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Mr. Gordon R. Evans
Vice President - Federal Regulatory
Verizon Communications, Inc.
1300 I St., N.W.
Suite 400 West
Washington, DC 20005

RE:  Section 271 Compliance Review Program for Section 271-
     Approved 
     States in the Verizon Region

Dear Mr. Evans:

     Since passage of the Telecommunications Act of 1996, the 
Commission has granted Verizon authorization, pursuant to section 
271, to provide interLATA services in eight states within its 
region - New York, Massachusetts, Connecticut, Pennsylvania, Rhode 
Island, Vermont, Maine and New Jersey.  The Enforcement Bureau 
(``the Bureau'') will monitor Verizon's continuing compliance with 
section 271 in each of these states 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 Verizon 
through the duration of the review and to monitor Verizon's 
performance in the states where it has received section 271 
approval.  The primary team members responsible for this review 
are Mark Stone, Attorney, and Jeff Stover, Auditor, for the former 
Bell Atlantic north states1; and Raelynn Tibayan Remy, Attorney, 
and Sheryl Herauf, Auditor, for the former Bell Atlantic south 
states.2

     During the review, the Team will closely review Verizon'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.3
     Phase 1:  The Phase 1 review will occur during the first six 
months following the section 271 grant.4  Shortly after the grant 
of approval, a representative from the Bureau will contact Verizon 
to schedule a planning meeting with Verizon representatives and 
the Team overseeing the review.  The purpose of this meeting is to 
provide Verizon with the opportunity to participate in developing 
the Review Program and to assist the Bureau in determining the 
type and format of information pertaining to Verizon's performance 
that the Team will review.  

     At the meeting, Verizon should be prepared to discuss the 
areas of concern that the Commission noted in the section 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.  Verizon should also 
provide to the Team the names and contact information of employees 
who are authorized to respond to requests for information on 
behalf of the corporation.  Following the meeting, the Team will 
send a follow-up letter to Verizon memorializing the discussions 
at the meeting and describing the information Verizon is 
responsible for submitting to the Bureau approximately six months 
after the approval date.  The Team will also continue to monitor 
Verizon's performance during Phase 1 through the monthly carrier-
to-carrier performance reports the Commission's Orders required 
Verizon to submit.

     Phase 2:  The Phase II review will occur during the second 
six-month period after the grant.  This phase of the review 
contemplates the issuance of a request for information directing 
Verizon to update information submitted previously, and to provide 
additional information concerning its performance since the Phase 
I review.  The information responsive to this request will be due 
at the end of the Phase II review period.  As in Phase 1, the Team 
will also continue to monitor Verizon's performance through the 
carrier-to-carrier reports.  The Team will not limit its review in 
Phase 2 to performance data or information derived 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 
Verizon submits the information the Team required in Phase 2.

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

Former Bell Atlantic-North State                                 
Page

Massachusetts                                               A-1

Connecticut                                                 A-2

Rhode Island                                                A-3

Vermont                                                A-4

Maine                                                       A-5


Former Bell Atlantic-South State                                 
Page

Pennsylvania                                                B-1

New Jersey                                                  B-2
                          Massachusetts
        Commission Identified Compliance Review Subjects5

I.   Checklist Item 2:  Unbundled Network Elements
     I.A.      Access to OSS
          I.A.1.    Pre-Ordering Functionality, Integration, 
          Response Times and Availability (Order at  52-53)
          I.A.2.    Access to Loop Qualification Information 
          (Order at  54-69)
          I.A.3.    Ordering
               I.A.3)a.  Ordering Confirmation Notices (Order at 
                71-73)
               I.A.3)b.  Order Rejection Notices and Order 
               Rejections (Order at  74-76)
               I.A.3)c.  Order Flow-Through Rate (Order at  77-
               82)
               I.A.3)d.  Order Completion Notices and Jeopardy 
               Information (Order at  83-86)
               I.A.3)e.  Ordering Notifiers and the New York 
               Consent Decree (Order at  87-89)
          I.A.4.    Provisioning
               I.A.4)a.  Resale Orders (Order at  91-93)
               I.A.4)b.  UNE-P Orders (Order at  94)
          I.A.5.    Maintenance and Repair
               I.A.5)a.  Functionality (Order at  95)
               I.A.5)b.  Interface Response Times, Time to Restore 
               and Quality of Work Performed (Order at  96)
          I.A.6.    Billing
               I.A.6)a.  Billing Accuracy (Order at  97-99)
               I.A.6)b.  Line Loss Reports (Order at  100)
               I.A.6)c.  Suspension for Non-Payment (Order at  
               101)
          I.A.7.    Change Management and Technical Assistance 
          (Order at  102-116)
     I.B.      UNE Combinations (Order at  117-120)

II.  Checklist Item 4: Unbundled Local Loops
     II.A.     xDSL-Capable Loops
          II.A.1.   Order Processing Timeliness (Order at  132-
          135)
          II.A.2.   Provisioning Timeliness (Order at  136-141)
          II.A.3.   Provisioning Quality (Order at  142-148)
          II.A.4.   Maintenance and Repair (Order at  149-153)
     II.B.     Subloops (Order at  154-155)
     II.C.     High Capacity Loop Performance (Order at  156)
     II.D.     Voice Grade Loops 
          II.D.1.   Hot Cuts (Order at  158-160)
          II.D.2.   New Stand-Alone Loop Provisioning (Order at  
          161-162)                             Connecticut
        Commission Identified Compliance Review Subjects6

I.   Checklist Item 4:  Unbundled Local Loops

     I.A.      xDSL Stand-Alone Loops 
          I.A.1.    Provisioning Timeliness (See Connecticut Order 
          (``Order'') at  16-20)
          I.A.2.    Provisioning Quality (Order at  16-20) 
          I.A.3.    High Capacity Loops (Order at  26)

     I.B.      Checklist Item 14:  Resale
          I.B.1.    Compliance with ASCENT decision (Order at  
          27-44)                            Rhode Island
        Commission Identified Compliance Review Subjects7

I.   Checklist Item 2:  Unbundled Network Elements
     I.A.      Pricing of Network Elements
          I.A.1.    Switch Rates (See Rhode Island Order 
          (``Order'') at  33-55)
          I.A.2.    Loop Rates (Order at  56-57)
     I.B.      OSS
          I.B.1.    Pre-ordering - Loop Qualification (Order at  
          61-65)
          I.B.2.    Ordering
               I.B.2)a.  Order Reject Notices/Rejects (Order at  
               66)
               I.B.2)b.  Jeopardies (Order at  67-68)
          I.B.3.    Provisioning - Average Interval Completed 
          (Order at  69-70)

II.  Checklist Item 4:  Unbundled Local Loops
     II.A.     xDSL Loops - Trouble Reports for Standalone Loops 
     (Order at  78-79)
     II.B.     Digital Loops 
          II.B.1.   Installation Troubles (Order at  80-81)
          II.B.2.   Repeat Troubles (Order at  80-81)
     II.C.     Voice-Grade Loops 
          II.C.1.   Repeat Trouble Reports (Order at  85)
          II.C.2.   Provisioning Timeliness (Order at  86)
     II.D.     High Capacity Loops - Provisioning Quality (Order 
     at  87-88)

III.      Checklist Item 5:  Transport
     III.A.    Dark Fiber (Order at  93)

IV.  Checklist Item 14:  Resale
     IV.A.     ASCENT Decision (Order at  94-97)
                              Vermont
        Commission Identified Compliance Review Subjects8

I.   Checklist Item 2:  Unbundled Network Elements

     I.A.      Pricing
          I.A.1.    Switching Rates (Order at  28-36)
          I.A.2.    Daily Usage Feed Rates (Order at  37-38) 

     I.B.      OSS
          I.B.1.    Order Accuracy (Order at  41)
          I.B.2.    Completion Notifiers (Order at  42)
          I.B.3.    Provisioning (Order at  43)

     I.C.      UNE Combinations (Order at  44)                               Maine 
        Commission Identified Compliance Review Subjects9

I.   Checklist Item 2:  Unbundled Network Elements

     I.A.      Pricing of Network Elements
          I.A.1.    DUF Rate (See Maine Order (``Order'') at  
          22-25)
          I.A.2.    Switching Rates (Order at  26-30)

     I.B.      OSS
          I.B.1.    Order Accuracy (Order at  37-38)
          I.B.2.    Flow-Through (Order at  39-40)

     I.C.      Billing (Order at  41)

     I.D.      UNE Combinations (Order at  42-43)

II.  Checklist Item 4:  Unbundled Local Loops

     II.A.     xDSL Loops 
          II.A.1.   Percentage of Installation Troubles (Order at 
           47)
          II.A.2.   Network Trouble Report Rate (Order at  47)

     II.B.     Digital Loops
          II.B.1.   Installation Troubles Reported (Order at  48)
          II.B.2.   Network Trouble Report Rate (Order at  48-49)

     II.C.     High Capacity Loops
          II.C.1.   Network Trouble Report Rate (Order at  50)
          II.C.2.   Digital Loops 
          II.C.3.   Installation Troubles (Order at  80-81)
          II.C.4.   Repeat Troubles (Order at  80-81)

     II.D.     Voice-Grade Loops 
          II.D.1.   Repeat Trouble Reports (Order at  85)
          II.D.2.   Provisioning Timeliness (Order at  86)

     II.E.     High Capacity Loops - Provisioning Quality (Order 
     at  87-88)




                                Pennsylvania
             Commission-Identified Compliance Review Subjects10


          I.   Checklist Item 2:  Unbundled Network Elements
               A.   OSS
                    1.   Billing 
                         a.   Service Usage (See Pennsylvania 
                              Order (``Order``) at  14)
                         b.   Wholesale Bills (Order at  15-42)
                    2.   Billing Notifiers (Order at  43-44)
                    3.   Access to Loop Qualification Information 
                         (Order at  45-47)
                    4.   Flow-Through (Order at  48-49)
               B.   Pricing of Network Elements (Order at  53-
               72)
               C.   Provision of UNE Combinations (Order at  73-
               75)

          II.  Checklist Item 4:  Unbundled Local Loops
               II.A.     xDSL-Capable Loops (Order at  79-84)
               II.B.     Digital Loops (Order at  85)
               II.C.     Hot Cut Activity (Order at  86)
               II.D.     Voice Grade Loops (Order at  87)
               II.E.     Line Sharing (Order at  88)
               II.F.     Line Splitting (Order at  89)
               II.G.     High Capacity Loops (Order at  90-92)

          III. Checklist Item 5:  Unbundled Local Transport (Order 
          at  109-113)

          IV.  Checklist Item 14:  Resale (Order at  93-98)













                              New Jersey
          Commission-Identified Compliance Review Subjects11


     I.   Checklist Item 2:  Unbundled Network Elements
          I.A.      Pricing of Unbundled Network Elements
               1.   Recurring Charges
                    a.   Loop Rates (See New Jersey Order 
               (``Order'') at  25-31)
                    b.   Switching Rates (Order at  32-55)
                    c.   Daily Usage File (DUF) Rates (Order at  
               56-60)
               2.   Non-Recurring Charges (Order at  61-73)    
                    a.   ``Hot Cut'' Charges (Order at  61-68)
                    b.   Feature Change Service Order Charge 
               (Order at  69-73)
          B.   OSS
               1.   Order Processing Notifiers (Order at  93-97)
                    a.   Timeliness of Confirmation and Reject 
                         Notices (Order at  98-101)
                    b.   Order Completion Notifiers 
                         1)   Accuracy of Order Completion 
                              Notifiers (Order at  103-109)
                         2)   Timeliness of Order Completion 
                              Notifiers (Order at  110-117)
                         3)   Notifier Trouble Tickets (Order at 
      118-120)
               2.   Wholesale Billing (Order at  121-129)
               3.   Order Flow-Through and Reject Rate (Order at 
      130-134)
     II.  Checklist Item 4:  Unbundled Local Loops
          A.   Voice Grade Loops (Order at  139-141)
          B.   Hot Cut Activity (Order at  142-143)
          C.   xDSL-Capable Loops (Order at  144-145)
          D.   Digital Loops (Order at  146-147)
          E.   High Capacity Loops (Order at  148-151)
          F.   Line Sharing and Line Splitting (Order at  152-
     153) 

                    



 
_________________________

1    Those states include New York, Massachusetts, Connecticut, 
Rhode Island, Vermont, Maine and New Hampshire.  We note that 
Verizon's section 271 application to provide interLATA services 
originating in New Hampshire is pending.
2    Those states include Pennsylvania, New Jersey, Delaware, 
Maryland, Virginia, West Virginia, and the District of Columbia.  
We note that Verizon's section 271 application to provide 
interLATA services originating in Delaware is pending.
3    We note that Verizon received section 271 approval in some 
states - New York, Massachusetts, and Connecticut - more than 
twelve months ago.  Consequently, Verizon's post-approval 
performance in these states will generally not be considered in 
the context of the Compliance Review phases outlined above.  
Rather, the Bureau will arrange a meeting with Verizon to review 
areas of concern in each of these states as discussed in the 
relevant section 271 decisions.  

4    States (such as Pennsylvania) in which Verizon received 
section 271 approval within the last six to twelve month period 
will be folded into the Compliance Review Program at Phase II.
5    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 Massachusetts Order or in 
this Attachment.

                               A-1
6    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 Connecticut Order or in 
this Attachment.

                               A-2
7    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 Rhode Island or in this 
Attachment.

                               A-3
8    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 Vermont Order or in this 
Attachment.

                               A-4
9    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 Maine Order or in this 
Attachment.

                               A-5
10   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 Pennsylvania Order or in 
this Attachment.


                               B-1
11   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 New Jersey Order or in 
this Attachment.


                               B-2