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Mr. Gordon R. Evans
Vice President - Federal Regulatory
Verizon Communications, Inc.
1300 I St., N.W.
Suite 400 West
Washington, DC 20005
RE: Section 271 Compliance Review Program for Section 271-
Approved
States in the Verizon Region
Dear Mr. Evans:
Since passage of the Telecommunications Act of 1996, the
Commission has granted Verizon authorization, pursuant to section
271, to provide interLATA services in eight states within its
region - New York, Massachusetts, Connecticut, Pennsylvania, Rhode
Island, Vermont, Maine and New Jersey. The Enforcement Bureau
(``the Bureau'') will monitor Verizon'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 Verizon
through the duration of the review and to monitor Verizon's
performance in the states where it has received section 271
approval. The primary team members responsible for this review
are Mark Stone, Attorney, and Jeff Stover, Auditor, for the former
Bell Atlantic north states1; and Raelynn Tibayan Remy, Attorney,
and Sheryl Herauf, Auditor, for the former Bell Atlantic south
states.2
During the review, the Team will closely review Verizon'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.3
Phase 1: The Phase 1 review will occur during the first six
months following the section 271 grant.4 Shortly after the grant
of approval, a representative from the Bureau will contact Verizon
to schedule a planning meeting with Verizon representatives and
the Team overseeing the review. The purpose of this meeting is to
provide Verizon 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 Verizon's performance
that the Team will review.
At the meeting, Verizon should be prepared to discuss the
areas of concern that the Commission noted in the section 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. Verizon should also
provide to the Team the names and contact information of employees
who are authorized to respond to requests for information on
behalf of the corporation. Following the meeting, the Team will
send a follow-up letter to Verizon memorializing the discussions
at the meeting and describing the information Verizon is
responsible for submitting to the Bureau approximately six months
after the approval date. The Team will also continue to monitor
Verizon's performance during Phase 1 through the monthly carrier-
to-carrier performance reports the Commission's Orders required
Verizon to submit.
Phase 2: The Phase II 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
Verizon to update information submitted previously, and to provide
additional information concerning its performance since the Phase
I review. The information responsive to this request will be due
at the end of the Phase II review period. As in Phase 1, the Team
will also continue to monitor Verizon'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 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
Verizon submits the information the Team required in Phase 2.
At any time during this review, the Team may ask Verizon to
provide additional information or to attend additional meetings
with Verizon 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 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 Attachments
Table of Contents
Former Bell Atlantic-North State
Page
Massachusetts A-1
Connecticut A-2
Rhode Island A-3
Vermont A-4
Maine A-5
Former Bell Atlantic-South State
Page
Pennsylvania B-1
New Jersey B-2
Massachusetts
Commission Identified Compliance Review Subjects5
I. Checklist Item 2: Unbundled Network Elements
I.A. Access to OSS
I.A.1. Pre-Ordering Functionality, Integration,
Response Times and Availability (Order at ¶¶ 52-53)
I.A.2. Access to Loop Qualification Information
(Order at ¶¶ 54-69)
I.A.3. Ordering
I.A.3)a. Ordering Confirmation Notices (Order at
¶¶ 71-73)
I.A.3)b. Order Rejection Notices and Order
Rejections (Order at ¶¶ 74-76)
I.A.3)c. Order Flow-Through Rate (Order at ¶¶ 77-
82)
I.A.3)d. Order Completion Notices and Jeopardy
Information (Order at ¶¶ 83-86)
I.A.3)e. Ordering Notifiers and the New York
Consent Decree (Order at ¶¶ 87-89)
I.A.4. Provisioning
I.A.4)a. Resale Orders (Order at ¶¶ 91-93)
I.A.4)b. UNE-P Orders (Order at ¶ 94)
I.A.5. Maintenance and Repair
I.A.5)a. Functionality (Order at ¶ 95)
I.A.5)b. Interface Response Times, Time to Restore
and Quality of Work Performed (Order at ¶ 96)
I.A.6. Billing
I.A.6)a. Billing Accuracy (Order at ¶¶ 97-99)
I.A.6)b. Line Loss Reports (Order at ¶ 100)
I.A.6)c. Suspension for Non-Payment (Order at ¶
101)
I.A.7. Change Management and Technical Assistance
(Order at ¶¶ 102-116)
I.B. UNE Combinations (Order at ¶¶ 117-120)
II. Checklist Item 4: Unbundled Local Loops
II.A. xDSL-Capable Loops
II.A.1. Order Processing Timeliness (Order at ¶¶ 132-
135)
II.A.2. Provisioning Timeliness (Order at ¶¶ 136-141)
II.A.3. Provisioning Quality (Order at ¶¶ 142-148)
II.A.4. Maintenance and Repair (Order at ¶¶ 149-153)
II.B. Subloops (Order at ¶¶ 154-155)
II.C. High Capacity Loop Performance (Order at ¶ 156)
II.D. Voice Grade Loops
II.D.1. Hot Cuts (Order at ¶¶ 158-160)
II.D.2. New Stand-Alone Loop Provisioning (Order at ¶¶
161-162) Connecticut
Commission Identified Compliance Review Subjects6
I. Checklist Item 4: Unbundled Local Loops
I.A. xDSL Stand-Alone Loops
I.A.1. Provisioning Timeliness (See Connecticut Order
(``Order'') at ¶¶ 16-20)
I.A.2. Provisioning Quality (Order at ¶¶ 16-20)
I.A.3. High Capacity Loops (Order at ¶ 26)
I.B. Checklist Item 14: Resale
I.B.1. Compliance with ASCENT decision (Order at ¶¶
27-44) Rhode Island
Commission Identified Compliance Review Subjects7
I. Checklist Item 2: Unbundled Network Elements
I.A. Pricing of Network Elements
I.A.1. Switch Rates (See Rhode Island Order
(``Order'') at ¶¶ 33-55)
I.A.2. Loop Rates (Order at ¶¶ 56-57)
I.B. OSS
I.B.1. Pre-ordering - Loop Qualification (Order at ¶¶
61-65)
I.B.2. Ordering
I.B.2)a. Order Reject Notices/Rejects (Order at ¶
66)
I.B.2)b. Jeopardies (Order at ¶¶ 67-68)
I.B.3. Provisioning - Average Interval Completed
(Order at ¶¶ 69-70)
II. Checklist Item 4: Unbundled Local Loops
II.A. xDSL Loops - Trouble Reports for Standalone Loops
(Order at ¶¶ 78-79)
II.B. Digital Loops
II.B.1. Installation Troubles (Order at ¶¶ 80-81)
II.B.2. Repeat Troubles (Order at ¶¶ 80-81)
II.C. Voice-Grade Loops
II.C.1. Repeat Trouble Reports (Order at ¶ 85)
II.C.2. Provisioning Timeliness (Order at ¶ 86)
II.D. High Capacity Loops - Provisioning Quality (Order
at ¶¶ 87-88)
III. Checklist Item 5: Transport
III.A. Dark Fiber (Order at ¶ 93)
IV. Checklist Item 14: Resale
IV.A. ASCENT Decision (Order at ¶¶ 94-97)
Vermont
Commission Identified Compliance Review Subjects8
I. Checklist Item 2: Unbundled Network Elements
I.A. Pricing
I.A.1. Switching Rates (Order at ¶¶ 28-36)
I.A.2. Daily Usage Feed Rates (Order at ¶¶ 37-38)
I.B. OSS
I.B.1. Order Accuracy (Order at ¶ 41)
I.B.2. Completion Notifiers (Order at ¶ 42)
I.B.3. Provisioning (Order at ¶ 43)
I.C. UNE Combinations (Order at ¶ 44) Maine
Commission Identified Compliance Review Subjects9
I. Checklist Item 2: Unbundled Network Elements
I.A. Pricing of Network Elements
I.A.1. DUF Rate (See Maine Order (``Order'') at ¶¶
22-25)
I.A.2. Switching Rates (Order at ¶¶ 26-30)
I.B. OSS
I.B.1. Order Accuracy (Order at ¶¶ 37-38)
I.B.2. Flow-Through (Order at ¶¶ 39-40)
I.C. Billing (Order at ¶ 41)
I.D. UNE Combinations (Order at ¶¶ 42-43)
II. Checklist Item 4: Unbundled Local Loops
II.A. xDSL Loops
II.A.1. Percentage of Installation Troubles (Order at
¶ 47)
II.A.2. Network Trouble Report Rate (Order at ¶ 47)
II.B. Digital Loops
II.B.1. Installation Troubles Reported (Order at ¶ 48)
II.B.2. Network Trouble Report Rate (Order at ¶ 48-49)
II.C. High Capacity Loops
II.C.1. Network Trouble Report Rate (Order at ¶ 50)
II.C.2. Digital Loops
II.C.3. Installation Troubles (Order at ¶¶ 80-81)
II.C.4. Repeat Troubles (Order at ¶¶ 80-81)
II.D. Voice-Grade Loops
II.D.1. Repeat Trouble Reports (Order at ¶ 85)
II.D.2. Provisioning Timeliness (Order at ¶ 86)
II.E. High Capacity Loops - Provisioning Quality (Order
at ¶¶ 87-88)
Pennsylvania
Commission-Identified Compliance Review Subjects10
I. Checklist Item 2: Unbundled Network Elements
A. OSS
1. Billing
a. Service Usage (See Pennsylvania
Order (``Order``) at ¶ 14)
b. Wholesale Bills (Order at ¶¶ 15-42)
2. Billing Notifiers (Order at ¶¶ 43-44)
3. Access to Loop Qualification Information
(Order at ¶¶ 45-47)
4. Flow-Through (Order at ¶¶ 48-49)
B. Pricing of Network Elements (Order at ¶¶ 53-
72)
C. Provision of UNE Combinations (Order at ¶¶ 73-
75)
II. Checklist Item 4: Unbundled Local Loops
II.A. xDSL-Capable Loops (Order at ¶¶ 79-84)
II.B. Digital Loops (Order at ¶ 85)
II.C. Hot Cut Activity (Order at ¶ 86)
II.D. Voice Grade Loops (Order at ¶ 87)
II.E. Line Sharing (Order at ¶ 88)
II.F. Line Splitting (Order at ¶ 89)
II.G. High Capacity Loops (Order at ¶¶ 90-92)
III. Checklist Item 5: Unbundled Local Transport (Order
at ¶¶ 109-113)
IV. Checklist Item 14: Resale (Order at ¶¶ 93-98)
New Jersey
Commission-Identified Compliance Review Subjects11
I. Checklist Item 2: Unbundled Network Elements
I.A. Pricing of Unbundled Network Elements
1. Recurring Charges
a. Loop Rates (See New Jersey Order
(``Order'') at ¶¶ 25-31)
b. Switching Rates (Order at ¶¶ 32-55)
c. Daily Usage File (DUF) Rates (Order at ¶¶
56-60)
2. Non-Recurring Charges (Order at ¶¶ 61-73)
a. ``Hot Cut'' Charges (Order at ¶¶ 61-68)
b. Feature Change Service Order Charge
(Order at ¶¶ 69-73)
B. OSS
1. Order Processing Notifiers (Order at ¶¶ 93-97)
a. Timeliness of Confirmation and Reject
Notices (Order at ¶¶ 98-101)
b. Order Completion Notifiers
1) Accuracy of Order Completion
Notifiers (Order at ¶¶ 103-109)
2) Timeliness of Order Completion
Notifiers (Order at ¶¶ 110-117)
3) Notifier Trouble Tickets (Order at
¶¶ 118-120)
2. Wholesale Billing (Order at ¶¶ 121-129)
3. Order Flow-Through and Reject Rate (Order at
¶¶ 130-134)
II. Checklist Item 4: Unbundled Local Loops
A. Voice Grade Loops (Order at ¶¶ 139-141)
B. Hot Cut Activity (Order at ¶¶ 142-143)
C. xDSL-Capable Loops (Order at ¶¶ 144-145)
D. Digital Loops (Order at ¶¶ 146-147)
E. High Capacity Loops (Order at ¶¶ 148-151)
F. Line Sharing and Line Splitting (Order at ¶¶ 152-
153)
_________________________
1 Those states include New York, Massachusetts, Connecticut,
Rhode Island, Vermont, Maine and New Hampshire. We note that
Verizon's section 271 application to provide interLATA services
originating in New Hampshire is pending.
2 Those states include Pennsylvania, New Jersey, Delaware,
Maryland, Virginia, West Virginia, and the District of Columbia.
We note that Verizon's section 271 application to provide
interLATA services originating in Delaware is pending.
3 We note that Verizon received section 271 approval in some
states - New York, Massachusetts, and Connecticut - more than
twelve months ago. Consequently, Verizon's post-approval
performance in these states will generally not be considered in
the context of the Compliance Review phases outlined above.
Rather, the Bureau will arrange a meeting with Verizon to review
areas of concern in each of these states as discussed in the
relevant section 271 decisions.
4 States (such as Pennsylvania) in which Verizon received
section 271 approval within the last six to twelve month period
will be folded into the Compliance Review Program at Phase II.
5 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 Massachusetts Order or in
this Attachment.
A-1
6 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 Connecticut Order or in
this Attachment.
A-2
7 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 Rhode Island or in this
Attachment.
A-3
8 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 Vermont Order or in this
Attachment.
A-4
9 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 Maine Order or in this
Attachment.
A-5
10 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 Pennsylvania Order or in
this Attachment.
B-1
11 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 New Jersey Order or in
this Attachment.
B-2