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

                      November 19, 2003


VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED
and FACSIMILE (202) 408-4805

Michelle Thomas
Executive Director
Federal Regulatory
SBC Communications, Inc.
1401 I Street, N.W., Suite 1100
Washington, DC 20005

Re:  Consolidated Section 271 Compliance Review Programs for 
Michigan, Illinois, Indiana, Ohio and   Wisconsin; EB-03-IH-
0415

Dear Ms. Thomas:

     As you know, the Commission recently granted SBC 
Communications, Inc. (``SBC'') authority to provide in-
region interLATA services in Michigan, Illinois, Indiana, 
Ohio, and Wisconsin, pursuant to Section 271 of the 
Communications Act of 1934, as amended (``the Act'').1  As a 
consequence, the Enforcement Bureau (``Bureau'') will now 
commence monitoring SBC's ongoing compliance with Section 
271 in these states, as described below, pursuant to its 
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 
individuals from its Investigations and Hearings Division to 
work with SBC through the duration of the review and to 
monitor SBC's performance in Michigan, Illinois, Indiana, 
Ohio, and Wisconsin.  The primary team members responsible 
for this review are Gary Schonman, Esq.; and Connie Hellmer 
and Larry McKinley, Auditors (the ``Team'').  

     During the review, the Team will closely review SBC's 
performance in subject matter areas that the Commission 
identified as areas of concern in its Orders.  In this 
regard, we have attached a list of the areas about which the 
Commission expressed concern in the Orders.  Although the 
Bureau will focus its review on these areas and relevant 
performance measurements, it may also monitor other areas 
not specifically identified in the Orders.  Generally, the 
Team's review will occur in three phases.

     Phase 1:  Phase 1 will span the initial six-month 
period following release of the October 15, 2003 Order.  
Within the next few days, a Team representative will contact 
SBC to schedule a planning meeting with SBC representatives.  
The purpose of this meeting will be to provide SBC with the 
opportunity to participate in developing the Review Program 
and to assist the Team 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 identified by the Commission in its Orders and 
included in the attachment appended hereto.  SBC should also 
be prepared to identify knowledgeable employees, applicable 
corporate records, and computer systems related to these 
areas.  In addition, SBC should be prepared to provide the 
Team with names and contact information of employees who are 
authorized to respond to requests for information on behalf 
of the corporation.

     Following this meeting, the Team will send a follow-up 
letter to SBC memorializing the discussions and describing 
the specific information that SBC will be responsible for 
submitting to the Team at the conclusion of Phase 1.  The 
Team will also monitor SBC's performance during Phase 1 
through its analysis of monthly carrier-to-carrier 
performance reports that the Commission, in its Orders, 
directed SBC to submit.

     Phase 2:  Phase 2 will span the second six-month period 
following release of the October 15, 2003 Order.  On or 
about the commencement of Phase 2, the Team will direct 
another request to SBC for specific information.  The 
information responsive to this request will be due at the 
end of Phase 2.  At that time, SBC will also be required to 
update information previously provided to the Team and to 
provide additional information concerning its continuing 
performance in Michigan, Illinois, Indiana, Ohio, and 
Wisconsin.  During Phase 2, the Team will continue to 
monitor SBC's performance through its analysis of SBC's 
monthly 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:  Phase 3 will commence approximately one year 
following release of the Orders and may consist of less 
formal contacts and inquiries by the Bureau.  The nature of 
the Team's oversight of SBC's compliance with Section 271 
during Phase 3 will be determined by SBC's record of 
compliance during Phases 1 and 2.

     At any time, 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.

     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 Trent Harkrader, 
Assistant Chief, Investigations & Hearings Division at (202) 
418-2955.  Thank you in advance for your cooperation.


                              Sincerely,



                              William H. Davenport
                              Deputy Division Chief
                              Investigations and Hearings 
                         Division
                              Enforcement Bureau

                                   
                         Attachment

               Compliance Review Subjects for
      Michigan, Illinois, Indiana, Ohio, and Wisconsin2


MICHIGAN


   I.   Checklist Item 2:  Unbundled Network Elements

        A.Access to Operations Support Systems

        I.1.   Pre-Ordering
              a.  Pre-Ordering Interface  Availability  (See 
              Order  62)
              b.  Loop Qualifications (See Order  63-64)

        I.2.   Ordering
              a.  Performance Metrics (See Order  66)
              b.  Rejections (See Order  67)
              c.  Separate LSR Requirement (See Order  68)
              d.  Project Definition (See Order  69)
              e.  Other Ordering Issues (See Order  70-77)

        I.3.   Provisioning
              a.  Provisioning Timeliness (See Order  79)
              b.  Provisioning Quality (See Order  80)

        I.4.   Maintenance and Repair (See Order  81-86)

        I.5.   Billing
              a.  Wholesale Bills (See Order  88-112) 
              b.  Service Usage  Reports (See Order   113-
              116)

        I.6.   Change Management
              a.  Adequacy  of Change Management  (See Order 
               118-119)
              b.  Adequate Documentation (See Order  120)
              c.  Testing Environment (See Order  121)
              d.  Adherence  to the CMP  (See Order   122-
              126)

   II.          Checklist Item 4:  Unbundled Local Loops

        II.1.  xDSL-Capable Loops (See Order  128-131)

        II.2.  Voice-Grade Loops, Digital  Loops, Dark Fiber 
          and Hot Cuts (See Order  132)

        II.3.  Line Sharing and Line Splitting (See Order  
          133-143)

   III.   Checklist Item 7:  Access to 911/E911

        III.1. Access to 911/E911 (See Order  144-150)

        III.2. Access    to   Operator    Services/Directory 
          Assistance ( 151-152)

   IV.  Public Interest Analysis

        IV.1.  Other Issues 
              a.   Penalty Waiver  Agreement  (See Order   
              177-180)
              b.  Security Deposits (See Order  181-182)




ILLINOIS, INDIANA, OHIO AND WISCONSIN



   I.   Checklist Item 1:  Interconnection ( 20-33)

   II.  Checklist Item 2:  Unbundled Network Elements

        A.Access to Operations Support Systems

        II.a.1.     Pre-Ordering (See Order  88-95)
              a.   Pre-Order  Interface   Availability  (See 
              Order  91-94)
              b.  Loop Qualifications (See Order  95)

        II.a.2.     Ordering (See Order  96-104)
              a.  Performance Metrics (See Order   97)
              b.  Rejections (See Order   98-99)
              c.   Service  Order  Completion  Notices  (See 
              Order  100)
              d.  Other Ordering  Issues (See Order   101-
              104)

        II.a.3.     Provisioning (See Order  105-109)

        II.a.4.     Maintenance  and  Repair (See  Order   
          110-112)

        II.a.5.     Billing
              a.  Service Usage Reports (See Order  114)
              b.  Wholesale Bills (See Order   115-133)

        II.a.6.     Change Management
              a.  Adequacy  of Change Management  (See Order  
               136)
              b.  Competitive LEC Input (See Order   137)
              c.  Testing Environment (See Order    138)
              d.  Adherence to  the CMP (See Order    139-
              140)

   III.   Checklist Item 4:  Unbundled Local Loops

        III.a.1.    xDSL-Capable Loops (See Order  143 )

        III.a.2.    Voice-Grade  Loops, Digital  Loops, Dark 
          Fiber and Hot Cuts (See Order  144)

        III.a.3.    Line  Sharing  and Line  Splitting  (See 
          Order  145-147)

        III.a.4.    Facilities  Provisioning  (See Order   
          148-149)

        III.a.5.    Unbundled IDLC/NGDLC (See Order  150)

                              
_________________________

1  See In the Matter of Application by SBC Communications, 
Inc., Michigan Bell Telephone Company, and Southwestern Bell 
Communications Services, Inc.  for Authorization to Provide 
In-Region InterLATA Services in Michigan, WC Docket No. 03-
138, FCC 03-228, (rel. September 17, 2003); In the Matter of 
Joint Application by SBC Communications Inc., Illinois Bell 
Telephone Company, Indiana Bell Telephone Company 
Incorporated, the Ohio Bell Telephone Company, Wisconsin 
Bell, Inc., and Southwestern Bell Communications Services, 
Inc. for Authorization to Provide In-Region InterLATA 
Services in Illinois, Indiana, Ohio, and Wisconsin, WC 
Docket No. 03-167, FCC 03-243, (rel. October 15, 2003) 
(collectively, ``Orders'').
2 As indicated in the letter to which this attachment is 
appended, the Bureau may, for enforcement purposes, monitor 
and evaluate SBC's performance in other subject matter areas 
and/or with other performance measures not expressly noted 
by the Commission in its Orders.