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FEDERAL COMMUNICATIONS COMMISSION
Enforcement Bureau, Investigations and Hearings Division
445 12th Street, S.W., Room 3-B443
Washington, D.C. 20554
July 2, 2002
Caryn D. Moir
Vice President - Federal Regulatory
SBC Telecommunications, Inc.
1401 I Street, NW
Suite 400
Washington, DC 20005-2296
fax 202-408-4809
RE: Section 271 Compliance Review Program for Arkansas
and Missouri
Dear Ms. Moir:
1. As you know, on November 16, 2001, the Commission
granted SBC's application to provide in-region interLATA
toll service in Arkansas and Missouri pursuant to section
271 of the Communications Act of 1934, as amended (``the
Act''). See Joint Application by SBC Communications Inc.,
Southwestern Bell Telephone Company, and Southwestern Bell
Communications Services, Inc. d/b/a Southwestern Bell Long
Distance Pursuant to Section 271 of the Telecommunications
Act of 1996 to Provide In-Region, InterLATA Services in
Arkansas and Missouri, 16 FCC Rcd 20719 (2001) (``Order'').
The Enforcement Bureau (``the Bureau''), therefore, will now
monitor SBC'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 SBC through the duration of
the review and to monitor SBC's performance in Arkansas and
Missouri. The primary team members responsible for this
review are David Janas, Attorney; Austin O'Connor, Auditor;
and Andrew Skadin, Auditor.
2.
3. During the review, the Team will closely review
SBC'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 two phases.
4.
5. Phase 1: Within the next few days, a
representative from the Bureau will contact SBC to schedule
a planning meeting with SBC representatives and the Team
overseeing the review. The purpose of this meeting is to
provide SBC 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
SBC's performance that the Team will review. SBC 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 SBC memorializing the discussions at
the meeting and describing the information SBC is
responsible for submitting to the Bureau approximately
twelve months after the approval date (i.e., November 16,
2002). The Team will also continue to monitor SBC's
performance during Phase 1 through the monthly carrier to
carrier performance reports the Commission's Order required
SBC to submit.
6.
7. Phase 2: The second phase of the review will
begin after SBC submits the information the Team required in
Phase 2 and will consist of less formal contacts and
inquiries by the Bureau.
8.
9. At any time during this review, the Team may ask
SBC to provide additional information or to attend
additional meetings with SBC employees who have expertise in
specific subject matters. These additional inquiries may
supplement existing requests or may encompass new inquiries.
10.
11. Finally, SBC 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.
12.
13.
14. Sincerely,
15.
16.
17.
18. Maureen F. Del Duca
19. Deputy Chief, Investigations and Hearings Division
20. Enforcement Bureau Attachment
Section 271 Compliance Review Program
SBC: Arkansas and Missouri
Commission Identified Compliance Review Subjects1
I. Checklist Item 1: Interconnection
I.A. Collocation (See Order, paragraph 86)
I.B. Installation (See Order, paragraph 87)
I.C. Point of Interconnection (See Order,
paragraph 88)
I.D. Pricing (See Order, paragraphs 92-96)
II. Checklist Item 2: Unbundled Network Elements
II.A. Access to OSS
II.A.1. Data Reliability (See Order, paragraphs
16-20)
II.A.2. Maintenance and Repair/LMOS (See Order,
paragraphs 22-36)
II.A.3. Pre-Ordering (See Order, paragraph 37)
II.A.4. Ordering
II.A.4)a. Order Confirmation Notices
(See Order, paragraph 39)
II.A.4)b. Order Rejection Notices (See
Order, paragraph 40)
II.A.4)c. Order Flow-Through Rate (See
Order, paragraphs 41-43)
II.A.5. Provisioning (See Order, paragraph 44)
II.A.6. Billing (See Order, paragraphs 45-46)
II.A.7. OSS of Advanced Services Affiliate (See
Order, paragraph 47)
II.B. Pricing of UNEs
II.B.1. Recurring Charges (See Order, paragraphs
52-68)
II.B.2. Nonrecurring Charges (See Order,
paragraphs 71-75)
II.C. Provision of UNE Combinations (See Order,
paragraphs 76-77)
III. Checklist Item 4: Unbundled Local Loops
III.A. xDSL-Capable Loops (See Order, paragraphs
100-01)
III.B. Hot Cuts (See Order, paragraph 102)
III.C. Voice Grade Loops (See Order, paragraph 103)
III.D. Line Sharing (See Order, paragraphs 104-05)
III.E. Line Splitting (See Order, paragraph 106)
III.F. High Capacity Loops (See Order, paragraphs
107-09)
III.G. Disconnecting IDSL (See Order, paragraph 110)
IV. Checklist Item 6: Switching (See Order, paragraphs
111-13)
V. Checklist Item 13: Reciprocal Compensation (See Order,
paragraphs 114-15)
VI. Checklist Item 14: Resale (See Order, paragraphs 78-
84)
21.
_________________________
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 Order or in this Attachment.