********************************************************    
                                        NOTICE
   ********************************************************
                               
               This document was converted from
          WordPerfect or Word 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:  January 11, 2000
                                               Released:  January 12, 2000
                                          
                                     Ms. Janette Luehring
                                     Chief of Telecommunications
                                     Kansas Corporation Commission
  1500 S.W. Arrowhead Road
  Topeka, KS 66604
  
  
  Dear Ms. Luehring:
  
       This letter responds to your request for guidance on interpreting certain conditions in
  the SBC/Ameritech Merger Order.  In your letter of January 3, 2000, you requested
  clarification of the Merger Conditions as they relate to the interconnection agreement between
  an SBC/Ameritech incumbent local exchange carrier ("LEC") and its advanced services
  affiliate.  Specifically, you ask whether the "Surrogate Line Sharing Charges" that the
  incumbent LEC charges its affiliate may be posted on an Internet site instead of contained
  within the interconnection agreement.  In addition, you asked whether information about the
  line sharing arrangement between the two companies must be contained in the interconnection
  agreement.
  
       The SBC/Ameritech Merger Order requires SBC/Ameritech incumbent LECs and their
  advanced services affiliates to negotiate, and file for approval with the appropriate state
  commissions, interconnection agreements that set forth the "terms, conditions, and prices for
  the provision of interconnection, telecommunications services, and network elements that the
  affiliated incumbent LEC shall provide to the separate Advanced Services affiliate for the
  purposes of the separate affiliate's provision of Advanced Services."  In addition, such
  interconnection agreements "shall be sufficiently detailed to permit telecommunications
  carriers to exercise effectively their 'pick-and-choose' rights under 47 U.S.C.  252(i) and the
  Commission's rules implementing that section."
       The SBC/Ameritech Merger Order further allows SBC/Ameritech incumbent LECs to
  provide "Interim Line Sharing" to their separate advanced services affiliates subject to certain
  provisions.  With respect to Surrogate Line Sharing Charges, the Merger Conditions state: 
  "The SBC/Ameritech incumbent LEC shall establish and make available through
  interconnection agreements with the separate Advanced Services affiliate . . . surrogate
  charges for the costs incurred in making available an unbundled local loop capable of
  providing Advanced Services . . . in combination with voice grade services [i.e., 'Surrogate
  Line Sharing Charges']."
  
       In accordance with the Merger Conditions, the interconnection agreement between
  SBC/Ameritech incumbent LECs and their advanced services affiliate must contain
  information about the Interim Line Sharing arrangement, even though SBC/Ameritech
  incumbent LECs may provide such arrangements to their affiliates on an exclusive basis for
  the interim period.  Despite inclusion of information about Interim Line Sharing arrangements
  in the relevant interconnection agreements, we recognize that competing carriers will not be
  able to opt into such arrangements because of operational and technical issues discussed more
  fully in the Commission's Advanced Services Third Report and Order.  Still, inclusion of
  information about the Interim Line Sharing arrangements is necessary to show that the
  affiliates operate at arm's length, and to inform the Commission, state commissions, and the
  public about important operational aspects of the relationship.  Moreover, inclusion of the
  Interim Line Sharing arrangements is necessary to satisfy the "sufficiently detailed"
  requirement for interconnection agreements between SBC/Ameritech incumbent LECs and
  their advanced services affiliates.
  
       The plain language of the Merger Conditions requires the Surrogate Line Sharing
  Charges to be contained within the interconnection agreement filed with the appropriate state
  commissions.  Failure to include the Surrogate Line Sharing Charges in the interconnection
  agreement would be inconsistent with the text of the Merger Conditions and could impair the
  ability of unaffiliated third parties to exercise their rights under the SBC/Ameritech Merger
  Order and the Commission's rules.  
       
       Please do not hesitate to contact me if I can be of further assistance.  You may also
  contact Anthony Dale in the Common Carrier Bureau directly at (202) 418-2260 for further
  information on this matter.
  
  
                                Sincerely,
  
                 
                                Lawrence E. Strickling
                           Chief, Common Carrier Bureau