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Jonathan Banks
General Counsel-BellSouth D.C.
1133 21st Street, N.W., Suite 900
Washington, D.C. 20036-3351
Fax (202) 463-4141
RE: Section 271 Compliance Review Program for Georgia and
Louisiana
Dear Mr. Banks:
As you know, the Commission recently granted BellSouth's
application to provide in-region interLATA toll service in
Georgia and Louisiana pursuant to section 271 of the
Communications Act of 1934, as amended (``the Act''). See Joint
Application by BellSouth Corporation, BellSouth
Telecommunications, Inc., and BellSouth Long Distance, Inc. for
Provision of In-Region, InterLATA Services in Georgia and
Louisiana, CC Docket No. 02-35, Memorandum Opinion and Order, FCC
02-147 (rel. May 15, 2002) (``Order''). The Enforcement Bureau
(``the Bureau''), therefore, will now monitor BellSouth's
continuing compliance with section 271 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 BellSouth
through the duration of the review and to monitor BellSouth's
performance in Georgia and Louisiana. The primary team members
responsible for this review are Hillary DeNigro, Attorney and
Mark Gerner, Auditor.
During the review, the Team will closely review BellSouth's
performance in subject matter areas that the Commission has
identified as areas of concern in the section 271 Order. In this
regard, we have enclosed with this letter an attachment listing
the specific performance measures and other areas about which the
Commission expressed its concern in the Order. Although the
Bureau will focus its review on these areas, it may also monitor
other areas not noted by the Commission in the Order. Generally,
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. Within the next few
days, a representative from the Bureau will contact BellSouth to
schedule a planning meeting with BellSouth representatives and
the Team overseeing the review. The purpose of this meeting is
to provide BellSouth with the opportunity to participate in
developing the Review Program and to assist the Bureau in
selecting the type and format of information pertaining to
BellSouth's performance that the Team will review. BellSouth
should be prepared to discuss the areas of concern that the
Commission noted in the 271 Order (also listed in the attachment
to this letter) and to identify knowledgeable employees,
applicable corporate records, and computer systems related to
these areas. Following this meeting, the Team will send a
follow-up letter to BellSouth memorializing the discussions at
the meeting and describing the information BellSouth is
responsible for submitting to the Bureau approximately six months
after the approval date (i.e., December 2, 2002). The Team will
also continue to monitor BellSouth's performance during Phase 1
through the monthly carrier to carrier performance reports the
Commission's Order required BellSouth to submit.
Phase 2: The second phase will proceed similarly to the
first but will occur during the second six-month period after the
grant. Specifically, the Team will send another request for
information to BellSouth. The information responsive to this
request will be due at the end of this period (approximately June
3, 2003). At that time, the Bureau will require BellSouth to
update information it already submitted and to provide additional
information concerning its continuing performance in Georgia and
Louisiana. Also, as in Phase 1, the Team will continue to
monitor BellSouth's performance through the 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: The third phase of the review will begin after
BellSouth submits the information the Team required in Phase 2
and will consist of less formal contacts and inquiries by the
Bureau.
At any time during this review, the Team may ask BellSouth
to provide additional information or to attend additional
meetings with BellSouth employees who have expertise in specific
subject matters. These additional inquiries may supplement
existing requests or may encompass new inquiries.
Finally, BellSouth should provide to the team at the initial
meeting during Phase 1 the names and contact information of
employees who are authorized to respond to requests for
information on behalf of the corporation. 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 Anthony Dale, Assistant Chief, Investigations and
Hearings Division at (202) 418-2260 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
Deputy Chief, Investigations and
Hearings Division
Enforcement Bureau
cc: Kathleen B. Levitz
Vice President - Federal Regulatory Attachment
Section 271 Compliance Review Program
BellSouth: Georgia and Louisiana
Commission Identified Compliance Review Subjects1
I. Data Reliability (See Georgia/Louisiana Order (``Order''),
paragraph 20)
II. Checklist Item 1: Interconnection
II.A. Quality (See Order, paragraphs 202-203)
II.B. Timeliness (See Order, paragraph 204)
III. Checklist Item 2: Unbundled Network Elements
III.A. Adherence to Change Management (See Order,
paragraph 195)
III.B. OSS
III.B.1. Pre-ordering
III.B.1)a. Interface Slowdowns/Outages (See
Order, paragraph 118)
III.B.1)b. Access to Due Dates (See Order,
paragraph 134)
III.B.1)c. Pre-Ordering/Ordering Integration,
TN Migration and Parsed CSRs (See Order,
paragraphs 123-130)
III.B.1)d. Access to Loop Qualification
Information (See Order, paragraph 112-116)
III.B.2. Ordering
III.B.2)a. Order Confirmation and Reject
Notice Timeliness (See Order, paragraph142)
III.B.2)b. Order Flow-Through (See Order,
paragraph 146)
III.B.2)c. Electronic Ordering Capability (See
Order, paragraphs 149-150)
III.B.2)d. Jeopardy Notices (See Order,
paragraph 156)
III.B.2)e. DSL Universal Service Order Code
and Phantom Universal Service Order Code (See
Order, paragraph 158)
III.B.2)f. Service Order Accuracy (See Order,
paragraphs 159-161)
III.B.2)g. Line Loss Notification Reports (See
Order, paragraph 163)
III.B.3. Provisioning
III.B.3)a. Product Mix/EELs (See Order,
paragraph 166)
III.B.3)b. Quality Service Problems (See
Order, paragraph 167)
III.B.4. Maintenance and Repair
III.B.4)a. Functionality (See Order,
paragraphs 170-171)
III.B.4)b. Time To Restore/Quality of Work
(See Order, paragraph 172)
III.B.5. Billing (See Order, paragraphs 173-178)
IV. Checklist Item 4: Unbundled Loops
IV.A. Voice Grade Loops
IV.A.1. Order Completion Interval (See Order,
paragraph 224)
IV.A.2. Missed Repair Appointment Metric (See Order,
paragraph 225)
IV.B. xDSL Capable Loops--Maintenance and Repair (See
Order, paragraph 229)
IV.C. High Capacity Loops--Installation Quality Measure
(See Order, paragraph 233)
V. Checklist Item 11: Number Portability
V.A. Loss of Inbound Calling (See Order, paragraph 261)
V.B. Double Billing (See Order, paragraph 262)
_________________________
1 Consistent with the representation in the letter pertaining
to the scope of the Bureau's review, the Bureau may monitor for
enforcement purposes other subjects or performance indicators not
expressly noted by the Commission in the Georgia/Louisiana Order
or in this Attachment.