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Jonathan Banks
General Counsel-BellSouth D.C.
1133  21st Street, N.W., Suite 900
Washington, D.C.  20036-3351
Fax (202) 463-4141

     RE:  Section 271 Compliance Review Program for Georgia and 

Dear Mr. Banks:

     As you know, the Commission recently granted BellSouth's 
application to provide in-region interLATA toll service in 
Georgia and Louisiana pursuant to section 271 of the 
Communications Act of 1934, as amended (``the Act'').  See Joint 
Application by BellSouth Corporation, BellSouth 
Telecommunications, Inc., and BellSouth Long Distance, Inc. for 
Provision of In-Region, InterLATA Services in Georgia and 
Louisiana, CC Docket No. 02-35, Memorandum Opinion and Order, FCC 
02-147 (rel. May 15, 2002) (``Order'').  The Enforcement Bureau 
(``the Bureau''), therefore, will now monitor BellSouth'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 BellSouth 
through the duration of the review and to monitor BellSouth's 
performance in Georgia and Louisiana.  The primary team members 
responsible for this review are Hillary DeNigro, Attorney and 
Mark Gerner, Auditor.

     During the review, the Team will closely review BellSouth'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 BellSouth to 
schedule a planning meeting with BellSouth representatives and 
the Team overseeing the review.  The purpose of this meeting is 
to provide BellSouth 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 
BellSouth's performance that the Team will review.  BellSouth 
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 BellSouth memorializing the discussions at 
the meeting and describing the information BellSouth is 
responsible for submitting to the Bureau approximately six months 
after the approval date (i.e., December 2, 2002).  The Team will 
also continue to monitor BellSouth's performance during Phase 1 
through the monthly carrier to carrier performance reports the 
Commission's Order required BellSouth 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 BellSouth.  The information responsive to this 
request will be due at the end of this period (approximately June 
3, 2003).  At that time, the Bureau will require BellSouth to 
update information it already submitted and to provide additional 
information concerning its continuing performance in Georgia and 
Louisiana.  Also, as in Phase 1, the Team will continue to 
monitor BellSouth'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 

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

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

     Finally, BellSouth 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 Anthony Dale, Assistant Chief, Investigations and 
Hearings Division at (202) 418-2260 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: Kathleen B. Levitz
Vice President - Federal Regulatory                           Attachment
              Section 271 Compliance Review Program
                BellSouth: Georgia and  Louisiana
        Commission Identified Compliance Review Subjects1

I.   Data Reliability (See Georgia/Louisiana Order (``Order''), 
     paragraph 20)
II.  Checklist Item 1:  Interconnection
     II.A.     Quality (See Order, paragraphs 202-203)
     II.B.     Timeliness (See Order, paragraph 204)
III.      Checklist Item 2:  Unbundled Network Elements
     III.A.    Adherence to Change Management (See Order, 
     paragraph 195)
     III.B.    OSS
          III.B.1.  Pre-ordering
               III.B.1)a.     Interface Slowdowns/Outages (See 
               Order, paragraph 118)
               III.B.1)b.     Access to Due Dates (See Order, 
               paragraph 134)
               III.B.1)c.     Pre-Ordering/Ordering Integration, 
               TN Migration and Parsed CSRs (See Order, 
               paragraphs 123-130)
               III.B.1)d.     Access to Loop Qualification 
               Information (See Order, paragraph 112-116)
          III.B.2.  Ordering
               III.B.2)a.     Order Confirmation and Reject 
               Notice Timeliness (See Order, paragraph142)
               III.B.2)b.     Order Flow-Through (See Order, 
               paragraph 146)
               III.B.2)c.     Electronic Ordering Capability (See 
               Order, paragraphs 149-150)
               III.B.2)d.     Jeopardy Notices (See Order, 
               paragraph 156)
               III.B.2)e.     DSL Universal Service Order Code 
               and Phantom Universal Service Order Code (See 
               Order, paragraph 158)
               III.B.2)f.     Service Order Accuracy (See Order, 
               paragraphs 159-161)
               III.B.2)g.     Line Loss Notification Reports (See 
               Order, paragraph 163)
          III.B.3.  Provisioning
               III.B.3)a.     Product Mix/EELs (See Order, 
               paragraph 166)
               III.B.3)b.     Quality Service Problems (See 
               Order, paragraph 167)
          III.B.4.  Maintenance and Repair
               III.B.4)a.     Functionality (See Order, 
               paragraphs 170-171)
               III.B.4)b.     Time To Restore/Quality of Work 
               (See Order, paragraph 172)
          III.B.5.  Billing (See Order, paragraphs 173-178)
IV.  Checklist Item 4:  Unbundled Loops
     IV.A.     Voice Grade Loops
          IV.A.1.   Order Completion Interval (See Order, 
          paragraph 224)
          IV.A.2.   Missed Repair Appointment Metric (See Order, 
          paragraph 225)
     IV.B.     xDSL Capable Loops--Maintenance and Repair (See 
     Order, paragraph 229)
     IV.C.     High Capacity Loops--Installation Quality Measure 
     (See Order, paragraph 233)
V.   Checklist Item 11:  Number Portability
     V.A.      Loss of Inbound Calling (See Order, paragraph 261)
     V.B.      Double Billing (See Order, paragraph 262)

1    Consistent with the representation in the letter pertaining 
to the scope of the Bureau's review, the Bureau may monitor for 
enforcement purposes other subjects or performance indicators not 
expressly noted by the Commission in the Georgia/Louisiana Order 
or in this Attachment.