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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 Alabama, 
          Kentucky, Mississippi, North Carolina, and South 
          Carolina

Dear Mr. Banks:

     As you know, the Commission recently granted BellSouth's 
application to provide in-region interLATA toll service in 
Alabama, Kentucky, Mississippi, North Carolina, and South 
Carolina 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 Alabama, Kentucky, Mississippi, North 
Carolina, and South Carolina, WC Docket No. 02-150, Memorandum 
Opinion and Order, FCC 02-260 (rel. Sept. 18, 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 Alabama, 
Kentucky, Mississippi, North Carolina, and South Carolina.  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.  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., February 
18, 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 
August 18, 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 Alabama, Kentucky, Mississippi, North Carolina, 
and South Carolina.  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 
information.

     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 
Bureau.

     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.


                              Sincerely,



                              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: Alabama, Kentucky, Mississippi, North Carolina, and 
                         South Carolina
        Commission Identified Compliance Review Subjects1

I.   Data Reliability (See 5 State Order (``Order''), paragraphs 
     13-19)
II.  Checklist Item 1:  Interconnection
     II.A.     Outages (See Order, paragraph 216)
     II.B.     Pricing (See Order, paragraph 227)
III.      Checklist Item 2:  Unbundled Network Elements
     III.A.    Change Control Process and Adherence to Process 
     (See Order, paragraph 179)
     III.B.    OSS
          III.B.1.  Pre-ordering
               III.B.1)a.     Interface Slowdowns/Outages (See 
               Order, paragraph 137)
          III.B.2.  Ordering
               III.B.2)a.     FOC and Reject Notice Timeliness 
               (See Order, paragraphs 145, 148, 149)
               III.B.2)b.     Order Flow-Through (See Order, 
               paragraph 152)
               III.B.2)c.     Jeopardy Notices (See Order, 
               paragraph 158)
               III.B.2)d.     Service Order Accuracy (See Order, 
               paragraphs 159)
               III.B.2)e.     DSL Universal Service Order Code 
               (See Order, paragraphs 162-63)
               III.B.2)f.     Ordering for Line Shared Loops (See 
               Order, paragraph 166)
               III.B.2)g.     Dial Around Compensation (See 
               Order, paragraph 168)
          III.B.3.  Provisioning
               III.B.3)a.     Quality Service Problems (See 
               Order, paragraph 170)
          III.B.4.  Maintenance and Repair
               III.B.4)a.     Trouble Report Rates (See Order, 
               paragraph 173)
          III.B.5.  Billing
               III.B.5)a.      Invoice Accuracy, Timeliness, 
               Completeness (See Order, paragraphs 174-75)
          III.B.6.  UNE Combos
               III.B.6)a.     Timely Access to EELS (See Order, 
               paragraph  211)
IV.  Checklist Item 4:  Unbundled Loops
     IV.A.     xDSL and UCL-ND Loops (See Order, paragraph 236-
     37)
     IV.B.     ISDN Loops (See Order, paragraph 239)
     IV.C.     High Capacity Loops (See Order, paragraph 237)
V.   Checklist Item 11:  Number Portability
     V.A.      Double Billing (See Order, paragraph 262)
     V.B.      Loss of Inbound Calling (See Order, paragraph 263)
VI.  Public Interest
     VI.A.     BSLD Rejection of CLEC LSR's (See Order, paragraph 
     298)
     VI.B.     Premature Long Distance Marketing (See Order, 
     paragraphs 299-301)
_________________________

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 5 State Order or in this 
Attachment.