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Mr. Gerald Asch
Director - Federal Regulatory
Verizon Communications, Inc.
1300 I Street, N.W.
Suite 400 West
Washington, D.C.   20005

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

Dear Mr. Asch:

     Since passage of the Telecommunications Act of 1996, the 
Commission has granted Verizon authorization, pursuant to section 
271, to provide interLATA services in eleven states within its 
region - New York, Massachusetts, Connecticut, Pennsylvania, 
Rhode Island, Vermont, Maine, New Jersey, New Hampshire, 
Delaware, and Virginia.  On July 2, 2002, we sent you a letter 
regarding the Enforcement Bureau's Section 271 Compliance Review 
Program for the eight states approved at that time.1  We now 
include the three recently approved states -- New Hampshire, 
Delaware, and Virginia -- in that program.2

     The Enforcement Bureau (``the Bureau'') will monitor 
Verizon's continuing compliance with section 271 in each approved 
state.  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 Dana 
Leavitt, Attorney, and Jeff Stover, Auditor, for the former Bell 
Atlantic North states3; and Raelynn Tibayan Remy, Attorney, and 
Sherry Herauf, Auditor, for the former Bell Atlantic South 
states.4

     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 each 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 concern in its decisions covering 
New Hampshire, Delaware, and Virginia.  Although the Enforcement 
Bureau will focus its review on these areas, it may also monitor 
other areas not noted by the Commission in its orders.  
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.  Following Verizon's 
receipt of this letter, a representative from the Bureau will 
contact the company to schedule a planning meeting or conference 
call 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.

     Phase 2:  The Phase II review will occur during the second 
six-month period after the grant.  This phase of the review could 
include the issuance of a request for information directing 
Verizon to update information submitted previously, or to provide 
additional information concerning its performance since the Phase 
I review.  The information responsive to such a request will be 
due at the end of the Phase II review period.  As in Phase I, 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 information the Team may have required in Phase 
2.

     At any time during this review, the Team may ask Verizon to 
provide additional information or to attend meetings or 
conference calls 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 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.

                                   Sincerely,




                                   Maureen F. Del Duca
                                   Acting Division Chief
                                   Investigations and Hearings 
                              Division
                                   Enforcement Bureau
                          New Hampshire
        Commission Identified Compliance Review Subjects5


I.   Checklist Item 2:  Unbundled Network Elements
     A.   Pricing of Unbundled Network Elements (See Verizon New 
       Hampshire/Delaware Order at  34-65)
     B.   Operations Support Systems
       1. Order Processing Notifiers (id. at  99-101)
       2. Flow-through (id. at  102)
       3. Billing Accuracy (id. at  103)
II.  Checklist Item 4:  Unbundled Local Loops
     A.   High Capacity Loops (id. at  112-114)
     B.   Digital Loops (id. at  116-117)
     C.   Dark Fiber (id. at  118-122)
                            Delaware
        Commission Identified Compliance Review Subjects6


I.   Checklist Item 2:  Unbundled Network Elements
     A.   Pricing of Unbundled Network Elements
       1.  Switching Rates (See Verizon New Hampshire/Delaware 
       Order at  74-80)
       2.  Loop Rates (id. at  81)
       3.  Non-Recurring Charges (id.  at  82-92)

II.  Checklist Item 4:  Unbundled Local Loops
     A.   Voice-Grade Loops (id at  108-110)
     B.   Hot Cut Activity (id at  111)  
     C.   Digital Loops (id at  115)                            Virginia
        Commission Identified Compliance Review Subjects7

I.   Checklist Item 2:  Unbundled Network Elements
     A.   OSS
       1.  Pre-Ordering - Loop Qualification Information (See 
          Verizon Virginia Order at  28-37)
       2.  Wholesale Billing 
          a.  Complete, Accurate and Auditable Carrier Bills (id 
          at  41-47)
          b.  Double Billing (id at  48)
          c.  Billing Dispute Resolution (id at  49-52)
          d.  Other Billing Issues (id at  53-55)
       3.  Change Management (id at  56-58)
     B.   UNE Combinations (id at  59-61)
     C.   Pricing of Unbundled Network Elements
       1.  Recurring Loop Rates (id at  90-95)
       2.  Recurring Non-Loop Rates (id at  96-121)
       3.  Non-Recurring Charges (id at  122-131)
       4.  Entrance Facility Rate (id at  132-133)

 II.     Checklist Item 4:  Unbundled Local Loops
     A.   High Capacity Loops (id. at  140-144)
     B.   Dark Fiber (id. at  145-147)
     C.   Voice Grade Loops (id. at  148)
     D.   xDSL Loops (id. at  149)
     E.   Other Loop Issues (id. at  150)
     F.   Line Sharing and Line Splitting (id. at  151)

III.      Checklist Item 8:  White Pages
     A.   Processing Errors (id. at  155-166)
     B.   Use of Listing Verification Process (id at  167-168)
     C.   Alpha/Numeric Listing Identifiers (id at  169-170)
_________________________

1 See Letter from Maureen F. Del Duca, Deputy Chief, 
Investigations and Hearings Division, Enforcement Bureau, to 
Gordon R. Evans, Vice President, Federal Regulatory, Verizon, 
dated July 2, 2002 (``July 2, 2002 Letter'').
2 See Application by Verizon-New England, Inc., et al., for 
Authorization to Provide In-Region, InterLATA Services in New 
Hampshire and Delaware, Memorandum Opinion and Order, FCC 02-262 
(rel. Sept. 25, 2002) (``Verizon New Hampshire/Delaware Order''); 
Application by Verizon Virginia Inc., et al., for Authorization 
to Provide In-Region, InterLATA Services in Virginia, Memorandum 
Opinion and Order, FCC 02-297 (rel. Oct. 30, 2002) (``Verizon 
Virginia Order'').  
3    Those states include New York, Massachusetts, Connecticut, 
Rhode Island, Vermont, Maine, and New Hampshire.  We note that 
all of the states in the former Bell Atlantic North region have 
now received section 271 approval.

4    Those jurisdictions include Pennsylvania, New Jersey, 
Delaware, Maryland, Virginia, West Virginia, and the District of 
Columbia.  
5    The Bureau may monitor for enforcement purposes other 
subjects or performance indicators not expressly noted by the 
Commission in the Verizon New Hampshire/Delaware Order or this 
letter.
6    The Bureau may monitor for enforcement purposes other 
subjects or performance indicators not expressly noted by the 
Commission in the Verizon New Hampshire/Delaware Order or this 
letter.
7    The Bureau may monitor for enforcement purposes other 
subjects or performance indicators not expressly noted by the 
Commission in the Verizon Virginia Order or this letter.