customer; who is responsible for what documentation in this proposed process; and when Qwest takes control over CLEC’s LSR, who is accountable for the negative impacts, such a interruption of service, misunderstandings of financial obligations; cost and cancellation of related orders; and derogatory statements or acknowledgement of Qwest involvement in the process. Some of the answers may be settled by extrapolating language in ICAs or existing rules and orders. However, until the proposed process is detailed, the responsibilities and accountabilities are clearly identified, it is not clear how these will be addressed or what other legal issues may arise.

Violation of the Interconnection Agreement: Qwest repeatedly claims that, based on its interpretation of the ICA, it does not violate the Interconnection Agreements (“ICA”). However, at least one CLEC finds that Qwest has violated several sections of the ICA’s via the CMP process, yet the excessive costs, delays, and variant results issued by the different state entities, makes disputing or challenging Qwest’s actions an untenable solution in many cases. Nonetheless, CLECs do find that this Qwest’s proposed process does violate our ICAs.

Qwest proposed process is a violation of ICAs based on:

· The description and use of the LOA/POA as defined in the ICA.

· The Disclaimer of Agency language

· The CMP process via the Referenced Document language and the Cooperation language of the ICA. (See brief discussion below.)

· The LNP process outlined in the ICA, specifically, Qwest will comply with “the FCC’s rules and regulations and the guidelines of the FCC’s North American Numbering Council’s (NANC) Local Number Portability Administration (LNPA) Working Group and the Industry Numbering Committee (INC) of the Alliance for Telecommunications Industry Solutions (ATIS).” (emphasis added)

· Applicable Intervals, such as 48 hours for cancellation. Implementing a change that is contrary to industry practices without first approaching those changes through the proper governing authority is a violation of the CMP process, and thus a violation of the ICA (i.e., Qwest agrees it will comply with the CMP process in the ICAs). Further, the intent of the CMP process was to be collaborative and provide protection from one party unilaterally imposing changes on the other party. Based on Qwest’s implementation date of April 10, 2009 when it will force their proposed process over the objections of all CLECs, their actions are inconsistent with the intent of the process. Based on some recent commission decisions (i.e., AZ and MN), some state commissions would find Qwest’s actions to be a violation of the ICA as well.

Per the ICA noted above, CLECs, Qwest and the LNPA-WG should review FCC porting order that the flow is based on to ensure any cancelation flow accurately reflects the order. As noted above, inconsistencies do constitute a violation of the ICAs.

Integra and affiliates ("Integra"), tw telecom inc., McLeodUSA Telecommunications Services, Inc (d/b/a) PAETEC Business Services, XO Communications and Comcast

3/18/09 Prod/Proc CMP Meeting

Mark Coyne-Qwest said that this CR announced on 3/6/09 to be effective on 4/10/09. (3/27/09 Comments to minutes received from Integra) Bonnie Johnson- Integra asked if we were going to discuss this CR. Mark Coyne-Qwest asked if Integra wanted to discuss it. Bonnie Johnson- Integra said yes Mark Coyne-Qwest said we would discuss it in the oversight review Mark Coyne-Qwest said that we retracted the Level 1 notice and held 4 adhoc meetings to respond to concerns. Mark said that we have made some minor changes and that the notification was sent on 3/6/09 with an implementation date of 4/10/09.

Julia Redman-Carter –PAETEC said (3/27/09 Comments to minutes received from PAETEC) that implementation of this process is premature that every CLEC has objected and voiced their concerns to the proposed process in every adhoc meeting. Qwest’s position is they have answered all questions. She said they don’t agree that the questions have been answered and answering questions to Qwest’s satisfaction does not equate to a collaborative process. This CMP process regarding Qwest’s proposed process has not been a collaborative effort. Julia said that she wanted to make a formal request (3/27/09 Comments to minutes received from Integra) to delay implementation of the proposed process and to work collaboratively with the CLECs goal for a process that works for all of us. She said that the proposed process doesn’t accommodate or address CLECs concerns and the meetings so far have not helped us to reach any kind of consensus or real evidence that this a collaborative process. Julia said that she would like to delay implementation of the proposed process and continue with the adhoc meetings.

Brenda Bloemke-Comcast said that she agreed with PAETEC and that no CLEC has agreed with this process.

Mark Coyne-Qwest said that the Industry process is out there and that we have the ability to use the process.

Bonnie Johnson-Integra said that (3/27/09 Comments to minutes received from Integra) the current process has been working for 11 years and the document has been out there since 1997. Bonnie said that the Industry has evolved and to try and apply that process may not be appropriate to the impacts that may not have been anticipated back then. Bonnie said that Qwest should have gone back to the LNPA working group and have started that process with the LNPA working group to have the flow reviewed. She said that they would like to work through the process and ask Qwest to do that collaboratively before this is implemented. Bonnie said that Qwest indicated that their process is reflected is this industry document and they disagree. Bonnie said that they want Qwest to retract the level 3 notice and work through the flow with the LNPA working group.

Liz Balvin-Covad said that they don’t believe this has been a collaborative effort and that every party except Qwest disagrees with this process. She said that this has been available for 11 years and now Qwest has decided to take advantage. Liz said that the OBF guidelines are there to support every ILEC. She said that at the time, Qwest’s interpretation was that of the industry. She said that there is too much at stake with the end user being out of service with a timeline they can’t handle and with no experience on what’s going to happen. She said that they can’t support a 4 hour jeopardy window and whose LOA is appropriate and is concerned with the slamming rules. Liz said that the end user calling multiple parties could cause fraudulent activity. She said this needs to a collaborative effort and that this was a unilateral decision made by Qwest.

Mark Coyne-Qwest said Qwest has made an effort to work collaboratively and has made changes to the process. Mark said that this is an 11 year old process and if changes are made in the LNPA working group discussions, Qwest will consider further changes.

Bonnie Johnson-Integra said that this process is not consistent with the flow and is Qwest’s interpretation. She referred to steps 7 and 10 of the NAPC flow and it does not say that Qwest cancel their LSR. Bonnie said that every time they bring this up, Qwest says it is their interpretation and the CLECs don’t agree. Bonnie said that in all the adhoc meetings, the CLECs have expressed concern about this process.

Liz Balvin-Covad asked how Qwest can live with themselves.

Mark Coyne-Qwest said that there are other companies that are doing this.

Julia Redman-Carter-PAETEC said that (3/27/09 Comments to minutes received from PAETEC) Qwest stated there was only one CLEC that has applied this process.

Mark Coyne-Qwest said that (3/27/09 Comments to minutes received from PAETEC) he stands corrected and there is only one CLEC.

Julia Redman-Carter-PAETEC said that an overstatement like that makes her anxious. She said that there are 6 active vocal CLECs that are all having issues with this process. Julia said that Qwest is not taking any steps to accommodate the CLECs (3/27/09 Comments to minutes received from PAETEC) concerns that are using a successful current industry process and this has not a collaborative effort. Julia said that rather it seems like Qwest is saying “it’s my way and too bad”.

Mark Coyne-Qwest said that what Qwest is trying to do with the question raised by the CLEC is to take them it back to the LNPA working group to get a better understanding. Mark said that we conveyed clarification from the LNPA working group Co Chair, Gary Sacra.

Bonnie Johnson-Integra said that she (3/27/09 Comments to minutes received from Integra) talked to Gary Sacra and sent an e-mail about that conversation and that Gary said that was his opinion.

Susan Lorence-Qwest said that she does not see where we have not collaborated on this process. Susan said that we have made changes to the process, provided documentation and cites on issues where the CLECs have disagreed. Susan said that we provided written responses to outstanding issues and that we have not received one e-mail in response that the CLECs disagreed.

Liz Balvin-Covad said that Covad asked specifically where in the flow the requirement to issue a supplement order is not equal to that of jeopardy. Liz said that Qwest responded but not adequately by saying that the jeopardy notice was not part of the step.

Bonnie Johnson-Integra said that flow 2 is meant to apply to the OLSP/NLSP and not another service provider who is not Qwest (see step 2 of the NANC flow) and that it means if a customer coming to them to cancel, the OLSP should be contacting them. Bonnie said that this is the problem and believes there is so much disagreement on the interpretation is why we need to work together to get clarification. She said that interpretations vary and that the Co Chair (Gary Sacra) said that it was done in 1997 and there are no meeting minutes to sort it out and nobody left to ask. She said that since there are major disagreements, Qwest and the CLECs need to work together to protect the end user.

Liz Balvin-Covad said that the parties that wanted this process may have provided a different flavor of interpretation. She reiterated that all CLECs have given reasons why they disagree and this is not a collaborative effort.

Susan Lorence-Qwest said that the working group forum takes time and asked if the CLECs were asking Qwest to put this on hold.

Bonnie Johnson-Integra said that we need Qwest and the CLECs to go back with the concern about the interpretation that Jan Doell provided from Gary Sacra. She said that she did not get the same answer from Gary and then Qwest said that they wanted to take Gary out of the picture and that she does not feel good about this process.

Susan Lorence-Qwest said that we have responded to the questions put forth and have provided multiple cites associated with the interpretation from Jan Doell. Susan said that if there are specific points you think are outstanding you need to let us know and we will provide a response in writing. Susan said that Qwest feels that we have provided a response to all points.

Julia Redman-Carter-PAETEC said that Qwest (3/27/09 Comments to minutes received from PAETEC) apparently thinks the issues are resolved because Qwest has answered the questions to their satisfaction. Julia said that they disagree with Qwest’s position that it is not appropriate to delay the process in light of how long it may take going through the LNPA working group. However, Qwest has been using this current process for 11 years. It should not be a big deal to delay it until the LNPA Working Group has done its review. CLECs are asking Qwest, rather than rushing in and implementing immediately, to slow down and get it right for everyone and the industry. She asked what has happened that Qwest needs to implement this process now over the objections of all CLECs. Julia said that just complying with something that has never been implemented is not a good enough answer. Also, having to relist CLECs concerns because the answers received from Qwest were not adequate uses my time and resources and doesn’t seem to be getting me to where we want to get go Julia said that they need to engage in a collaborative effort to make this process work but we can’t do that in the abbreviated timeframe that Qwest is imposing without understanding all the facts and expectations.

Brenda Bloemke-Comcast said that she was not sure if the LNPA working group would take months to resolve.

Susan Lorence-Qwest reiterated that Qwest has provided documentation that supports our position and no CLEC has disagreed. (3/27/09 Comments to minutes received from PAETEC) She said that she was shocked to discover that there were still open issues.

Julia Redman-Carter-PAETEC said (3/27/09 Comments to minutes received from PAETEC) she didn’t realize that Qwest did not hear the objections, but the CLECs have continually voiced our objections at all the meetings. The CLECs requested and wanted to opt out of this “optional” process and Qwest then said that they can’t because it is not optional. CLECs have voiced objections, concerns, disagreement and/or our desire to opt out of this process at every meeting. Julia said that on every call there have been objections by the CLECs and she is surprised that Qwest didn’t know there are objections to the process. She did not know what more she needed to do to convey the concerns so to get the message through to Qwest. With that said, PAETEC is saying now, for the record, that we have serious concerns with and object to the implementation of Qwest’s proposed process.

Susan Lorence-Qwest said that we understand there were objections and in the last call we provided the reasons and rationale as to why we were moving forward with the process. Susan said that no one disagreed nor challenged the documentation we sent out. Susan said Qwest heard the objections and in the last call agreed to send the information out via e-mail and not one CLEC responded requesting an adhoc meeting.

Julia Redman-Carter-PAETEC said that in the last call we ran out of time and didn’t get through agenda. Julia said that Qwest said that they would get the responses out and move (3/27/09 Comments to minutes received from PAETEC) on. She said that she didn’t understand or didn’t assume that meant moving forward with implementation. So, She said that she is responding now stating that PAETEC does have a concern with and objects to the proposed process.

Liz Balvin-Covad said that Qwest is going to get these comments and then what happens. Liz said that the volumes for this process are not significant. She said that even with the comments it will be the same and Qwest won’t do anything about this. She said that Qwest will say that they have the ability to do this and will get the process in place.

Mark Coyne-Qwest said that when we get the responses to comments we will get with our SMEs and legal team He said that it is a marketing opportunity (3/27/09 Comments to minutes received from Integra and PAETEC to delete the words in CAPS in this paragraph) FOR THE COMPANY WHO IS THE OLSP. Mark said that the volumes may not be large but it is a marketing opportunity. Mark Coyne said that this can only be initiated by the end user.

Bonnie Johnson-Integra asked why it is a marketing opportunity if the customer is contacting the NLSP to initiate the cancellation. She said it shouldn’t be any different because if the customer wants to cancel they can cancel. Bonnie said that she did not understand why this is a market opportunity and does this mean you are going to have more cancellations using this process.

Mark Coyne-Qwest said that we turn the customer back to the NLSP.

Mindy Chapman-Neustar asked what is the impetus for putting this in now.

Susie Wells-Qwest said that (3/27/09 Comments to minutes received from PAETEC to delete the words in bold in this paragraph) Qwest is seeing more customers that belong to our resellers or Qwest retail calling in and requesting to cancel or take care of their request because they don’t want to port. Susie said that, in the past, we have turned them away. Susie said we discovered that this process has been there for 11 years. She said when it was brought to our attention and we thought it would be a good thing for our end user customer. She said this process gives the customer the opportunity to contact whoever they want and we were trying to help the reseller and the end user to make that choice. She said that was part of the impetus and as long as the opportunity was there we took advantage of it on behalf of the end user.

Joyce Bilow-PAETEC asked (3/27/09 Comments to minutes received from PAETEC) at what point is the LOA obtained by Qwest if the LSR is already in the pipeline? How would Qwest get the LOA when the customer calls in. Joyce stated that the LOA should never be obtained by Qwest to cancel the order when the port is two days away.

Liz Balvin-Covad said that they are looking at a 3 day interval from the time Qwest gets that request. Liz said that when the end user calls the NLSP to request their service, they could have called Qwest in the next 2-3 days to stop the port. Liz said that the end user calls Qwest and that is the issue with the LOA because it could possibly be on the same day. She said that there could possible slamming activities since the end user could say Qwest took me back and they really did not mean that. She said that they would take it up with the Commission and say that they have the LOA and had authorization from the end user. She said that it becomes a risk without the date and time stamp.

Susie Wells-Qwest said that the documented process is around who has the most current POA/LOA on behalf of Wholesale She said that if the reseller calls in or sends e-mail to the CSIE with a port request and based on the LOA/POA process today, we are assuming that the CLEC has POA/LOA from that end user. Susie said that this is based is on the customer contacting the CSIE having some POA from current end user.

Julia Redman-Carter-PAETEC said that (3/27/09 Comments to minutes received from PAETEC) the CLECs have issues with the timing associated with processing the LOA and would like to see the LOA within a timeframe that they can work with. Julia said that they asked for a copy of that LOA within the 4 hour window so they could respond appropriately. They wanted to check who made the authorization for what with the date and time stamp. She said that Qwest is saying that we can file a dispute after the fact, request the LOA and in 3 days Qwest will give us the LOA. She said by that time the damage is done. She said that Qwest’s response is not acceptable for the CLECs. She said that Qwest is the 3rd party in the middle of this and they are not the OLSP or NLSP. We are also concerned about lag time.

Bonnie Johnson-Integra said that we have had this discussion 6 times and it is getting us nowhere. She said that they don’t agree with Qwest’s interpretation and because of CMP process, Qwest has the ability to implement this over their objections. Bonnie said that Qwest will provide the same response that they are going to unilaterally implement over our objections. Bonnie said that Qwest hasn’t had this proposed process for 11 years and if you are receiving calls from the customers, Qwest should be talking to the people who are giving them the number and said that is a different issue. Bonnie requested that the notice be retracted and that we work with the LNP working group to get the interpretation and get the flow revised. She said that have been so many changes in 12 years to systems, processes and business in the industry that the flow doesn’t accurately reflect where are at today. Bonnie said that you haven’t used it for 12 years what is a few more months.

Mark Coyne-Qwest said that (3/27/09 Comments to minutes received from Integra) the CLECs can ask for to retract in the comments we will take a look at the comments and work with the SMEs and Legal and see what we can do. Mark said that we will respond to comments.

Susan Lorence-Qwest said that Qwest will provide the cites that Jan Doell (Qwest) provided if asked if the CLECs disagree with any of the areas to explain why as part of the comment.

Bonnie Johnson-Integra asked if Qwest could extend the comment cycle by a few days.

Mark Coyne-Qwest said that we will extend the comment cycle until next Wednesday, March 25th.

3/2/09 E-mail from Integra Qwest,

Please post this email to CR PC012009-1. We intend to discuss this item in the next CMP ad hoc call that Qwest scheduled for March 2nd (today) as well.

Qwest and many CLECs disagree about what type of authority was intended in step 7 of the cancelation process flow (page 23 of 35 of the LNP flow at http://www.npac.com/cmas/codocs/NANCOpsFlowNarrativesv3.0.doc). In an effort to get clarification on the LNPA's intent of step 7, Qwest said it spoke with Gary Sacra, the LNPA-WG Co-Chair. The minutes from the February 11th, 2009 Change Management Process (CMP) meeting state:

“Denise said that Qwest contacted the LNPA-WG Co-Chair for the clarification and the intent of Step 7 in NANC LNP Process Flows, Cancellation Figure 9. She said that the LNPA-WG Co-Chair says the authority indicated in this Step 7 should be the same type of acceptable authority that is required in the very beginning of the flows where the NLSP obtains authority from the end user to port their number. The beginning LNP Process Flow Main Flow, Figure 1, Step 3, says, “NLSP obtains authority (Letter of Authorization - LOA) from end-user to act as the official agent on behalf of the end-user. The NLSP is responsible for demonstrating necessary authority.” Denise said that Qwest supports the NANC LNP Process Flows.”

“Bonnie Johnson-Integra asked who Qwest talked to for their interpretation.”

“Denise Martinez-Qwest said that they talked with Gary Sacra from Verizon. He is the working committee’s Co-Chair.”

On Tuesday February 24th, 2009, I spoke directly to Gary Sacra, the LNPA-WG Co-Chair from Verizon. When I told him Qwest told CLECs in CMP that he said the authorization in step 7 of the cancelation was an LOA (see excerpts of meeting minutes above), he told me that is not what he said.

I asked Gary if he was present during discussions regarding step 7 of the cancelation flow when the language was developed. Gary told me that said he was not involved in the discussions when the language was crafted and said it was only his personal opinion that it was, or could be, an LOA. I asked Gary if there were any meeting minutes when step 7 of the LNP cancelation flow was discussed when the language was developed. Gary said there were none, as this dated back to 1997. Gary told me that he was involved in the development of Version 2.0 and Version 3.0 of the flow, and no conversation took place regarding step 7 of the cancelation flow. Gary also said that he understands how the difference in wording could lead to a dispute. Gary agreed that, because there is no documentation or meeting minutes to reference, all we are left with is what the document says.

Action Required:

Qwest based its refusal to remove its own interpretation of step 7 of the LNP cancelation flow (that the authority is an LOA) and denied Integra’s request to add the actual language in step 7 of the cancelation flow because “…the LNPA-WG Co-Chair says the authority indicated in this Step 7 should be the same type of acceptable authority that is required in the very beginning of the flows where the NLSP obtains authority from the end user to port their number.” Based on my conversation with Gary Sacra, that is incorrect. Therefore, Qwest has provided no basis for its position.

It is apparent that there is no resource (meeting minutes or attendees) that can shed light on what the LNPA intended when it developed language for step 7 of the cancelation process. In any event, it is not the alleged intent but the language of the document that controls. The document does not say the authority is an LOA. Therefore, it is inappropriate for Qwest to force its interpretation on CLECs, when Qwest knows the CLECs do not agree and any Qwest implementation would be over CLEC objection. Qwest should use in its documentation the actual language from the LNP process flow which states: “The OLSP obtains ‘actual authority’ from the end-user to act as the official agent on behalf of the end-user to cancel the porting request

2/20/09 Adhoc Meeting CMP Ad Hoc Meeting Minutes Change Request # PC012009-1 February 20, 2009

Attendees: Bonnie Johnson-Integra, Kim Isaacs-Integra, Kasha Faucett-Comcast, Jen Aspeslagh-Comcast, Liz Balvin-Covad, Nora Torrez-tw telecom, Susie Franke-tw telecom, Jason Lee-Verizon Business, Julia Redman-Carter-McLeod (PAETEC), Joyce Bilow-McLeod (PAETEC), Mindy Chapman-Neustar, Crystal Hanus-GVNW, Ann Vick-GVNW, Maureen Callan-Qwest, Susie Wells-Qwest, Linda Miles-Qwest, Janean Van Dusen-Qwest, Denise Martinez-Qwest, Ellen Munz-Qwest, Mark Coyne-Qwest, Susan Lorence-Qwest, Lynn Stecklein-Qwest

Nora Torrez-tw telecom said that she wanted to know who was on the call from Qwest.

Susan Lorence-Qwest said that we have representatives from Process, Documentation, Product and CMP. She said that the agenda and updated process were posted to the Wholesale calendar. She said that following the last our Qwest SMEs reviewed our proposed process with the LNP working group to ensure that we were in line with the LNP operational flows. She said that our representative could not be on the call today but did agree that we were in line with the flow.

Bonnie Johnson-Integra asked who that representative was.

Susan Lorence-Qwest said that her name is Jan Doell from Qwest.

Nora Torrez-tw telecom asked who Jan Doell confirmed with.

Susan Lorence-Qwest said that Qwest SME team confirmed with her.

Nora Torrez-tw telecom said that this is her interpretation of the flow.

Susan Lorence-Qwest said that was correct.

Nora Torrez-tw telecom said that she wanted to confirm that Qwest checked with a Qwest representative to interpret the rules around this process and it wasn’t an oversight person.

Susan Lorence-Qwest said that if there is a question or concern about the interpretation of the flow, Qwest is requesting that it be sent in writing and asked that them include any supporting cites She said that Jan Doell is willing to take back any concerns to the working group and that the CLECs are welcome to take any concerns to their LNP working group representative.

Susie Wells-Qwest said that we want to revisit and clarify the use of the term Optional Process. She feels that the use of term optional may have been misunderstood. She said that Qwest is updating the proposed language in the PCAT to reflect that this is simply the process for the OLSP to cancel a port request for the end user. Susie said that this process is intended to be a process the OLSP can use if the end user comes to them and they choose to follow the process. Susie said that Qwest is following the Industry Standard defined by the LNP working group and Qwest is in support of the industry standard. Susie said this process allows the End user authority to make the decision to contact the NLSP or the OLSP and is an alternative process for the OLSP to use. She said that the OLSP can choose to send the end user back to the NLSP or choose to follow the process we are proposing to document. Susie said that the process is not optional for the NLSP and they can’t opt out.

Nora Torrez-tw telecom said that they have a problem with not be able to opt out and that we are back to square 1. Nora said that Qwest went back and rethought their process. Nora said that when you look at the Industry flows it does not go into the alternative/ optional proposal of cancelling the LSR. She said that is a collaborative decision for the providers in the Industry to make sure we are caring for our business and customers.

Maureen Callan-Qwest said what Susie is referring to is the cancel flow figure 9. She said that if the end user contacts the NLSP or the OLSP, it defines the process depending on which service provider, the end user contacts. She said that if the OLSP is contacted, and the steps are followed, it does not give the NLSP the opportunity to not participate. She said that whether they choose to respond or not, there is still a result that impacts the NLSP.

Susan Lorence-Qwest said that we want to clarify that Qwest did not rethink the process. Susan said we wanted to clarify the wording because the term optional was throwing everyone off. Susan said that this is an alternative to cancel the port request that was not there previously. She said we are providing that based on the Industry Flow and is the same process proposed in November.

Nora Torrez-tw telecom said that she did not understand why the current porting process (when you are contacted by the end user to cancel the port and you refer them to the NLSP to cancel the port) isn’t working. She said that she does not understand why Qwest wants to invest money and time to change to an alternate solution and asked what the business reason was.

Maureen Callan-Qwest said that Qwest wants to have a clear connection between the cancel flow and our process.

Nora Torrez-tw telecom said that from their perspective the current process in place today has been working and working efficiently and cares for both sides of the business. She said that she wanted clarification why Qwest made a business to change to an alternate flow.

Maureen Callan-Qwest said that the current process flow says that the end user can contact the NLSP or the OLSP and that wasn’t being offered to the end user. She said that we wanted make the connection that the end user has a choice.

Nora Torrez-tw telecom said that statement was disconnected. She said that that today if a customer says they want to port to Tw telecom they issue a porting order to notify you they want to come to tw telecom. Nora said that if the customer decides they don’t want to port after all, they contact Qwest and Qwest will tell the customer to call tw telecom. Nora said that this process is working. She asked what changed with Qwest that they now want to take this to the next level in the port process by sending them a cancellation and said that she did not understand the motivation.

Maureen Callan-Qwest said it is not a matter of motivation and that if the end user is allowed to call the OLSP, we need to be able to support that.

Liz Balvin-Covad said that the process already provides the ability for the end user to cancel the port.

Maureen Callan-Qwest said that this is an alternative to that.

Bonnie Johnson-Integra (3/2/09 Comments to minutes received from Integra) asked if the question Nora for tw was trying to ask is what is broken that Qwest is trying to fix and asked what triggered Qwest believing that there was a need to do this.

Nora Torrez-tw telecom said that is sounds like a retention issue.

Maureen Callan-Qwest said that the flows state that the end user can call the OLSP and ask them to cancel. Maureen said we did not have that process defined and shared with the customer. Nora Torrez-tw telecom said that if the process were to be put in place, will they be able to call the customer when Qwest sends the cancellation. Maureen Callan-Qwest said that is not the purpose of this.

Nora Torrez-Tw telecom said that they have a contract with the customer and if they call the customer is Qwest going to take issue with that.

Maureen Callan-Qwest said that is not covered in the cancellation flow. She said that the flow says that the end user can make the decision to cancel.

Nora Torrez-Tw telecom said that Qwest needs to understand that they have a contract with the customer.

Maureen Callan-Qwest said that we can’t comment on their business.

Liz Balvin-Covad said that in order for them to issue the order to Qwest they have to have the LOA in place. Liz said that if there is a contract in place with them do they have the ability to contact them if Qwest intervenes.

Maureen Callan-Qwest said that she did not think that a contract and the LOA are the same thing.

Susan Lorence-Qwest said that we are rehashing items that were discussed in the last call. Susan said that we were clear and confirmed with the LNP co chair that the LOA that anyone gets in this process has to be the most current. Susan said that whoever is being contacted by the end user customer is working of the end users authority.

Julia Redman-Carter-McLeod said they want clarification from what they were told in the 1st meeting when they asked if they could contact the customer if they received this jeopardy code. Julia said Qwest said yes, you can call the customer. Julia said in a subsequent meeting Qwest said they can’t call the customer because that is a violation. She said that she has received different answers from Qwest on how they are to resolve the issue (2/27/09 Comments to minutes received from McLeod) or what is the next step. She said that one of the reasons they would need to call the customer is because they have contract with them but at the same time we don’t interfere with the last LOA, if it is yours. Julia asked how do they resolve their contract if they can’t call the customer. Julia said that she wants a clear definitive answer on whether they can call them or not under what situations and when. That should be part of the process.

Denise Martinez-Qwest said that she spoke to this on the last call and advised that we did have discussions with our attorneys and that based on the FCCs Brighthouse and Verizon opinion, that was just affirmed, no one should be contacting an end user to retain them triggered by the information we are sending.

Julia Redman-Carter-McLeod said that based on (2/27/09 Comments to minutes received from McLeod) Denise’s response, they would not be able to contact customer. Julia said that she wants to get the question on record that when they receive the jeopardy what are they supposed to do. It’s not in the process.

Susan Lorence-Qwest said that we confirmed that after review with our attorneys and it was discussed in the 1st meeting. Susan said that we will discuss that question in our agenda today.

Bonnie Johnson-Integra said that (3/2/09 Comments to minutes received from Integra) first she wanted to comment on the optional process and the NLSP not being able to opt out. Bonnie said that it is clear that Qwest now recognizes that a Level 1 can’t have an operational impact. She said that Qwest understands whether optional or not, this does have an impact to the NLSP. Bonnie asked where in the in the cancellation flow does it say that Qwest does anything with their LSR. Bonnie said that she was looking at the document flow narrative or at the flow diagram and asked Qwest to point her to where it says that Qwest can reject the NLSP LSR. Maureen Callan-Qwest said that the cancellation flow doesn’t talk about the actual flow or notification, it just says you notify. She said step 2 says that the NLSP or OLSP whoever gets the end user notification gathers the information and sends it to the other party and so it is not going to talk about the LSR.

Bonnie Johnson-Integra said that in step 2, the OLSP can initiate this request and the 2nd bullet says that the contacted service provider gathers information for sending the supp request to the other service provider noting cancellation and sending the cancellation request to NPAC. She asked if that was where Qwest is basing their authority to send jeopardy. She said that the non fatal jeopardy error is a step that Qwest takes so the CLEC to take action to clear that non fatal jeopardy. Bonnie said that this step has no meaning to this process because there is no action they can take. Bonnie said that Qwest said they can’t go from the FOCd LSR to a reject and that Qwest needs to have that step in between. Bonnie said that the non fatal jeopardy step is meaningless because there is no action they can take and that the LSR in the 2nd bullet in step 2 when activity is related to the LSR.

Maureen Callan-Qwest said that the jeopardy is how we notify when the end user cancels. She said the jeopardy is the vehicle for how that happens.

Bonnie Johnson-Integra said that in flow #10, the OLSP in this case would be Qwest. Bonnie said that she doesn’t see where it says that the LSR is rejected and asked where that was in the flow.

Maureen Callan-Qwest said that in flow #2, is where we use the tool and where it is defined.

Bonnie Johnson-Integra said that in steps 9 & 10 it talks about the NLSP notifies the OLSP via their intercompany interface. Bonnie asked if Qwest interprets the intercompany interface to be the e-mail that is sent to the CSIE and said it sounds like a system (3/2/09 Comments to minutes received from Integra) not an e-mail.

Maureen Callan-Qwest said that bullet says that the OLSP contacted by the end user or notified by the NLSP via the intercompany interface. Maureen said that intercompany is between 2 companies and not intracompany.

Janean Van Dusen-Qwest said that the CSIE is the intercompany interface for all CLEC calls, e-mails or when the go thru the self service portal.

Susan Lorence-Qwest asked if they were questioning the step or the process. Susan said that step 9 is the internal process and that the details of this flow are not discussed there. Susan questioned why we are getting to this detail because this is a reject notice or cancel etc. She asked what the CLECs were questioning and what is the issue.

Bonnie Johnson-Integra said they want to compare this flow to the process and that they have a right to ask questions about this process. Bonnie said they want to know about the intercompany interface. She said she does not agree that the details of this flow are not discussed because when you look at the flow it is pretty specific. Bonnie said they want to know how Qwest is interpreting this and want to put that step to the process. She said that in your process it says that you contact the CSIE and she wants to know if that is step 9.

Susie Wells-Qwest said that the answer to Integra’s question is yes. She said that we are relating the process to step 9 and is the intercompany interface that we have chosen to use to allow the OLSP to cancel the request.

Maureen Callan-Qwest said that we want to review steps 2, 9 & 10 and are there any questions in step 10.

Julia Redman-Carter-Mcleod said that (2/27/09 Comments to minutes received from McLeod) per step 10 it states that the jeopardy is Qwest’s proposed form of a cancellation message. She said that to clarify this 1st bullet says that the OLSP contacted by the end user notified by the NNSP via the intercompany interface sends a cancellation message to the OLSP via their intercompany interface and asked if that is the CSIE.

Susie Wells-Qwest said that was correct.

Janean Van Dusen-Qwest said that we are going to change the process to cancel the port request in the flow and we have taken out the word optional to eliminate confusion. Janean said it will read: In a porting situation, the end-user may contact either the New Local Service Provider (NLSP) or Old Local Service Provider (OLSP) to cancel the porting request. If the end user decides not to complete the port and contacts the OLSP to cancel an existing LNP or Loop with NP request to port to a NLSP, the following process applies.

Janean said that instead of stating NLP provider in the Qwest will create a CSIE ticket section we changed that to NLSP for clarification. She said that in the 4 hour business jeopardy window, Qwest has also changed NLP to say NLSP and we have added after being contacted by the end user and added the link to the ordering PCAT for clarifying information.

Julia Redman-Carter-McLeod referred to the paragraph that states: If the NLSP does not respond within the 4 hours, the port orders will be cancelled and the LSR will be rejected using the reject code of 814. She asked what she is supposed to do in the 4 hours.

Denise Martinez-Qwest said that they don’t need to do anything in those 4 hours. She said that today when we send these notifications and is documented in the Ordering Overview that if we do get a response and it is something we can act on, we can send the FOC. She said that if we don’t get anything, we cancel the existing order and send the reject notification. Denise said that based on discussions from our last call, she pulled a days worth of these type of jeopardy codes. She said that we had a variety of CLECs, and regardless of the reason we sent the jeopardy’s none of those jeopardy notices were responded to. She said that after the 4 hour period we did exactly what the process calls for and cancelled the service orders and sent reject notifications at that point in time.

Bonnie Johnson-Integra said regardless of whether any CLEC responded or not there may have been some type of action that could have been taken to respond to that non fatal jeopardy. She said that in this case it is a moot point because there is no action they can take or respond. She said that it is a process in the middle because Qwest is indicated that they can’t contact the customer. She said that they would have to wait for the 4 hours because there is nothing they can respond to. Bonnie said that she wanted to make her point that a non fatal jeopardy are design and that the CLEC may be able to take some type of action and respond to that non fatal jeopardy and it appears this is not the case.

Denise Martinez-Qwest said that this could be for non fatal or fatal is specifically designated in a note in the matrix in the Ordering Overview. She said some of the examples she looked at were definitely fatal. Denise said that one example was for a request for LNP to port the number out. At the time it was processed, we sent an FOC. She did say that there was a timing issue and the comment that was sent back was that the customer had already placed an LNP order with a conflicting date. Denise said that request conflicted with the request that had been sent. Denise said that we had several duplicate requests from the same company. She said these are things that are non fatal where we can’t process a secondary request for the same type of request that is being asked for. She said that another example was for a TN that had been disconnected. That is a fatal because there is nothing that can be done once the number has been disconnected.

Joyce Bilow-McLeod said if there is a pending order they will receive a reject that will tell them that there is a pending order that exists and that we are unable to port at this time.

Denise Martinez-Qwest said that when we put this jeopardy notification procedure in place, it was due to the fact that once we sent the FOC and needed to send additional information, whether it be fatal or non fatal, the CLEC systems couldn’t accept a reject or an error notice. She said that the notice your system could accept was the jeopardy notice. Denise said that she has issued a system CR SCR021809-1 that will be presented in the March CMP and it will be included in the prioritization for IMA 26.0. She said that we hope this will help because rather than receiving a jeopardy, you will be receiving a cancellation notice that the end user has cancelled the request.

Julia Redman-Carter-McLeod said that the jeopardy notification we are using today, (2/27/09 Comments to minutes received from McLeod) Qwest is claiming it is a catchall for anything that comes thru.

Denise Martinez-Qwest said that was correct and that it is for any fatal or non fatal condition identified after the FOC is sent.

Julia Redman-Carter-McLeod said that your flow says that if the NLSP does not respond in 4 hours they should be able to respond. She said now Qwest is telling them they can’t respond and that the flow is not accurate.

Denise Martinez-Qwest said that if within the 4 hour period, your end user contacted you pro-actively, you would have the opportunity to try and change their mind. Denise said that you would get the LOA and respond back to us by Supping your request.

Julia Redman-Carter-McLeod said that they have a 4 hour window but that can’t do anything unless everything (2/27/09 Comments to minutes received from McLeod) happens to falls into place.

Denise Martinez-Qwest said that the end user has started this entire process and we are reacting just as you are.

Nora Torrez-tw telecom said that when a customer calls Qwest to tell them they want to cancel a port and they have to get a signed LOA that means there should be a 24 hour delay. She said that from their perspective as a CLEC Community they are going to have to request a written copy of the LOA in all of these situations if this process goes forward.

Maureen Callan-Qwest said the process that has been agreed to is that the companies that have the LOA would produce it and if you (2/27/09 Comments to minutes received from McLeod) raised a dispute.

Julia Redman-Carter-McLeod said that the LOA is not automatically provided in the process (2/27/09 Comments to minutes received from McLeod) we currently have today. But in the process that Qwest is proposing, the CLECs want the LOA automatically provided in this situation.

Maureen Callan-Qwest said that it is a broader issue and that we have agreements that say if there is an LOA.

Nora Torrez-tw telecom said that we have an agreement that we would not use an alternate.

Maureen Callan-Qwest said that she was not aware of any agreement.

Julia Redman-Carter-McLeod said that our processes never allowed for (2/27/09 Comments to minutes received from McLeod) stacking LOAs with different providers, so we agreed that we would not have to provide the LOA each time. Julia said, however, they would like to see the LOA be produced each time, including a date and time in this situation because of the cancellation by another provider.

Maureen Callan-Qwest said that would not be acceptable and would be out of line with the acceptance of the company of the service provider who has the LOA. Maureen said it is not required to be presented on a regular basis.

Nora Torrez-tw telecom said that they are disputing this and is the purpose of these calls. Nora said the CLEC community is disputing this process and that there are huge flaws in it. Nora said that they have agreements and there is a current process that works and is not broken.

Maureen Callan-Qwest said that this proposed process matches the Industry flow process and we aren’t talking about concerns with LOA that are defined. She said that we haven’t agreed to not have a process that supports the Industry flow.

Bonnie Johnson-Integra said she wanted to talk to the point in the process about producing actual authority from the end user to cancel the porting request. She said Qwest has indicated that they don’t do this now for regular LSRs. Bonnie said that on page 3, step 3 and page 23, step 7 it says the NLSP is responsible for demonstrating authority and one says that the OLSP is responsible for such authority as necessary. She said that they don’t believe that step 3, page 3 is necessary (3/2/09 Comments to minutes received from Integra) but it is not for a cancellation.

Maureen Callan-Qwest said that that changes to the LOA flow is not on the table for this CR.

Julia Redman-Carter-McLeod said that (2/27/09 Comments to minutes received from McLeod) but page 23 step 7 which is the options process, is on the table for this CR. It appears that Qwest wants to mirror the flows when it suits them, but is not as flexible when the CLECs want to do the same in a different place in the flow.

Susan Lorence-Qwest said that we talked about this in the last meeting and that we received confirmation from the LNP co chair that the LOA /POA process was sufficient and that the current process is defined. Susan said that whatever process you have in place today is between you and your end user.

Kim Isaacs-Integra said that the arrangement that tw telecom is talking about is the arrangement between Qwest and the NLSP. She said that when the NLSP has ordered a special access Loop that supports the number that is porting in, they have to pay the install and early termination charges because they had to disconnect because you have disconnected the porting order. Nora Torrez-tw telecom said that she needed to get to the FCC about this information. She said that she was concerned about slamming, stranded investment and anti-competitive issues. She said that this gets worse instead of better. Julia Redman-Carter-McLeod said they want information/clarification on timing elements on when they send in the port, when they get the FOC and the LOA that cancels it. Susie Wells-Qwest said that process addresses that very issue. She said that the date of cancellation must be received by 2 pm MT one day prior to the port date. Susie said that if the port date is 4 days from today and you send the notification that the end user wants to cancel the port, we would have to have the request into the CSIE no later than 2pm MT the day before the actual port. Susie said that anything outside of that would be considered too late and would be sent back to you. Julia Redman-Carter-McLeod asked if when Qwest says cancellation is that the jeopardy Qwest is sending. Susie Wells-Qwest said that the request has to be in the CSIE by 2pm MT. Julia Redman-Carter-McLeod asked if Qwest is saying that they will send the jeopardy back in 60 seconds. Susie Wells-Qwest said that we will send it as soon as we can. Julia Redman-Carter-McLeod asked when is that last moment they can cancel the port. She said that if she calls at 1:59 to cancel the port, it is before 2:00pm MT. Janean Van Dusen-Qwest said that we would not accept that. Julia Redman-Carter-McLeod said that the cutoff is 2 pm (2/27/09 Comments to minutes received from McLeod) for the cancellation request, but when is the cutoff for Qwest to send the cancel message to the CLECs, that is not the same cutoff time that they can cancel up to. Janean Van Dusen-Qwest said that if we can’t get the cancel out by 3pm MT. Julia Redman-Carter asked if they will take calls until 2pm MT. Janean Van Dusen-Qwest said that we don’t take verbal phone calls. Julia Redman-Carter-McLeod asked if they used the ticket process what would be the last time the NLSP would see that jeopardy notice (2/27/09 Comments to minutes received from McLeod) comes in on a given day. Janean Van Dusen-Qwest said that she did not know when they pull the jeopardy notices so we don’t have an answer for that. She said not after 3pm MT. Julia Redman-Carter-McLeod confirmed that any jeopardy notices sent to cancel the port for the next day would be sent from Qwest no later than 3:00 pm MT prior to the due date. Julia asked for this to be added to the process. Janean Van Dusen-Qwest said that we can add that to the PCAT. Susan Lorence-Qwest said that there are 3 items to take back: 1) the inclusion of some reference or indication of the date and time stamp that the OLSP contacted Qwest Wholesale that they have the current LOA/POA, 2) Question about charges – We don’t believe that this is our issue because it is between you are your end user, 3) the clarification of the timing of the process. Susan said that Qwest will schedule another call to address these points. Bonnie Johnson-Integra said that the ‘SX’ jeopardy code for non design should not be used for this because it is the NLSPs LSR that Qwest is sending a jeopardy for. Susan Lorence-Qwest said that we will take that back and reconfirm. Denise Martinez-Qwest asked if Integra could put something in writing with details regarding their concern. She said that we did address this in a previous meeting but will look at their question again. Liz Balvin-Covad said that if they had concerns about the discrepancies in the NANC flows vs. the Qwest process they were asked to put it in writing. She said that she wants to do a side by side comparison and identify any concerns that Covad may have and talk about it in the next meeting. Susan Lorence-Qwest asked that Covad send their concerns to Qwest. Susan said that we will be inviting the Qwest LNP working group representative to the next call. Susan also requested that those who have representatives in the LNP working group invite, them to the next call.

2/18/09 ProdProcCMP Meeting Mark Coyne-Qwest said that this CR is also included in Attachment E associated with the Oversight issue. He said that Qwest has held several adhoc meetings in the last couple of weeks and have another meeting scheduled on 2/20 to address any remaining questions.

2/12/09 Adhoc Meeting LNP Optional Process Ad Hoc Mtg Change Request # PC012009-1 February 12, 2009

Attendees, Kim Isaacs-Integra, Bonnie Johnson-Integra, Laurie Roberson-Integra, Joyce Bilow-McLeod, Julia Redman-Carter-McLeod (PAETEC), Liz Balvin-Covad, Jennifer Aspeslagh-Comcast, Kasha Fauscett-Comcast, Ann Vick-GVNW, Susie Franke-tw telecom, Nora Torrez-tw telecom, Mindy Chapman-Neustar, Mark Coyne-Qwest, Susan Lorence-Qwest, Denise Martinez-Qwest, Janean Van Dusen-Qwest, Susie Wells-Qwest, Lynn Stecklein-Qwest

Susan Lorence-Qwest said that this is a continuation of discussions related to CR PC012009-1, Define LNP process for port cancellation by OLSP on behalf of or at the direction of the end user. She said that there is extensive background in regard to this CR that is available on the CMP website. Susan said that an agenda has been posted to the calendar.

Susie Wells-Qwest said that this process is for any service that a number port request can be issued against. She said that the industry guidelines that Qwest referred to are specific to Inter-Service Provider LNP Operations Flows. Susie said that it clearly relates specifically to Ports and this process is built around LNP and Loop with number port only. Susie said that we do not believe other products should be included as that document only refers to these specific scenarios. Susie said that in the last meeting a question of authority was brought up in regard to whether Qwest believed they had the authority to apply this process to other types of products and/or migration activity. Susie said that this is not a question of authority. She said that Qwest is implementing this process to address the specific scenarios identified in the Inter-Service Provider LNP Operations Flows.

Nora Torrez-Time Warner said that Time Warner does not want to participate in this optional process and they believe the existing LNP porting process is working. Nora said with the agreements and contracts they sign with their customers, they need to have the customer who decides they don’t want to follow through with the service we are selling them, to have that customer contact them directly. Nora said they expect not to receive rejects or calls if the customer chooses to cancel the service with them and they need to be talking with their end users because of their sign up process.

Susie Wells-Qwest said that Qwest noted Time Warner’s position.

Bonnie Johnson-Integra said that Qwest has said all along that the reason for implementing this new process is to benefit the customer so they can get what they want. Bonnie said they believe that this process is discriminatory by limiting it to LNP or Loop with LNP. She said if Qwest’s position is that they want all customers to get what they want, wouldn’t Qwest want all customers to get what they want regardless of what type of product the NLSP is ordering. Bonnie asked if the reason that Qwest is not implementing this process for all products is because there is no document of authority that applies to LNP and Loop with LNP and that is why Qwest is limiting to just porting products.

Susie Wells-Qwest said that the reason this process is being implemented this way is because it addresses LNP and the other broader product range are outside of the scope of this request. She said that Qwest believes there would have to be a separate CR to include all products.

Bonnie Johnson-Integra said that in the last several years when a CR has been submitted and if someone wanted other products included that request would be evaluated. Bonnie said that they want all products added so that it is not discriminatory.

Susan Lorence-Qwest said that this CR is specific to the notification that went out in November and Qwest worked through multiple issues and discussions. Susan said that this change is specific to porting and Qwest doesn’t want to modify this request and delay this process any longer. She said that if there are broader requirements then a separate request would be needed.

Bonnie Johnson-Integra disagreed and that by adding other products would not delay implementation or require additional work.

Susan Lorence-Qwest said that we will make note of Integra’s concern.

Susie Wells-Qwest reviewed 2 new scenarios that were added from the February 3rd adhoc meeting.

Migration Scenarios/Non Port Scenario Scenario Detail (Product Type) Where service is coming from What happens today What happens tomorrow 1) Wholesale End user with Eschelon wants to migrate QLSP Pots service to McLeod QLSP Pots service and then decides to stay with Eschelon QLSP POTs to QLSP POTs or Resale POTS to Resale POTs EU is required to contact New Provider of POTs service to advise they wish to Cancel the Migration request (Eschelon cannot contact Wholesale CSIE and request migration be cancelled) No Impacts – This is not part of the Optional Port Process, so the handling of the cancellation request stays the same as it is today. 2) Retail End User migrating to Eschelon Resale Service decides to stay Qwest Retail Retail POTS to Resale POTS or Retail POTs to QLSP POTS EU is required to contact the pending new service provider (Eschelon) to request cancellation of the migration. (Retail cannot directly contact the CSIE and request cancellation of the Migration request) No Impacts This is not part of the Optional Port Process so the handling of the cancellation request remains same as it is today

Bonnie Johnson-Integra said they want to go on record that they agree with Time Warner that this process is optional. She said that they don’t want to participate and they won’t have anything to do with the port process.

Joyce Bilow-McLeod said that they agree and if it is optional they don’t want to participate.

Liz Balvin-Covad said that Covad agreed and asked how Qwest would manage this given that the majority of CLECs do not want to participate in this optional process. Susan Lorence-Qwest said that the Industry Flow states this is a national standard and that we will take back the concern on whether or not there is an option to the opt out.

Nora Torrez-Time Warner said that they were not at any Industry forum to vote on any modification to the porting process. Nora said that the FCC has ruled on porting and there are hard rules on how it should be administered. She said that the Industry conversation on this should be reviewed by the Commission staff and that we have to be careful that we don’t get into situations like the slamming issue.

Denise Martinez-Qwest said that in the last meeting, there was concern that the 2 references identified in the industry document had 2 distinct meanings as they were not worded exactly the same. Although the wording is different, the meaning is not different.

Denise said that Qwest contacted the LNPA-WG Co-Chair for the clarification and the intent of Step 7 in NANC LNP Process Flows, Cancellation Figure 9. She said that the LNPA-WG Co-Chair says the authority indicated in this Step 7 should be the same type of acceptable authority that is required in the very beginning of the flows where the NLSP obtains authority from the end user to port their number. The beginning LNP Process Flow Main Flow, Figure 1, Step 3, says, “NLSP obtains authority (Letter of Authorization - LOA) from end-user to act as the official agent on behalf of the end-user. The NLSP is responsible for demonstrating necessary authority.” Denise said that Qwest supports the NANC LNP Process Flows. She said that based on that clarification, Qwest will continue to follow the Qwest documented process in the POA/LOA Business Procedure. She said that we believe we currently have this process documented and it meets the industry co-chairs’ understanding of what is required.

Liz Balvin-Covad provided a scenario when the end user goes to Covad with the LOA and they issue the order. She said the end user decides they don’t want to leave their provider and Qwest is saying that they too get an LOA. Liz asked what is the distinguishing factor in the LOA rules in the event the end user starts blaming one or both parties.

Denise Martinez-Qwest said that the LOA would have the most current date and time.

Liz Balvin-Covad asked what happens if the date is the same and asked why the end user wouldn’t cancel with the provider they went to.

Nora Torrez-Time Warner asked for clarification that Qwest received on the Industry document. She asked if Qwest was saying that because they have an agreement with them in the porting process to disconnect the service and migrate numbers, does that gives Qwest the authority to reject their order and to cancel.

Denise Martinez-Qwest said that the current LOA would overtake the previous LOA.

Liz Balvin-Covad said that the current process says that the end user should cancel with the new provider and that process has been in place for a long time. She asked what this change is buying anyone.

Susie Wells-Qwest said that the LNP flows have been the same for along time. She said that if Version 2 goes as far back as 2004. She said that the LNP flow states the end user has a choice.

Nora Torrez-Time Warner said that they are not suggesting that the end user doesn’t have the ability to make the decision about their service provider. Nora said that they are asking for clarification on how they handle this situation in their business so that the end user is abiding by agreements they are making. She said that if they have a contract with their end user with the LOA who is porting their service and that customer calls Qwest and says that they want to cancel, Qwest should refer them to Time Warner to cancel the service. She said that it would be the same if they want to disconnect their service with you or have a final bill they wouldn’t get in the middle of that discussion. She said that they manage their service with Qwest and they manage their service with us. Nora said that her concern is that there is work in progress that is outside of the conversation and that Qwest is saying they have the authority to cancel my business request because the customer is contacting you. She said she has an issue as to how Qwest can arbitrarily cancel an agreement/LSR request.

Susan Lorence-Qwest said that we will determine if the Industry intent is that if company by company these types of agreement would be made.

Bonnie Johnson-Integra asked who Qwest talked to for their interpretation.

Denise Martinez-Qwest said that they talked with Gary Sacra from Verizon. He is the working committee’s Co-Chair.

Susan Lorence-Qwest said that Qwest will determine if it is a possible that a company can disallow or not go forward with this intended Industry Guideline.

Julia Redman-Carter-McLeod asked how they would distinguish which LOA is the latest if they have the same date.

Denise Martinez-Qwest said we don’t provide a copy of the LOA/POA unless there is a dispute that is brought to our attention. She said that we are in good faith taking the fact that the customer is saying that what we are being given is the most current POA/LOA.

Julia Redman-Carter-McLeod asked how they would determine who has the most recent LOA.

Denise Martinez-Qwest said we would get a copy of the LOA being disputed at that time.

Mark Coyne-Qwest said that for the process to be invoked, the end user has to be doing the contacting, not the company.

Kim Isaacs-Integra asked how they are going to tell if the end user did the contacting.

Nora Torrez-Time Warner said that you could have a divorce situation and the wife calls in and cancels.

Bonnie Johnson-Integra asked how they avoid inappropriate retention.

Susan Lorence-Qwest said these are the same processes that exist today regardless of this process.

(2/19/09 Comments to Minutes received from Integra) Bonnie Johnson-Integra said currently this OLSP cannot cancel the port)

Julia Redman-Carter-McLeod said that in the divorces example Time Warner used, there may be 2 different parties talking to the provider now which may lead to an authority conflict and that they only have 4 hours to resolve.

Denise Martinez-Qwest said that in the last meeting there was discussion regarding the 4 hour window being insufficient. She said that the NLSPs concerns are a moot point. She said that based on discussions with our attorneys, Qwest is not required to give you any notification about the cancellation of a port request. She said that we are merely utilizing our existing notification process to notify that your original request has changed status and to make you aware of that current status. It is not clear to Qwest why there is an issue with the 4-hour window. Under the FCC's Brighthouse v. Verizon opinion, just affirmed, (2/19/09 Comments to minutes received from Integra) I do recall Jill saying it was just affirmed you should not be contacting the customer to retain them, triggered by Qwest's information to you that the port is cancelled. That is carrier-to-carrier porting information, proprietary to Qwest. Denise said that even before Brighthouse, the FCC held that "change of carrier" information exchanged between carriers (which this is, given that the customer has decided not to change carriers) was proprietary to the carrier submitting the information, the submitting carrier here being Qwest.

(2/19/09 Comments to Minutes received from Integra) Qwest, The meeting minutes should not include a parenthetical. The conversation either took place or it did not. If Qwest is attempting to add clarifications to state its positions, this is not appropriate. Qwest should review the minutes for any parenthetical it has added, and remove the parenthetical if the statement was made or remove the comment in its entirety if it was not.

Julia Redman-Carter-McLeod said that Qwest is using the jeopardy code to cancel their LSR and that they need to respond in 4 hour window. She said that they have no time to contact the customer for any follow up. She said they would have no clue what happened and for an error they never made.

Denise Martinez-Qwest said that we are sending you a jeopardy because of the way our systems are set up. Denise said that there is no other way to send you any type of notification advising you that the status has changed other than to send the jeopardy. Denise said that we have had this jeopardy process in place between 8 and 10 years to identify and explain a scenario to you once the FOC has been sent. Julia Redman-Carter-McLeod said that this sounds like a process that was designed for Qwest. Julia said that she did not think that the jeopardy will work for this process and that Qwest should not try and make it work for this optional process.

Bonnie Johnson-Integra said they agreed that the non fatal jeopardy process is not appropriate. She said that what Qwest is really sending is a fatal reject and that Qwest should either send a fatal reject or make some kind of change. Bonnie said that in the escalation she said that they suspected the only reason Qwest has interjected this non fatal process is because there is no other way for Qwest to reject their LSRs.

Denise Martinez-Qwest said that for clarification, this process is not specific to non fatal. It is for errors or rejects that can’t be sent. She said that we initially put this process in place based on requests from the CLECs because our systems allowed us to send but the CLECs systems did not allow any notification after FOC other than a jeopardy. Denise said that since that was how your systems were designed, we sent the jeopardy notifications to identify that information regarding both fatal and non fatal reasons.

Bonnie Johnson-Integra said that there is no action they can take. She said that in a previous call she asked what does Qwest anticipate they are going to do within the 4 hours window. She said that Qwest said that we would contact the customer etc. She said that she was looking at the order from Verizon Business and she agrees and that is a retention effort if the customer is being bounced back and forth. She said that she did not agree with Qwest comments re: contacting the customer. She said that a non fatal error is not fatal and is something that we need to do in this 4 hour window. Bonnie said that in this case because Qwest has sent the FOC and Qwest’s systems won’t let you do anything else, Qwest is going to use this process that means nothing.

Denise Martinez-Qwest said that as stated in the recent opinion that it is not something that someone should be doing as far as using the information from another source to contact the end user. Denise said that when the end user has contacted us or any other Carrier to identify they want to have the port cancelled, at that point the information is proprietary and it would be up to the end user to contact you. Denise said that if it happened within that 4 hour period we would expect you would take action.

Nora Torrez-Time Warner said that what Qwest is saying is right on track. The order says the customer has the right to cancel a port. Nora said if the customer now comes to you and you have FOC’d my LSR and confirmed the date, you can initiate a port order to take those numbers back and you have a responsibility to tell the customer that is what is going to occur because you have given the numbers away based on the initial request. She said that would drive the customer to contact the NLSP to resolve the issue. She said that the order doesn’t say you have a 4 hour window and that you can take a current LSR that I have sent for porting and cancel it. The order says that the customer can cancel and that we can’t contact them if we find out.

Denise Martinez-Qwest clarified that we aren’t cancelling the LSR; we are cancelling the internal port order.

Nora Torrez-Time Warner said that you can’t because that is my order to port. She said that the Industry says that in a porting scenario, they have an agreement that is the LSR with the customer who is porting a number. She said that the customer signs the LOA with them and that is what that agreement is about.

Bonnie Johnson-Integra asked if there were any other non fatal error that Qwest sends (2/10/09 Comments to minutes received from Integra) that a CLEC cannot act on because as Liz Balvin (Covad) has said before you are taking the LSR out of my hands.

Denise Martinez-Qwest said that it is based on the direction of the end user.

Liz Balvin-Covad said that across every ILEC, the process has the end user calling the local service provider they asked to port the number to cancel the order and that this process has been used for years. She said that she struggles with the fact that the Industry Guidelines allow for this and yet no one is using it because the process in place is working

Susan Lorence-Qwest said that Qwest doesn’t agree that no one is using this process.

Nora Torrez-Time Warner said that she deals with 300 to 400 providers and this is the 1st time she has heard about this.

Liz Balvin-Covad said that she supports that no other ILEC have this optional process to cancel the LSR during the port.

Susan Lorence-Qwest said that we aren’t trying to refute that you haven’t seen it but that Qwest knows this process has been used.

Bonnie Johnson-Integra said that Denise inserted a clarification in meeting minutes where she said that Qwest is not cancelling the LSR and when you reject the LSR you are cancelling the (2/19/09 Comments to minutes received from Integra) LSR. Bonnie said that with Qwest’s comment that nobody is using the process and asked if Qwest was referring to the brief period of time where Qwest implemented this inappropriately as a L1 and somebody used it you had implemented or are you aware that another ILEC or provider that has allowed a process for the OLSP to cancel the port.

Nora Torrez-Time Warner said that independent of this process.

Susan Lorence-Qwest said that from a Qwest perspective, we are aware it has been used it and not by Qwest.

Mark Coyne-Qwest agreed and that it is independent of this process.

Bonnie Johnson-Integra clarified that it was not associated with when Qwest briefly had this process in place, but Qwest is saying that this process is being used by another ILEC or Carrier that is allowing the OLSP to cancel port.

Susie Wells-Qwest said yes.

Julia Redman-Carter said that with the issues she sees and with the processes they currently have today, this is not the best way to deal with this process. She said that this process will not be smooth, neat or clean and will cause a lot of problems for them to force this process into the configurations they have today. Julia said they would like to see the process outlined to determine what system work would be necessary etc.

Jennifer Aspeslagh Comcast said that they agree with McLeod and by implementing this process the customer will suffer.

Susan Lorence-Qwest said that we will take note of their concern but was not sure how the customer would suffer because the customer is the lead in this effort.

Jennifer Aspeslagh-Comcast said that the CLECs are saying that with their processes today, there is a chance that the customer could remain in their systems, get double billed and there may be potential downstream impacts from Qwest issuing the jeopardy notices and only allowing 4 hours to responds.

Julie Redman-Carter-McLeod said that they have not been given the means on how to respond. Julia said that if it was possible that she understood that the legal stuff should not be discussed here but with the different interpretations from each company but is causing us problems on going forward and proposed to that their attorney and the Qwest attorney to talk about the issues whether they be Industry, legal, timing, or how we convey information not to negate Qwest’s legal authority because it seems the information Qwest is getting is different from the information they are getting from their attorneys. Susan Lorence-Qwest said that Qwest would be happy to have the attorneys talk and proposed taking this information back to review. Susan said that Qwest feels we are on solid ground with our interpretation with working with LNP working group to proceed. Susan said that we will send out a final adhoc meeting notice because we would like to get this optional process in place by using the existing mechanisms we have defined. Susan said that then Qwest would issue a change request to mechanize this process and make a fatal error that would have to go through prioritization. She said that with the jeopardy process in place for non fatal and fatal meets the needs and Qwest is proposing that we go forward with that. Susan asked if everyone could review the information we have provided.

Julia Redman-Carter-McLeod said that in the next meeting she would like to discuss how they can opt out of this process.

Susan Lorence-Qwest said that was one of the 1st points we discussed and that we will get with our attorneys to determine if that can be done and how that is handled.

Bonnie Johnson-Integra said that if this is an optional process they have the option to not to participate and Integra chooses not too.

2/18/09 ProdProc CMP Meeting Mark Coyne-Qwest said that there is an adhoc meeting scheduled on 2/20/09.

2/3/09 Adhoc Meeting LNP Optional Process Ad Hoc Mtg Change Request # PC012009-1 February 3, 2009

Attendees, Kim Isaacs-Integra, Bonnie Johnson-Integra, Laurie Roberson-Integra, Joyce Bilow-McLeod (PAETEC), Brenda Bloemke-Comcast, Jennifer Aspeslagh-Comcast, Kasha Fauscett-Comcast, Jason Lee-Verizon Business, Barbara Webb-Time Warner, Kenny Williams-Time Warner, Judy Burke-Time Warner, Jeff Sonnier-Sprint, Mindy Chapman-Neustar, Mark Coyne-Qwest, Susan Lorence-Qwest, Linda Miles-Qwest, Denise Martinez-Qwest, Janean Van Dusen-Qwest, Ellen Munz-Qwest, Susie Wells-Qwest, Lynn Stecklein-Qwest

Susan Lorence-Qwest said that this is a continuation of discussions related to CR PC012009-1, Define LNP process for port cancellation by OLSP on behalf of or at the direction of the end user. She said that there is extensive background in regard to this CR that is available on the CMP website -- as noted in both the CR and the ad hoc meeting notice. Susan said that she would not go through all of that background today. She said that we are here to continue our discussion around the optional process for existing LNP and Loop with NP requests to port to an alternate provider where the end-user decides not to complete the port. Susan said that she added an agenda to the Wholesale calendar for today’s meeting and there is also a matrix of LNP Port Scenarios that we will be discussing. She said that before she started the meeting, she wanted to review a couple items that will hopefully make our call go smoother. Susan asked if everyone could mute their line if they were not speaking, that may help with the echo. She also asked that we only have one person speaking at a time and listen to all information before asking clarifying questions or sharing your feedback. Susan said that there were a number of issues identified on the ad hoc call that we held on Wednesday, January 28, that we want to continue to discuss today. The first on the agenda is the question about which products this optional process is to be used with. Susie Wells-Qwest stated that the intent of this process is to cover LNP port out and Loop with number port requests. She said that when a CLEC is the OLSP either via resale or QLSP service, any TN that is eligible for porting could be included in this optional for cancelling port out. She said that when Qwest Wholesale receives a port out request from a Service Provider, that request could be included in this optional process if the end user chooses or wishes to go to the OLSP to cancel the port. Bonnie Johnson-Integra said that Qwest said that only time that this process can be used is if the NLSP has requested LNP only or LNP with number port. She said by design this is not an optional process because the other process does not limit to only LNP and LNP with port. Susie Wells-Qwest said that this process is for Loop and Loop with number port requests based on the NANC flows. She said this process is optional for those customers that are in a porting situation. She said that it doesn’t impact all products and is an optional process. Kim Isaacs-Integra said that Qwest indicated that this process only applies when a CLEC is the OLSP using resale or QLSP and asked if Qwest Retail was prohibited from using this process.

Susie Wells-Qwest said that Qwest could also use the process.

Kim Isaacs-Integra said that for a facility based user such as Integra, this process is discriminatory.

Susie Wells-Qwest reviewed the matrix when this process could be used and looked at applicable scenarios using actual customer names in these scenarios for clarification. The LNP port scenario matrix can be located at:

http://wholesalecalendar.qwestapps.com Bonnie Johnson-Integra referred to the NANC document, page 22, process flow #2. She said the description says that the end user contacts either the NLSP or OLSP to cancel the porting request and that only the NLSP or OLSP can initiate this transaction and not another service provider etc. She said that there no where in the step #2 flow does it talk about if the end user contacts the OLSP. Susie Wells-Qwest said that in step 2 the description says if ‘yes’ go to step 3 and if ‘no’ go step 7. Susie said step 7 is where the flow says ‘yes’ they did contact the NLSP or no they did not. She said that If they did not you go to step 7 where it is says that they did not, it says that the OLSP obtains end user authorization. Bonnie Johnson-Integra said that they have questions about authority and Qwest being the middle man. She said that Qwest indicated they are basing authority on this document. Bonnie asked if the reason Qwest is not applying this to resellers, is because Qwest (2/11/09 Comments to minutes received from Integra) believes it doesn’t have authority because there is no document. Susan Lorence-Qwest said we could take this question back to our SME team. Bonnie Johnson-Integra provided a scenario of Qwest retail with 5 POTS line and they are ordering QLSP for a conversion as is. Bonnie said that with Qwest’s proposal and documentation in the PCAT, if the customer goes to the OLSP, they can’t use this new process because the NLSP didn’t order LNP with NP or NP only. Susie Wells-Qwest said that we will take this question back to our SME team and provide a response. Susie asked, if in Integra’s example, would the service provider be Qwest. Bonnie Johnson-Integra said that it could be another reseller. Susie Wells-Qwest said that the QLSP provider is a Wholesale customer and you are a Wholesale customer and you want to do a Conversion as is for that customer. Susie said that if it doesn’t involve porting it doesn’t qualify and is not part of the process. Bonnie Johnson-Integra said that she was surprised that CLECs that are all facility based are impacted by this new process and straight resellers are not. (2/11/09 Comments to minutes received from Integra) She said that Qwest said it was doing this for the end user but if the end users NLSP orders a certain product, the end user cannot use this process. Susan Lorence-Qwest asked if there was an example of this in the scenarios matrix. Bonnie Johnson-Integra said that it does not fit any scenario. Susie Wells-Qwest said that she agreed that this scenario is not there. Susie said that the SME Team will look at adding it to the matrix. Bonnie Johnson-Integra said that her question is more around authority. Bonnie said that they believe it is discriminatory to limit this to LNP and LNP with NP. She asked if the reason Qwest has excluded that scenario, is because Qwest doesn’t believe it has the authority because there is not a document that spells it out. Susan Lorence-Qwest said that Denise Martinez will talk about the POA/LOA and authorization requirements. Denise Martinez-Qwest said that Qwest’s current policy for LOA/POA is available on the Qwest Wholesale website and is part of business procedure that is titled Proof of authorization/Order of Agency. She said that Process states that we don’t require that a POA accompany a request for any records or services. Denise said that we are taking the authorization at face value and in good faith. She said that the only time we ask for a copy of a POA, today, is if there is a dispute or discrepancy arises and we need to settle that discrepancy. She said that Qwest’s position is to continue with this current policy for this process.

Bonnie Johnson-Integra said that in step 7 it said that the OLSP is responsible for demonstrating such authority as necessary. She said that the CLEC community is telling Qwest that demonstrating such authority is needed in this type of transaction. She said that they want this to be part of the process because of the short timeframe of the 4 hour window to respond to does not allow them the opportunity to get that authority from the OLSP and they want this as part of the process. Bonnie wanted to know if Qwest was going to address the interpretation of the definition of POA/LOA. Denise Martinez-Qwest said that the document provides many definitions on terminology and that we did not see anything that refers to the actual proof Integra is referring to. Bonnie Johnson-Integra said that sometimes definitions to acronyms are provided in the beginning of the document. She said that if there is no separate definition provided, the definition is the description and this is a very different description. Denise Martinez-Qwest asked Integra if they could provide clarification on what they see the proof being. Bonnie Johnson-Integra said that the she sees it as it is described in the document. Bonnie said that it says that you obtain actual authority from the end user to act as an agent to cancel the porting request. She said that it is something that the customer has signed authorizing the OLSP to cancel the porting request and that is different than the LOA. Denise Martinez-Qwest said that Integra is looking for something more specific as rather than more general. Bonnie Johnson-Integra agreed and that it is inappropriate for Qwest to make an interpretation that the CLECs don’t agree with to that application. She said that if Qwest instead of the POA/LOA description that they put in the PCAT, want to use the description that is in the LNP Document without interpretation she is fine with that. Denise Martinez-Qwest said that we need to take this back to our legal group to get the appropriate interpretation. Mark Coyne-Qwest clarified that Integra’s definition of actual represents something written. Bonnie Johnson-Integra said that it is written and it specifically gives authority to cancel a port request. Mark Coyne-Qwest clarified that Integra does not believe that the LOA/POA is actual authority. Bonnie Johnson-Integra said not to cancel a port request. Susan Lorence-Qwest asked Integra if it believes that the LOA/POA is not actual authority, in this instance, to cancel the port. Susan said that the specific requirement is for OLSP to get that. Brenda Bloemke-Comcast said that they have the same concern as Integra. Mark Coyne-Qwest clarified that Comcast agrees that actual authority is written. Bonnie Johnson-Integra said that the LOA/POA for certain transactions don’t require party’s to provide the LOA, depending on what process your are using. She said that not only should it be written, the authorization needs to be specific to providing actual authority to cancel a port request. Mark Coyne-Qwest said that it could be electronic or written and that there are several options covered in LOA/POA. Bonnie Johnson-Integra said that it can’t be verbal. Denise Martinez-Qwest said that it can be verbal if it is verified by an independent 3rd party. Denise asked if there was a new type of LOA/POA that is very specific to porting and accepted as part of process, would Integra find it acceptable for Qwest to continue the process as we have described it to this point. Bonnie Johnson-Integra said that she does not agree with the limitation of products and does not with 4 hour timeframe. Bonnie said that (2/11/09 Comments to minutes received from Integra) what she does know is whether or not they object, Qwest will implement the process anyway. Bonnie said that she has obtained Integra’s legal interpretation of the authority if cancel the port which is different than Qwest’s interpretation. She said that with the difference between the two, they will escalate and dispute. Denise Martinez-Qwest said at this point in process you are looking for us to obtain the LOA/POA that is specific to authority for porting.

Bonnie Johnson-Integra said that Qwest’s proposed process says, as the service provider of choice whether to cancel a port request or issue a SUP request to continue with the port, you are responsible for obtaining the most recent POA either via the LOA or another method. She said that she does not agree on the cancelling the port portion of this. She said Qwest can word it exactly to say to obtain actual authority from the end user to act as the official agent on behalf of the end user to cancel the porting request. Susan Lorence-Qwest said that we understand that wording is the key issue and we can take that back. Denise Martinez-Qwest said that the Jeopardy notification process is part of current ordering overview and has been in place for many years. She said that it is referenced in the last row of the error reject notice matrix. She said that if the LSR has been accepted and the FOC has been sent, and we then detect a condition that requires a correction or a SUP from you, we will send the jeopardy notification of CO5 or SX jeopardy code. She said that we wait the maximum of 4 business hours for you to send a sup or cancel the request. Denise said that if we do receive a SUP, we act on that and send the FOC. She said that if we don’t receive anything within the 4 hours, we will cancel any existing service orders and send a reject notification. Joyce Bilow-McLeod said that this is not an error and is an optional process that would have to be included. Denise Martinez-Qwest said that it is terminology. She said that when we put this process into place, many of the CLEC/Qwest systems would not allow us to send any other type of a notice other than a jeopardy once the FOC had been sent. She said that Qwest deployed this process because it allows us to send any type of notification subsequent to the FOC without changes to the functionality of those systems. Denise said that it provides a mechanism to provide a free form remark as to what the issue is. Joyce Bilow-McLeod said she is having a hard time with the 4 hour timeframe. She said 8 hours isn’t even enough. Denise Martinez-Qwest said that the 4 business hour process has been in place for all types of notifications as was agreed upon when the process was put in place. Joyce Bilow-McLeod asked if Qwest would modify the process to accommodate this optional process. She said it will require additional calls to Qwest to figure out what is going on with our orders and that the need more clarification for their end users because they will not understand this process at all. Denise Martinez-Qwest said that the Remark is very clear that the end user has requested the cancellation of the service and there would not be much more to explain. Denise said that Qwest’s position is to be able to tell you that the end user has authorized the cancel. She said that we can talk about providing who the end user is, the date, etc. within the remark. Joyce Bilow-McLeod asked if they would be charged for the cancellation. (2/11/09 Comments to minutes received from Integra) because McLeod will not pay for a cancellation. Denise Martinez-Qwest said that they do not have to take any action at all and this is optional on their part on what they want to do or how they respond. She said that if they respond, we will act on the SUP and if they don’t, we will cancel the internal Qwest orders, reject the LSR and it will be in a final state. Bonnie Johnson-Integra said that they understand that the non fatal jeopardy process has been around a long time but Qwest has never sent this type message before. She said Covad explained in a previous meeting that the LSR is now out of their control and takes it out of the flow. She said that it is much different than the current non jeopardy process where they are still in control of their own LSR. She said that they disagree with sending this new type of message and determine internally how to react. Denise Martinez-Qwest said that we understand that the CLECs would prefer to see notices that are very specific to the issue. She said that we have looked at creating a mechanized end user cancellation notification. Bonnie Johnson-Integra said that whether it is mechanized or not, it would still require some development in each company depending on what action is taken and what process would need to be followed. Denise Martinez-Qwest said that we understand that there would be some process changes but thought it would be more appetizing. She said that if there was a problem with the jeopardy itself there are other possibilities that could be looked at. Susan Lorence-Qwest said that we will take back the questions from this meeting. Susan said that the next meeting is scheduled on February 12th at 1:00 pm MT and any supporting documentation will be provided prior to the meeting. LNP Optional Process Ad Hoc Mtg Change Request # PC012009-1 January 28, 2009

Attendees, Kim Isaacs-Integra, Bonnie Johnson-Integra, Laurie Roberson-Integra, Julia Redman-Carter-McLeod (PAETEC), Brenda Bloemke-Comcast, Jennifer Aspeslagh-Comcast, Kasha Fauscett-Comcast, Jason Lee-Verizon Business, Susie Franke-Time Warner, Jeff Sonnier-Sprint, Mindy Chapman-Neustar, Gloria Velez-AT&T, Mark Coyne-Qwest, Susan Lorence-Qwest, Denise Martinez-Qwest, Janean Van Dusen-Qwest, Ellen Munz-Qwest, Susie Wells-Qwest, Lynn Stecklein-Qwest Susan Lorence-Qwest said that a Level 1 notification was sent on 11/14/08 for an optional process and was implemented on 11/17/08. Susan said this optional process allowed existing LNP and loop port request to port to an alternate provider if there was an end user that decided not to complete the port. Susan said that we provided an alternative to the existing process to cancel the port request. She said that the PCATs were updated and e-mails were sent between Integra and Qwest expressing concerns about the process. Susan said an escalation was submitted in regard to the optional process and Qwest responded to the escalation with a binding response. Susan said that subsequent to the escalation, there was a CMP oversight issue submitted by several CLECs and a CMP oversight meeting was held in mid January. Qwest’s decision was to retract the L1 notice on 1/21/09 and to issue a Level 4 (CR PC012009-1) on 1/20/09 so that a formal comment cycle could occur .She said that the LNP updates were restored back to the way it was prior to the optional process going in. Susan said that this meeting was to review the optional process and discuss any changes or concerns the CLECs have on the process itself. Susie Wells-Qwest stated that she will be presenting the CR and to review the existing process. She said that when one of the CLECs end users wants to cancel a pending port request, the CSIE may receive a call from resale or QLSP providers requesting that Qwest, on behalf of their customer, cancel the port request. She said that the Qwest’s process is to advise the customer to contact the end user to get in touch with the pending NLSP or the new Network Service Provider to cancel the port for them. Susie said that Qwest does not cancel the request on their customer’s behalf. She said that Qwest’s proposed process is to cancel the port request from information received from our customer (Reseller or QLSP) on behalf of their end user. Susie said that we want to allow the end user to go to either the pending NLSP or the OLSP they have today. Susie said that this optional process is for existing LNP and Loop with NP requests when the end-user decides not to complete the port. Susie said that the original provider may utilize the optional process to cancel the port request to the alternate provider. Bonnie Johnson-Integra said that Qwest’s proposed process and the document which Qwest is basing it’s authority to cancel ports, says it is not limited to LNP and Loop with LNP. She said that Integra will object to limiting the process to Loop and Loop with LNP and that the process should be implemented across the board for all products. Bonnie said that the process is discriminatory for a CLEC vs. a Reseller or a Company doing one type of business over another. Bonnie asked why Qwest was not including all products. Susie Wells-Qwest said that operational flows being referenced by Integra are directly related to LNP. Mark Coyne-Qwest asked if the document Integra was referring to had the heading “Inter-Service Provider LNP Operational Flows”. Bonnie Johnson-Integra said that it did. She said that the link that Qwest provided is a separate document and she was looking at version 3. Mark Coyne-Qwest said that the document was specific to LNP. Susie Wells-Qwest said that the link provided takes you to the NANC Operation Flows V3 and the other documents are earlier versions of the same document. She said Integra’s concern has been noted. Bonnie Johnson-Integra said that if this document is only referring to porting. She said that in previous meetings Qwest stated that we want the customer to get what they want. She said that it was not appropriate to implement the process for only certain products and that the customer can’t use this option in all cases. Susie Wells-Qwest said Qwest’s proposed process will allow an e-mail to be sent to the Qwest Customer Service Inquiry and Education (CSIE) CSIEsup@qwest.com with a Subject Line of: Notification of Cancelled Port. Include the following information in the body of the e-mail: Billing Telephone Number (BTN) or Ported Telephone number of the Cancelled Port, Date of Cancellation (must be a minimum of 2:00 PM Mountain time one day prior to the port due date) and End-user name and address. Susie said that Qwest will create one CSIE ticket for each Notification of Cancelled Port e-mail request and manually issue a Jeopardy notice to the porting LNP provider via IMA or Fax Gateway. Susie said that the following Jeopardy (JEP) codes will be used: C05 – Design with is Loop with NP and SX – Non Design which is the standard number port. The Jeopardy notification will include the comment: End User has requested cancellation of the Port request. Susie said if the LNP provider does not respond within the 4 business hours which is the standard JEP window, the port order(s) will be canceled and the LSR will be rejected using the Reject code of 814 (No response to C05 or SX Jeopardy from CLEC 4 hours after request for additional info). She said that the CSIE will send a confirmation of the cancellation request and will be sent via email from the CSIE. She said if the LNP provider issues a SUP request within the 4 business hours JEP window, the CSIE will not cancel the pending port request and will respond back to the Notification of Cancelled Port e-mail: Due to a more current request we cannot process your cancel. Bonnie Johnson-Integra said that Qwest appears to be the only CLEC/ILEC implementing this type of process. She asked what action Qwest (2/4/09 Comments to Minutes from Integra) anticipates the NLSP will take when Qwest sends the non fatal jeopardy. Susie Wells-Qwest said they may want to change the due date, update the LSR indicating the end user changed their mind about completing the port request. She that the pending service provider would be sending it back saying that they have talked with the end user and they have changed their mind. Susie said they would SUPP the request advising they have the latest POA or information from the end user that enables them to finish the port request. Bonnie Johnson-Integra (2/4/09 Comments to Minutes from Integra) said so Qwest anticipates the NLSP would be contacting the customer to verify that information. Susie Wells-Qwest said that they would if they Supp’d the request. She said that all of our documentation today states that there has been contact with the customer and that they have the most recent POA. Bonnie Johnson-Integra said that contacting a customer in a 4 hour timeframe is unreasonable. Jennifer Aspeslagh-Comcast asked if the CLEC issues a SUP 3 that the customer wants to port to Comcast, does Qwest notify the reseller via e-mail that Comcast is going to take the customer. She asked if the Reseller can say no and that they have the most recent LOA. She said that there will there be a lot of back and forth. Bonnie Johnson-Integra said she can see that happening. Bonnie referred to page 23, step 7 (LOA) that states: “The OLSP obtains actual authority from the end-user to act as the official agent on behalf of the end-user to cancel the porting request.” She said that the LOA is discussed on page 3 of the document and does not agree with Qwest’s interpretation that the authorization is the standard LOA. She said she believes the Industry document is saying that there will be an actual document where the end user is giving the OLSP authorization to cancel the porting request. Susie Wells-Qwest said that she wanted to address Comcast’s concern of going back and forth. She said that because we have the cutoff time for when all this can occur, it lessens the likelihood of going back and forth. Susie said, for example, the customer has decided to port with us, we send a response back to the Reseller who sent the request. She said that the cutoff times will lessen the likelihood of that reseller wanting to start the whole process over. Bonnie Johnson-Integra said that they could open up a new ticket and say that they have the most recent LOA and start the whole process over. Susie Wells-Qwest said that port request intervals are 3 business days and if the end user were to request to port with one of our customers, that customer would send the LNP request. Susie said that in the meantime (i.e.4-6 hours) the customer says they want to go back to their OLSP. She said that there is no a whole lot of time to work with and the possibility is a lot less with the standard interval being 3 business days. Julia Redman-Carter-McLeod wanted clarification that they have 4 hours to contact their customer and to verify the authorization to determine what the customer wants to do. Susie Wells-Qwest said yes, and that we are following the existing jeopardy notification process and that Qwest will send the jeopardy notification in the standard 4 hour business timeframe. Gloria Velez-AT&T asked at what point Qwest would not accept the e-mail from the provider that they want to cancel. Susie Wells-Qwest said that we would not be able to accept the e-mail past 2 PM MT on the day prior to the port. Jeff Sonnier-Sprint said that they process 70,000 ports weekly with all RBOCs and to introduce Qwest as a 3rd party between Sprint and another CLEC adds complication. Jeff asked how Qwest gets any benefit from this. He said it would be a detriment for them to go through a 3rd party to get back with the end user as well as getting back to the other CLEC who is either taking or giving the number. Bonnie Johnson-Integra asked when Qwest cancels the subscription. Susie Wells-Qwest said that when we receive the e-mail, send out the jeopardy notice and the NLSP has not responded within the four business hour timeframe, Qwest rejects the LSR back to the NSLP. Susie said we then cancel the Qwest service order and notify via e-mail the cancellation of the port request. Bonnie Johnson-Integra said that Qwest does not have these steps outlined in the process. Susan Lorence-Qwest asked what steps Integra was looking for. Bonnie Johnson-Integra said they were looking for the process from end-to-end and should document step- by- step everyone’s responsibilities. Julia Redman-Carter-McLeod said they need to understand what happens before and after. Bonnie Johnson-Integra said that in a previous meeting, Covad stated that Qwest has taken the LSR out of their control. She said that Qwest needs to document this process end-to-end so the end user is not taken out of service. Jeff Sonnier-Sprint said that this process is putting Qwest in the middle of 2 CLECs and the end user with the latest LOA. Jeff said that he did not understand why Qwest would not refer back to the NLSP. Bonnie Johnson-Integra agreed and expressed her concern about Qwest making an interpretation of what documentation is appropriate and does not agree with Qwest’s Interpretation. Bonnie said there should be an actual authorization to cancel the port and the current service provider should provide that document attached to the e-mail sent to the CSIE. Brenda Bloemke-Comcast said that she agreed with the LOA comment. Susie Wells-Qwest said that the process does indicate the most recent authorization whether it is an LOA or another method. Bonnie Johnson-Integra asked where that is in the in the documentation. Bonnie said that the process flow of LNP in the document describes the process flow of LNP. She said that it specifically states that actual authority from the end user to act as the official agent to cancel the porting request. Susan Lorence-Qwest said that what we are getting into questions about the industry document and is not an area that is part of this discussion. Bonnie Johnson-Integra said it should be part of the discussion if Qwest is interpreting the LOA/POA and putting it into the PCAT. Susan Lorence-Qwest said that if there is a question about the interpretation of this document within the community, it needs to go back to the industry forum and should not be part of this discussion. Susan said that Qwest has made an interpretation of the LOA and if there is a question about the interpretation that should be taken back to the appropriate industry group. Julia Redman-Carter-McLeod said that she did not agree and when she gets the notification she wants to see the LOA (2/4/09 Comments to Minutes from Integra) or whatever is is attached that gives the actual authorization information. Julia said that she wants to see the date and time. She said McLeod would not be interested in this process unless they can see or have attached to the e-mail the most recent authorization which would need to include the time of the authorization to prevent making additional calls, sending things back and forth and spending their resources trying to beat a clock. Janean Van Dusen-Qwest asked if the CLECs were requesting that the OLSP who issued the cancel request, provide information as to who they spoke to, the time etc. in the e-mail they send the CSIE. Bonnie Johnson-Integra said that the actual signed document should be attached. Julia Redman-Carter-McLeod said that she has 4 hours when she gets the jeopardy notification to investigate and to call the customer and to determine if they have the most recent LOA. She said that someone else in the meantime calls them again and we go back and forth. Janean Van Dusen-Qwest said that she was not clear on how the information sent to the CSIE will help. Julia Redman-Carter-McLeod said that she was not clear on the process and that this information is very high level. She said that Qwest has left out a lot of things the CLEC needs to coordinate and to communicate to whom and when. Janean Van Dusen-Qwest said that what she is hearing is that that the CLECs want to see the authorization. Julia Redman-Carter-McLeod said that Qwest is cancelling the LSR that used to belong to them. (As a clarification, Qwest is cancelling the port and the internal service order. We are not cancelling the LSR). She said that she wants to know who took it, when, and where did the authority go and at what point they get it back. Janean Van Dusen-Qwest said that she wanted to clarify that the CLECs would like the CSIE to provide the NLSP the information on authorization. Julia Redman-Carter-McLeod clarified that she wanted access to that authorization. Susan Lorence-Qwest asked why this process is different than the initial port request. She asked if the LOA is provided when the NLSP initiates the port request. She said that there is a trust factor for all of this to work appropriately. Julia Redman-Carter-McLeod said that today someone contacts them about a port and you know you are going to lose the customer. She has talked to the party and she can cancel the port and knows that they have the authorization. She said that in this instance someone else is cancelling their LSR, she never saw the authorization, no one contacted them and they were not a player and have nothing to show why that customer went somewhere else. She reiterated that she only has 4 hours and now the LSR is out of their hands. She said that with the 3rd party involvement she has no control. Jeff Sonnier-Sprint agreed and wants the burden of proof on the 3rd party. Susan Lorence-Qwest asked who Sprint was referring to as the 3rd party. Jeff Sonnier-Sprint said that Qwest wants to be involved as a 3rd party because the end user is calling them. Jeff said that if they were doing a port with Integra and we swapped LSR and FOC information back and forth, the end user would call Qwest to ask to remain who they are with (Integra) and Qwest will cancel my LSR. Susie Wells-Qwest said Qwest will only be involved if one of the wholesale customers that we provide service to, i.e. on a Resale or QLSP basis where Qwest is the underlying Network Service Provider. Kim Isaacs-Integra said that Qwest needs to include Qwest retail because they are the most common user of this process. Susie Wells-Qwest said that from a retail perspective, the network SP or from Wholesale QLSP where Qwest is the underlying network provider – She said we have to be involved. Jeff Sonnier-Sprint said that he thought we were saying the same thing. He said that assuming Integra was using Qwest facilities. He said that if they are reusing facilities that Qwest owns as the network service provider is what he is referring to when he talks about 3rd party. Susie Wells-Qwest said that request goes to Qwest and not Integra. She said that you as the NLSP know that Integra has the end user on a resale or QLSP basis will send the port request to Qwest. She said that the only time you would go to Integra is in a facility type situation. Jeff Sonnier-Sprint said that the question of the LOA still stands. He said that he doesn’t want to have to hunt around with a very limited timeframe to try to reach an end user, a 3rd party etc. He said that the end user could just as easily call him and asked why they could not be directed to the new service provider. Janean Van Dusen-Qwest said that the customer will not call Qwest to cancel their request. She said that they either have to go to their OLSP saying they don’t want to leave or go to their NLSP and make those arrangements. Qwest retail will not take those calls. Kim Isaacs-Integra said Qwest retail would advise that Integra is porting a Qwest retail customer. She said that the end user contacts Qwest retail and indicates they don’t want to go with Integra anymore, or someone from Qwest calls them and ask why they are porting to Integra which does happen. Kim said Qwest retail will contact the CSIE and the CSIE will send them a jeopardy saying their port has been cancelled. Janean Van Dusen-Qwest said that she was just addressing scenarios between 2 local CLECs, rather than Qwest. Kim Isaacs-Integra said that they would refer the end user to the NLSP. Gloria Velez-AT&T said that if there are 2 CLECs, excluding Qwest, then Qwest wouldn’t need to be involved at all. Janean Van Dusen-Qwest said that she was addressing Sprint’s scenario. Gloria Velez-AT&T asked if QLSP translates to Qwest Retail. Susie Wells-Qwest said that it is a form of Qwest retail or the old UNE-P, QPP. Susie said that it stands for Qwest Local Service Platform. Susan Lorence-Qwest said that it appears the biggest issue is having authorization attached to the e-mail and that there is either a document included with a date and time stamp of the current LOA/POA. Bonnie Johnson-Integra said that she wanted to make it very clear regarding Integra’s concern with Qwest’s interpretation of what/when authorization is appropriate. She said that Qwest is refusing to discuss their interpretation. Susan Lorence-Qwest said that Qwest is not refusing to discuss but discussing the industry document in detail is not appropriate for this call. Susan said Qwest Qwest is not refusing to discuss but discussing the industry document in detail is not appropriate for this call. Susan said Qwest is proposing a port process that Qwest has interpreted and believes is in support of what the Industry document says. She said that if there is a broader question about the interpretation of the industry document, there is a forum where that discussion should reside. Julia Redman-Carter-McLeod said if that is the case it would be appropriate for the CLECs to determine what is adequate for the documentation. Susan Lorence-Qwest said that we have captured that concern and will take it as an action item. Bonnie Johnson-Integra said that if Qwest is going to make an interpretation on behalf of everyone, she does not agree. Bonnie said if Qwest wants to update the PCAT (2/4/09 Comments to Minutes from Integra) the information the same as the LNP document, they will not object and is subject to interpretation for the reader. She said that if Qwest makes an interpretation then Qwest has an obligation to advise who in the Industry they talked to. Bonnie said that if Qwest wants to make the interpretation for its own company they can do that but not for everyone else. She said that in the event Qwest accepts the LOA/POA and later the interpretation may be incorrect. Susie Wells-Qwest said that step 7 on page 23 “The OLSP obtains actual authority from the end-user to act as the official agent on behalf of the end-user to cancel the porting request. The OLSP is responsible for demonstrating such authority as necessary”. Bonnie Johnson-Integra said if that is what Qwest wants to document in the PCAT she does not object. Denise Martinez-Qwest asked Integra to provide their view on their interpretation so that Qwest can better understand why we are going down different paths. Bonnie Johnson-Integra said that their interpretation is exactly what it states. She said the way it is worded the OLSP obtains actual authority from the end-user to act as the official agent on behalf of the end-user to cancel the porting request. Bonnie said that the document is saying that it is not just the standard LOA and also includes actual authorization to cancel a pending port. Denise Martinez-Qwest said that Integra sees this as a document and if you were contacted by the end user you would not take this as a verbal. You are looking for a different document. Bonnie Johnson-Integra said that she believed it could be a LOA with additional paragraph and interprets that as a document and specifically says that the end user is giving the OLSP authority to cancel the porting request. Julia Redman-Carter-McLeod said that she agreed with Integra and is looking for something that specifically says that the OLSP has the authority to cancel the pending port. Bonnie Johnson-Integra said that on page 3 NLSP obtains authority LOA from the end user to act as the official agent of the end user. She said that in the cancellation it says to add that they have authority to cancel the request. She said that if the industry anticipated that the LOA was going to serve the purpose you would see this sentence in number 7 of the cancellation and it is not. Susan Lorence-Qwest said that Qwest has captured the concern. Susan said that Denise Martinez-Qwest will talk about the jeopardy codes of CO5 and SX. Kim Isaacs-Integra said the CO5 is used with LNP and LNP with Loop orders and so including the SX jeopardy in the process implies that Qwest will be cancelling implies that you are going to cancel LSRs to convert retail to resale or QLSP and resale QLSP to retail QLSP. Bonnie Johnson-Integra said that the codes are conflicting with the products you are implementing the process for. Denise Martinez-Qwest said, for example, if you had a POTS service with the associated TN to be ported that is when we would use SX. Denise said if we were porting a TN that was associated to a design service i.e. DID trunk, we would use the CO5. Kim Isaacs-Integra said that is not how Qwest is using them today. She said the CO5 is used on Unbundled Loops, LNP, and LNP with Unbundled loops. Denise Martinez-Qwest asked if Integra could share examples of where the codes are not being applied correctly. She said that the application of the codes is based on what the current Qwest service is and whether we have a POTS service or a design service. Denise said that we are not just using it for number portability. Kim Isaacs-Integra said that she did not think Qwest understood what Qwest’s Centers are doing. She said that they are applying the code based on the product. Denise Martinez-Qwest said that it should be applied based on the product that it is coming from and if Integra could provide examples we would be happy to research. Bonnie Johnson-Integra said that Qwest has the data too. Denise Martinez-Qwest said that if there is a problem, Qwest would like to research. Kim Isaacs-Integra said that the Qwest center is using the jeopardy codes based on where the product is going to. She said a port order with LNP will receive a CO5 or CO1 jeopardy and not the SX jeopardy. Kim said that the language implies that if it goes to resale/QLSP, Qwest will also cancel those. Denise Martinez-Qwest said that is not what we are trying to relay and will take this issue offline. Denise said that regardless of the code, the intent was to be able to send you notifications regarding an issue after the FOC has been sent because there was not a way we could send an error or reject code. She said the reason the process was put in place initially was so that we could mechanically send notifications after FOC. Denise said that we have a design and non design code and if they are being applied incorrectly we will fix that. She said that we are using the codes to identify for you a condition that exists which is a cancellation from the end user. She said that Qwest is sending the jeopardies so that you can take whatever steps within your company. 2/3/09 - Subsequent to the call, Denise analyzed 23 LNP and Loop with NP LSRs. One request had been identified incorrectly. The LSR had a mixture of one non-designed and three designed orders yet the SDC had marked all orders as designed. Denise will send a notification to the Centers to correct this misunderstanding. We appreciate that Kim brought this to our attention. On a good note, anything processed through FTS has the correct logic to determine non-design and design on an individual order basis. Lastly, this should still not impact this process. The jeopardy codes of SX and C05 only define design and non-design. They do not define a product type. The Remark for porting or loop with port jeopardy notices specifically indicate that the End User has requested cancellation of the port requested. Bonnie Johnson-Integra cited examples: if Integra sends an LNP only request (Qwest Retail) and ports all the numbers on the account, Qwest retail or any CLEC can use this process. Bonnie said that if the NLSP is issuing the LNP order, the OLSP, if Qwest is the Network provider can use this process. If Integra sends the LNP with Loop order and Qwest is the old Network provider the OLSP can use this process. Bonnie asked if Integra sends the order to convert either on a port into Qwest or a conversion from Qwest retail to QLSP can the OLSP use this process. Susie Wells-Qwest said no, if porting is not involved. Bonnie Johnson-Integra said that she provided examples of both. She said one example referred to when they were ordering QLSP with another CLEC and is a port into Qwest as QLSP. Susie Wells-Qwest said the answer to the 1st question would depend on if the other service provider that you are trying to port from wants to use this process. She said the Network Service Provider has their own facilities and you order the service through QLSP as a port in. She said we let that service provider know that we are going to port in this customer. Susie that they can FOC us and say fine and at some point if their customer says they have changed my mind and request to cancel the port for them, they can turn around and use this process to cancel the port. Susie said that this is an optional process for any service provider who wishes to use it. Bonnie Johnson-Integra said that in that case your description that it applies to LNP and LNP with Port only is inaccurate. Susie Wells-Qwest said that on behalf of Qwest, it’s not inaccurate because we don’t have any control over what other service providers do, decide to keep, or retain to keep care of their customers that are getting ready to leave. Susie said it doesn’t have anything to do with our porting process because that would not change. She said it depends on how the other service provider handles their port out process. Bonnie Johnson-Integra said that Qwest has indicated in this document that this applies to LNP and LNP with Loop with number port only. She said that per Qwest’s documentation the NLSP has to have ordered one of those 2 products. Susie Wells-Qwest said agreed and that they would have sent us a standard number port request which means they are not requesting the facilities; they just want the number ported. Bonnie Johnson-Integra said if they ordered QLSP, with the process written today, it would not apply. Susie Wells-Qwest said that was correct and said that it would only apply to port LNP or port out from Qwest. She said that the intent in this scenario is when an end user decides they don’t want to port away, we give that end user the option of contacting you as the reseller or QLSP provider or Qwest Retail when they change their mind. Julia Redman-Carter-McLeod asked if the NLSP defines which process is being used. Susie Wells-Qwest said that the OLSP defines the process from Qwest’s standpoint. Susie addressed Integra’s example. Susie said that if Integra has a customer that belongs to McLeod and Qwest is the underlying network service provider, they can provide their own facilities. Susie said that request to port in this customer (QLSP or Retail) that makes Qwest the underlying Network Service provider. She said that we get the request and if you have sent in a standard port request and you want us to provide new facilities on your behalf to that end user, we will do that. Susie said that if you ask that we try to reclaim an UBL we will go to McLeod with the LSR and say that we are requesting to port in this number either just as a standard number port or request UBL. She said that in this instance McLeod is the OLSP so we will FOC and we have everything ready to go. She said that the customer may choose not to go to Integra and stay with McLeod and request them to cancel the port request. Susie said that depending on the process that McLeod wants to use, it is their choice as the OLSP, to tell their end user that they have to contact Integra to cancel the request or they can come back to Qwest and say on behalf of their end user they are cancelling the request. Bonnie Johnson-Integra said that earlier she understood that the only time that the process of sending an e-mail to the CSIE as the NLSP order is with LNP only and LNP with Loop only. Bonnie said that if they ordered QLSP the answer is yes. Gloria Velez-AT&T said that she was confused as well. Susan Lorence-Qwest said that we do have another call in a week and we will provide a matrix to show under what conditions this optional process applies. Bonnie Johnson-Integra said that at the beginning of the call that she expressed Integra’s concern about their being any limitations. Bonnie said that if Qwest is going to implement this process, it needs to be implemented regardless of what products the OSLP is using to service the customer or how the NLSP is ordering from Qwest. Susan Lorence-Qwest said that we have Integra’s initial concern noted. Gloria Velez-AT&T asked when Qwest was talking about the jeopardy process and not receiving the supp within 4 hours, the company that initiated the LSR would get another response coming from and asked what that response would be. Susan Lorence-Qwest said that we will take that note and provide the flow and we can’t put down what the NLP is going to do but if we can provide examples of when we receive something back within the 4 hours and if we didn’t receive something back. Gloria Velez-AT&T said that the new company initiating the LSR and when there is no response within the 4 hours issue a supp. She said that Qwest will be sending another response. She said that the company that issues the LSR will be getting another response and in the flow doesn’t work that way. She said that in the flow the Network Service provider issues a jeopardy and they wait for something and if they don’t get anything they don’t send another response. Denise Martinez-Qwest said we were describing the current jeopardy process for CO5 and SX. She said that we send a jeopardy notice and if the company does not respond within 4 hours, we send a reject code of 814 that indicates there is no response to the CO5 and SX jeopardy. Denise said that it is in a final condition and the LSR is in a rejected state. Gloria Velez-AT&T said that Qwest is not doing that today. Denise Martinez-Qwest said that we are, and if we send the CO5 or SX jeopardy and don’t get a response within 4 hours, Qwest is sending a reject. Reference the Ordering Overview, then see the Error/Reject Notice Matrix, specifically the last row at http://www.qwest.com/wholesale/clecs/ordering.html Susan Lorence-Qwest said that we have a call scheduled on 2/3/09 from 9:30 am to 11:00 am and an agenda will be provided by Monday, 2/2/09.