******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the document such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlining, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Federal Communications Commission Washington, D.C. 20554 Adopted: June 24, 1998 Released: June 24, 1998 Ms. Patricia E. Koch Assistant Vice President, Government Relations - FCC Bell Atlantic Corporation 1300 I Street NW, Suite 400W Washington, DC 20005 Dear Ms. Koch: In this letter, the Accounting Safeguards Division ("ASD") addresses the resolution of certain issues concerning Bell Atlantic's Performance Monitoring Report ("PMR") submissions filed pursuant to the Bell Atlantic/NYNEX Merger Order and the progress Bell Atlantic has made in filing such reports. In November 1997 and February 1998, Bell Atlantic filed its PMR submissions in accordance with the Bell Atlantic/NYNEX Merger Order. After ASD staff reviewed the PMR submissions and identified certain issues with these filings, we released a letter directing Bell Atlantic to revise its PMR submissions in order to be consistent with Appendix D of the Bell Atlantic/NYNEX Merger Order ("Appendix D"). In a series of meetings with ASD staff, Bell Atlantic representatives discussed and agreed to correct these issues. Specifically, Bell Atlantic will revise the labelling format of its PMR submissions and provide corrected copies of the November 1997 and February 1998 PMR submissions on or before July 6, 1998. In addition, Bell Atlantic will provide a glossary of terms and detailed definitions as a common reference document for future PMR filings no later than the August 1998 PMR submission. We anticipate that these actions will help ensure that the PMR data is clear, usable, and consistent with Appendix D of the Merger Order. Bell Atlantic's May 1998 PMR submission contained certain labelling and reporting errors that were not evident in earlier submissions. Specifically, the paper and electronic versions of the May 1998 PMRs contain different data in some metrics. In addition, Bell Atlantic erroneously labelled certain proprietary data as "non-proprietary." After discussing these issues with ASD staff, Bell Atlantic has been correcting the labelling and reporting errors and will provide a corrected version of the May 1998 PMR submission on or before July 6, 1998. We anticipate that Bell Atlantic's review and re-examination will ensure that the May 1998 PMR data is accurate and consistent with Appendix D of the Merger Order. As a general matter, we are encouraged by Bell Atlantic's efforts to implement this reporting program. We are concerned, however, about the error rates we have found in the three submissions Bell Atlantic has filed to date. We believe Bell Atlantic is working to solve the problems and we fully expect that these issues will not arise in the August 1998 and subsequent filings. If there is anything the ASD staff can do to facilitate the reporting process, please feel free to contact us at any time. In the meantime, if you have any questions concerning this letter or would like to further discuss these issues, please feel free to contact Anthony Dale at (202) 418-2260 or Whiting Thayer at (202) 418-0822. Sincerely, Kenneth P. Moran Chief, Accounting Safeguards Division