Announcement Date:	August 19, 2021
Effective Date:	September 10, 2021
Notification Number:	CMPR.CTLL.08.19.21.F.18255.UNE_Ordering_Limitations
Notification Category:		CMP
Target Audience:	CLEC-C & CLEC-Q
Subject:	Level 2 – UNE Ordering Limitations

 

Dear [COMPANY NAME]:

 

Summary of Change:

CenturyLink is contacting you regarding your Interconnection Agreement(s) with CenturyLink (the “Agreement(s)”).

The Federal Communications Commission (the “FCC” or “Commission”) released Order FCC 19-66, a Report and Order on Remand and Memorandum Opinion and Order in WC Docket Nos. 18-141, et al (the “UNE Transport Order”), which became effective upon release, and on August 2, 2019, the FCC released Order FCC 19-72, a Memorandum Opinion and Order in WC Docket 18-141 (the “UNE Analog Loop and Resale Forbearance Order”), which became effective upon release, and on October 28, 2020, the FCC released Order FCC 20-152, a Memorandum Opinion and Order in WC Docket 19-308 (the “UNE Digital Loop and Dark Fiber Forbearance Order”), which became effective upon release. Together, the UNE Transport Order , the UNE Analog Loop and Resale Forbearance Order and the UNE Digital Loop and Dark Fiber Forbearance Order collectively referred to as the “Forbearance Orders”, are changes in Applicable Law that, pursuant to the terms of the Agreement, result in the withdrawal of certain services under the Agreement.

In order to implement the terms of the Forbearance Orders, and consistent with the terms of the Agreement regarding withdrawal of services, the following process and actions will be taken:

CenturyLink will be implementing changes in our ordering systems to ensure orders for services that are no longer supported under the Forbearance Orders fail validation and that an error message is returned.  Orders failing validation will be returned with an error message of “This product is no longer offered due to forbearance”

Ø  For services where the last order date has already occurred, the validation errors will begin no sooner than September 10, 2021.  Initially, this will apply only to UDIT, EEL and DS3 UNE-L requests in forborne SWCs

Ø  For services where the last order date is after September 10, 2021, the validation errors will begin immediately the day after the last order date.

This action is specifically provided for in the Agreement, as discussed in Withdrawal of Services. If your company maintains that other language requires a different process, please respond as such to this communication.

 

Comment Cycle:

CenturyLink encourages you to review and submit questions or comments at any time during the comment cycle as listed in the table below.

 

You may e-mail questions or comments to intagree@centurylink.com.  Please be sure to reference the Notification Number listed above.

 

Timeline:

 

Business As Usual	August 19, 2021
CLEC Comment Cycle begins	August 19, 2021
CLEC Comment Cycle ends	5:00 PM MT, August 26, 2021
CenturyLink response to CLEC Comments (if applicable)	September 2, 2021
Proposed Terms of Forbearance Orders Date	September 10, 2021