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  Enforcement Bureau, Investigations and Hearings Division
             445 12th Street, S.W., Room 3-B443
                   Washington, D.C. 20554

                        July 2, 2002

Caryn D. Moir
Vice President - Federal Regulatory
SBC Telecommunications, Inc.
1401 I Street, NW
Suite 400
Washington, DC 20005-2296
fax 202-408-4809

     RE:  Section 271 Compliance Review Program for Arkansas 
and Missouri

Dear Ms. Moir:

     1.   As you know, on November 16, 2001, the Commission 
granted SBC's application to provide in-region interLATA 
toll service in Arkansas and Missouri pursuant to section 
271 of the Communications Act of 1934, as amended (``the 
Act'').  See Joint Application by SBC Communications Inc., 
Southwestern Bell Telephone Company, and Southwestern Bell 
Communications Services, Inc. d/b/a Southwestern Bell Long 
Distance Pursuant to Section 271 of the Telecommunications 
Act of 1996 to  Provide In-Region, InterLATA Services in 
Arkansas and Missouri, 16 FCC Rcd 20719 (2001) (``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 Arkansas and 
Missouri.  The primary team members responsible for this 
review are David Janas, Attorney; Austin O'Connor, Auditor; 
and Andrew Skadin, Auditor.
     3.   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 two phases.
     5.   Phase 1:  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 
twelve months after the approval date (i.e., November 16, 
2002).  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.
     7.   Phase 2:  The second 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.
     9.   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.
     11.  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 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 
     14.  Sincerely,
     18.  Maureen F. Del Duca
     19.  Deputy Chief, Investigations and Hearings Division
     20.  Enforcement Bureau                         Attachment
            Section 271 Compliance Review Program
                 SBC: Arkansas and Missouri
      Commission Identified Compliance Review Subjects1

I.   Checklist Item 1:  Interconnection
     I.A.      Collocation (See Order, paragraph 86)
     I.B.      Installation (See Order, paragraph 87)
     I.C.      Point of Interconnection (See Order, 
     paragraph 88)
     I.D.      Pricing (See Order, paragraphs 92-96)
II.  Checklist Item 2:  Unbundled Network Elements
     II.A.     Access to OSS
          II.A.1.   Data Reliability (See Order, paragraphs 
          II.A.2.   Maintenance and Repair/LMOS (See Order, 
          paragraphs 22-36)
          II.A.3.   Pre-Ordering (See Order, paragraph 37)
          II.A.4.   Ordering
               II.A.4)a.      Order Confirmation Notices 
               (See Order, paragraph 39)
               II.A.4)b.      Order Rejection Notices (See 
               Order, paragraph 40)
               II.A.4)c.      Order Flow-Through Rate (See 
               Order, paragraphs 41-43)
          II.A.5.   Provisioning (See Order, paragraph 44)
          II.A.6.   Billing (See Order, paragraphs 45-46)
          II.A.7.   OSS of Advanced Services Affiliate (See 
          Order, paragraph 47)
     II.B.     Pricing of UNEs
          II.B.1.   Recurring Charges (See Order, paragraphs 
          II.B.2.   Nonrecurring Charges (See Order, 
          paragraphs 71-75)
     II.C.     Provision of UNE Combinations (See Order, 
     paragraphs 76-77)
III.      Checklist Item 4:  Unbundled Local Loops
     III.A.    xDSL-Capable Loops (See Order, paragraphs 
     III.B.    Hot Cuts (See Order, paragraph 102)
     III.C.    Voice Grade Loops (See Order, paragraph 103) 
     III.D.    Line Sharing (See Order, paragraphs 104-05)
     III.E.    Line Splitting (See Order, paragraph 106)
     III.F.    High Capacity Loops (See Order, paragraphs 
     III.G.    Disconnecting IDSL (See Order, paragraph 110)
IV.  Checklist Item 6:  Switching (See Order, paragraphs 
V.   Checklist Item 13:  Reciprocal Compensation (See Order, 
     paragraphs 114-15)
VI.  Checklist Item 14:  Resale (See Order, paragraphs 78-

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 Order or in this Attachment.