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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 all of the states within 
its region - New York, Massachusetts, Connecticut, Pennsylvania, 
Rhode Island, Vermont, Maine, New Jersey, New Hampshire, 
Delaware, Virginia, West Virginia, Maryland and Washington, D.C.  
On July 2, 2002 and January 23, 2003, we sent Verizon letters 
regarding the Enforcement Bureau's Section 271 Compliance Review 
Program for the eleven states approved at that time.1  We now 
include the three recently approved states - Maryland, Virginia 
and the District of Columbia -- 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 Trent 
Harkrader, Attorney, and Jeff Stover, Auditor, for the former 
Bell Atlantic North states3; and Raelynn Tibayan Remy, Attorney, 
Andrew Skadin, Auditor, and Austin O'Connor, Auditor, for the 
former Bell Atlantic South states.4

     During the review, the Team will closely monitor 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 decision covering 
Maryland, Washington, D.C. and West 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 

     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 

     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 


                                   Maureen F. Del Duca
                                   Chief, Investigations and 
Hearings Division
                                   Enforcement Bureau
            Maryland, Washington, D.C., West Virginia
        Commission Identified Compliance Review Subjects5

I.   Checklist Item 2:  Unbundled Network Elements
     A.   Operations Support Systems
       1. Ordering (Verizon MD/DC/WVA Order at  21-24)
       2. Provisioning (id. at  25)
       3. Wholesale Billing (id. at  26-34)
       4. Maintenance and Repair (id. at  35-36)
       5. UNE Combinations (id. at  37-38)
     B.  Pricing (id. at  39-96)
II.    Checklist Item 12:  Dialing Parity (id. at  97-101)
III.        Checklist Item 1:  Interconnection (id. at  102-
IV.    Checklist Item 4:  Unbundled Local Loops
       IV.A.   xDSL Loops, Digital Loops, Voice Grade Loops, and 
          Hot Cuts (id. at  121)
       IV.B.   High-Capacity Loops (id. at  122)
       IV.C.   Dark Fiber (id. at  123-126)
V.   Checklist Item 7:  911-E911 Access and Directory 
     Assistance/Operator Services (id. at  127-128)
VI.  Checklist Item 8:  White Pages (id. at  129-137)
VII.      Checklist Item 10:  Databases and Associated Signaling 
     (id. at  138-139)
VIII.     Checklist Item 11:  Number Portability (id. at  140-
IX.  Checklist Item 13:  Reciprocal Compensation (id. at  143-
X.   Checklist Item 14:  Resale (id. at  153-158)

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'');  Letter from 
Maureen F. Del Duca, Acting Chief, Investigations and Hearings 
Division, Enforcement Bureau, to Gerald Asch, Director, Federal 
Regulatory, Verizon, dated January 23, 2003 (``January 23, 2003 
2 See Application by Verizon Maryland Inc., Verizon Washington, 
D.C. Inc, Verizon West Virginia Inc. et al. for Authorization to 
Provide In-Region, InterLATA Services in Maryland, Washington, 
D.C. and West Virginia,, Memorandum Opinion and Order, FCC 03-37 
(rel. March 19, 2003) (``Verizon MD/DC/WVA Order'').  
3 Those states include New York, Massachusetts, Connecticut, 
Rhode Island, Vermont, Maine, and New Hampshire. 

4 Those jurisdictions include Pennsylvania, New Jersey, Delaware, 
Maryland, Virginia, West Virginia, and Washington, D.C.  
5    The Bureau may monitor for enforcement purposes other 
subjects or performance indicators not expressly noted by the 
Commission in the Verizon MD/DC/WVA Order or this letter.