KEY FACTS REGARDING NEW YORK


I.	COMPETITION IN NEW YORK 

? New York State has some of the most intensely competitive local exchange and local 
exchange access markets in the nation.  This track record of successful competition 
places Bell Atlantic's section 271 application in a different context than prior filings. 
? Competitors in New York serve at least 651,793 lines using their own facilities, 152,055 
lines using the UNE platform, and 314,332 lines through resale for a total of at least 
1,118,180 lines. 
? Competitors in New York serve at least 35,753 residential lines over their own facilities, 
provide service to 137,342 residential customers using the UNE platform and resell 
another 63,547 residential lines.
II. THIRD PARTY TESTING OF BELL ATLANTIC OSS

? Incumbent LECs use a variety of systems, databases, and personnel (collectively referred 
to as OSS) to provide service to their customers at a certain level of quality, accuracy and 
timeliness.  The Commission has found that nondiscriminatory access to OSS is a 
prerequisite to the development of meaningful local competition.  For example, new 
entrants must have access to the functions performed by the incumbent's OSS in order to 
formulate and place orders for network elements or resale services, to install service to 
their customers, to maintain and repair network facilities, and to bill customers. 
? The New York Commission retained KPMG Peat Marwick (KPMG) to conduct an 
independent, third-party test of the readiness of Bell Atlantic's OSS, interfaces, 
documentation and processes.  Over the course of fifteen months, KPMG evaluated 855 
separate items relating to pre-ordering, ordering, provisioning, maintenance and repair, 
billing, and relationship management and infrastructure, by performing both transaction 
and operational tests. 
? In performing these tests, KPMG adopted a military-style test philosophy, or a mindset of 
"test until you pass."  Thus, when situations arose where testing revealed that a Bell 
Atlantic process, document, or system did not meet expectations, Bell Atlantic would 
generally implement a fix and KPMG would retest the process, document, or system until 
satisfied.
? To the greatest extent possible, the KPMG test was both independent and blind.  For 
example, KPMG required that all documents provided to them were generally available 
to all competing carriers.  The New York Commission monitored phone calls between 
KPMG and Hewlett Packard and Bell Atlantic, and competing carriers were invited to 
attend conference calls.  Hewlett Packard acted as a competing carrier information 
technology group, establishing electronic bonding with Bell Atlantic, translating back and 
forth between business and EDI rule formats, and resolving problems with missing orders 
and responses.

? The rigorous, comprehensive third party testing in New York identified numerous 
shortcomings in Bell Atlantic's OSS performance that were subsequently corrected and 
re-tested.  The pseudo-competitive LEC, KPMG, released its final report on August 6, 
1999, concluding that Bell Atlantic's OSS was commercially available and sufficient to 
handle reasonable, anticipated commercial volumes.
III. NEW YORK DEVELOPMENT OF PERFORMANC MEASURES AND 
STANDARDS 
? The New York Commission developed, and continues to refine, inter-carrier performance 
measures and service quality standards in its Carrier-to-Carrier proceeding.  For 
example, the New York Commission has instituted collaborative proceedings to address 
xDSL issues and is developing xDSL specific performance measures and standards.  
? To ensure that the company's performance data or "metrics" are reported reliably in 
accordance with the New York Commission's definitions, New York staff and KPMG 
reviewed the adequacy of internal controls surrounding the data collection process.  In 
addition, the New York Commission's staff verifies on a monthly basis that Bell 
Atlantic's reported results conform to the definitions developed in the Carrier-to-Carrier 
proceeding.  The definitions and standards developed in that proceeding have done much 
to foster the development of consistent and meaningful data concerning Bell Atlantic's 
performance.  This gives us greater confidence that our decision is based on performance 
data that accurately measures Bell Atlantic's actual performance. 
IV. NEW YORK PERFORMANCE ASSURANCE PLAN  
? New York has adopted a self-effectuating performance assurance plan that will provide 
significant financial incentives for Bell Atlantic to maintain an open market and prevent 
"backsliding" in the future provision of service by Bell Atlantic to competitive LECs.
? The New York Commission is committed to supervising the implementation of these 
plans.