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                           June 4, 2003

William Johnston
Executive Director
Federal and Financial Policy
Qwest Communications International, Inc.
1801 California Street, 47th floor
Denver, CO  80202

RE:  Section 271 Compliance Review Program for New Mexico, Oregon 
     and South Dakota 
     in the Qwest Region

Dear Mr. Johnston:

     The Commission has granted Qwest Communications 
International, Inc. authorization to provide interLATA services in 
three states within its region:  New Mexico, Oregon and South 
Dakota, pursuant to section 271 of the Communications Act of 1934, 
as amended (the ``Act'').1  The Enforcement Bureau (``Bureau'') 
will monitor Qwest'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 Qwest through the duration 
of the review and to monitor Qwest's performance in the states 
where it has received section 271 approval.  The primary team 
members responsible for this review are Mika Savir, Attorney 
Advisor, and Robert Bentley, Auditor.

     During the review, the Team will closely review Qwest's 
performance in subject matter areas that the Commission has 
identified as areas of concern in the Qwest Order.  In this 
regard, we have attached a list of areas about which the 
Commission expressed its concern in the Qwest Order.  The Bureau 
will focus its review on these areas and relevant performance 
measurements; however, it may also monitor other areas not noted 
by the Commission in the Qwest Order.  

     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.  Shortly after the grant 
of approval, a representative from the Bureau will contact Qwest 
to schedule a planning meeting with Qwest representatives and the 
Team overseeing the review.  The purpose of this meeting is to 
provide Qwest 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 Qwest's performance 
that the Team will review.  

     At the meeting, Qwest should be prepared to discuss the areas 
of concern that the Commission noted in the Qwest Order (also 
listed in the attachment to this letter) and to identify 
knowledgeable employees, applicable corporate records, and 
computer systems related to these areas.  We will also discuss the 
feasibility of consolidating this compliance review with the Qwest 
9-state compliance review program.  

     Qwest should provide the names and contact information of 
Qwest employees authorized to respond to requests for information.  
Following the meeting, the Team will send a follow-up letter to 
Qwest memorializing the discussions at the meeting and describing 
the information Qwest is responsible for submitting to the Bureau 
approximately six months after the approval date.  The Team will 
also continue to monitor Qwest's performance during Phase 1 
through the monthly carrier-to-carrier performance reports.

     Phase 2:  The Phase 2 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 
Qwest to update information submitted previously, and to provide 
additional information concerning its performance since the Phase 
1 review.  The information responsive to this request will be due 
at the end of the Phase 2 review period.  The Team will continue 
to monitor Qwest'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 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 

     Phase 3:  The third phase of the review will begin after 
Qwest submits the information the Team required in Phase 2.  
During this phase the Bureau may make informal inquiries of Qwest 
regarding its section 271 compliance in the three states and will 
investigate instances of suspected or alleged noncompliance.

     At any time during this review, the Team may ask Qwest to 
provide additional information.  The Team may also request 
additional meetings with Qwest 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 Ms. Savir at 
(202) 418-0834 or Mr. Bentley at (202) 418-0876.  Thank you in 
advance for your cooperation.


                              Maureen F. Del Duca
                              Investigations and Hearings Division
                              Enforcement Bureau


cc:  Melissa Newman                            Attachment
        Commission-Identified Compliance Review Subjects2

I.   Checklist Item 2:  Unbundled Network Elements
     I.A.   OSS
       I.A.1.     Pre-Ordering (Qwest New Mexico/Oregon/South 
            Dakota Order  39-42)
       I.A.2.     Ordering  (Qwest New Mexico/Oregon/South Dakota 
            Order  43-45)
       I.A.3.     Maintenance and Repair (Qwest New 
            Mexico/Oregon/South Dakota Order  46-49)
       I.A.4.     Billing  (Qwest New Mexico/Oregon/South Dakota 
            Order  50-53)
       I.A.5.     Change management  (Qwest New 
            Mexico/Oregon/South Dakota Order  54-62)
  I.B.      Pricing of Unbundled Network Elements - Oregon (Qwest 
       New Mexico/Oregon/South Dakota Order  84)
II.    Other Checklist Items -- Unbundled Local Loops  (Qwest New 
  Mexico/Oregon/South Dakota Order  96-97)
III.   Public Interest Analysis -- Unfiled Interconnection 
  Agreements (Qwest New Mexico/Oregon/South Dakota Order  124)


1    Application by Qwest Communications International, Inc. for 
Authorization to Provide In-Region, InterLATA Services in New 
Mexico, Oregon and South Dakota, Memorandum Opinion and Order, FCC 
03-81 (rel. April 15, 2003) (``Qwest Order'').
2    The Bureau may monitor other subjects or performance 
indicators not expressly noted by the Commission in the Qwest 
Order or this letter.