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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-
Approved
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
information.
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.
Sincerely,
Maureen F. Del Duca
Acting Division Chief
Investigations and Hearings Division
Enforcement Bureau
Enclosure
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-
96)
b. Service Order Completion (Qwest Multistate Order at
¶ 97)
c. Processing of Manually Handled Orders (Qwest
Multistate Order at ¶¶ 98-105)
d. Order Flow-Through Rate (Qwest Multistate Order at
¶¶ 106-112)
I.A.3. Billing
a. Wholesale Bills (Qwest Multistate Order at ¶¶ 119-
126)
b. Billing Accuracy (Qwest Multistate Order at ¶¶ 128-
130)
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 ¶
367)
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.