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Mr. Gary Phillips
General Attorney & Assistant General Counsel
SBC Communications Legal Department
1401 I Street, N.W., Suite 1100
Washington, D.C. 20005

RE:  Section 271 Compliance Review Program for California

Dear Mr. Phillips :

     As you know, the Commission recently granted SBC's 
application to provide in-region interLATA toll service in 
California pursuant to section 271 of the Communications Act of 
1934, as amended (``the Act'').  See In the Matter of Application 
by SBC Communications, Inc., Pacific Bell Telephone Company, and 
Southwestern Bell Communications Services Inc., for Authorization 
to Provide In-Region InterLATA Services in California, WC Docket 
No. 02-306, FCC 02-330 (rel. December 19, 2002) (``Order'').  The 
Enforcement Bureau (``the Bureau''), therefore, will now monitor 
SBC's continuing compliance with section 271 through the Section 
271 Compliance Review Program.  This program is based on a 
structured and systematic approach to compliance review and 
enforcement.  The Bureau has assigned a team of auditors, 
attorneys, and other professional staff from the Investigations 
and Hearings Division (``Compliance Review Team'' or ``Team'') to 
work with SBC through the duration of the review and to monitor 
SBC's performance in California.  The primary team members 
responsible for this review are Gary Schonman, Attorney and 
Constance Hellmer, Auditor.

     During the review, the Team will closely review SBC's 
performance in subject matter areas that the Commission has 
identified as areas of concern in the section 271 Order.  In this 
regard, we have enclosed with this letter an attachment listing 
the specific performance measures and other areas about which the 
Commission expressed its concern in the Order.  Although the 
Bureau will focus its review on these areas, it may also monitor 
other areas not noted by the Commission in the Order.  Generally, 
the Bureau's review will occur in three phases.

     Phase 1:  The Phase 1 review will occur during the first six 
months following the section 271 grant.  Within the next few 
days, a representative from the Bureau will contact SBC to 
schedule a planning meeting with SBC representatives and the Team 
overseeing the review.  The purpose of this meeting is to provide 
SBC with the opportunity to participate in developing the Review 
Program and to assist the Bureau in selecting the type and format 
of information pertaining to SBC's performance that the Team will 
review.  SBC should be prepared to discuss the areas of concern 
that the Commission noted in the 271 Order (also listed in the 
attachment to this letter) and to identify knowledgeable 
employees, applicable corporate records, and computer systems 
related to these areas.  Following this meeting, the Team will 
send a follow-up letter to SBC memorializing the discussions at 
the meeting and describing the information SBC is responsible for 
submitting to the Bureau approximately six months after the 
approval date (i.e., June 19, 2003).  The Team will also continue 
to monitor SBC's performance during Phase 1 through the monthly 
carrier to carrier performance reports the Commission's Order 
required SBC to submit.

     Phase 2:  The second phase will proceed similarly to the 
first but will occur during the second six-month period after the 
grant.  Specifically, the Team will send another request for 
information to SBC.  The information responsive to this request 
will be due at the end of this period (approximately December 19, 
2003).  At that time, the Bureau will require SBC to update 
information it already submitted and to provide additional 
information concerning its continuing performance in California.  
Also, as in Phase 1, the Team will continue to monitor SBC's 
performance through the carrier to carrier reports.  The Team 
will not limit its review in Phase 2 to performance data or 
information from only the second six-month period; rather, when 
evaluating the need for any further action, the Team will 
consider all of the post-authorization data and information.

     Phase 3:  The third phase of the review will begin after SBC 
submits the information the Team required in Phase 2 and will 
consist of less formal contacts and inquiries by the Bureau.

     At any time during this review, the Team may ask SBC to 
provide additional information or to attend additional meetings 
with SBC employees who have expertise in specific subject 
matters.  These additional inquiries may supplement existing 
requests or may encompass new inquiries.

     Finally, SBC should provide to the team at the initial 
meeting during Phase 1 the names and contact information of 
employees who are authorized to respond to requests for 
information on behalf of the corporation.  If you have any 
general questions concerning the issues raised in this letter, 
please feel free to contact me at (202) 418-1420.  You may also 
contact William Davenport, Assistant Chief, Investigations and 
Hearings Division at (202) 418-1034 or Trent Harkrader, Section 
271 Compliance Review Program Team Leader at (202) 418-2955.  
Thank you in advance for your cooperation.


                              Maureen F. Del Duca
                              Deputy Chief, Investigations and 
                         Hearings Division
                              Enforcement Bureau

Cc:  Becky Sparks
     Executive Director - Federal Regulatory