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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 Section 271-
     States in the Qwest Region

Dear Mr. Johnston:

     The Commission has granted Qwest Communications 
International, Inc. authorization, pursuant to section 271 of the 
Communications Act of 1934, as amended (the ``Act''), to provide 
interLATA services in nine states within its region:  Colorado, 
Idaho, Iowa, Montana, Nebraska, North Dakota, Utah, Washington, 
and Wyoming.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, 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 Multistate Order.  In 
this regard, we have attached a list of specific performance 
measures and other areas about which the Commission expressed its 
concern in the Qwest Multistate Order.  The Bureau will focus its 
review on these areas; however, it may also monitor other areas 
not noted by the Commission in the Qwest Multistate 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 Multistate Order 
(also listed in the attachment to this letter) and to identify 
knowledgeable employees, applicable corporate records, and 
computer systems related to these areas.  Qwest should also 
provide to the Team the names and contact information of Qwest 
employees authorized to respond to requests for information on 
behalf of the corporation.  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.

     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 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.


                              Maureen F. Del Duca
                              Acting Division Chief
                              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
          a.   Pre-Ordering and Ordering Integration (Qwest 
               Multistate Order at  45-60)
          b.   Access to Loop Qualification Information (Qwest 
               Multistate Order at  61-83)
       I.A.2.     Ordering
          a.   Jeopardy Notices (Qwest Multistate Order at  91-
          b.   Service Order Completion (Qwest Multistate Order at 
          c.   Processing of Manually Handled Orders (Qwest 
               Multistate Order at  98-105)
          d.   Order Flow-Through Rate (Qwest Multistate Order at 
       I.A.3.     Billing
          a.   Wholesale Bills (Qwest Multistate Order at  119-
          b.   Billing Accuracy (Qwest Multistate Order at  128-
       I.A.4.     Maintenance and Repair (Qwest Multistate Order 
            at  154 & note 581)
       I.A.5.     Provisioning (Qwest Multistate Order at  162-
            164, 166-167)
     I.B.   Pricing - Colorado -- Line Sharing (Qwest Multistate 
          Order at  210-213)
II.  Other Checklist Items
     II.A.  Unbundled Local Loops (Qwest Multistate Order at  
          352-354, 356-359)
     II.B.  Unbundled Local Transport (Qwest Multistate Order at  
III.   Section 272 Compliance (Qwest Multistate Order at  399, 
     406, 412, 414, 416)
IV.  Public Interest Analysis -- Unfiled Interconnection 
     Agreements (Qwest Multistate Order at  466)

1    Application by Qwest Communications International, Inc. for 
Authorization to Provide In-Region, InterLATA Services in the 
States of Colorado, Idaho, Iowa, Montana, Nebraska, North Dakota, 
Utah, Washington, and Wyoming, Memorandum Opinion and Order, FCC 
02-332 (rel. Dec. 23, 2002) (Qwest Multistate Order).
2    The Bureau may monitor other subjects or performance 
indicators not expressly noted by the Commission in the Qwest 
Multistate Order or this letter.