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Mr. Gerald Asch
Director - Federal Regulatory
Verizon Communications, Inc.
1300 I Street, N.W.
Suite 400 West
Washington, D.C. 20005
RE: Section 271 Compliance Review Program for Section 271-
Approved States in the Verizon Region
Dear Mr. Asch:
Since passage of the Telecommunications Act of 1996, the
Commission has granted Verizon authorization, pursuant to section
271, to provide interLATA services in eleven states within its
region - New York, Massachusetts, Connecticut, Pennsylvania,
Rhode Island, Vermont, Maine, New Jersey, New Hampshire,
Delaware, and Virginia. On July 2, 2002, we sent you a letter
regarding the Enforcement Bureau's Section 271 Compliance Review
Program for the eight states approved at that time.1 We now
include the three recently approved states -- New Hampshire,
Delaware, and Virginia -- in that program.2
The Enforcement Bureau (``the Bureau'') will monitor
Verizon's continuing compliance with section 271 in each approved
state. 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 Dana
Leavitt, Attorney, and Jeff Stover, Auditor, for the former Bell
Atlantic North states3; and Raelynn Tibayan Remy, Attorney, and
Sherry Herauf, Auditor, for the former Bell Atlantic South
states.4
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 each 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 concern in its decisions covering
New Hampshire, Delaware, and Virginia. Although the Enforcement
Bureau will focus its review on these areas, it may also monitor
other areas not noted by the Commission in its orders.
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. Following Verizon's
receipt of this letter, a representative from the Bureau will
contact the company to schedule a planning meeting or conference
call 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.
Phase 2: The Phase II review will occur during the second
six-month period after the grant. This phase of the review could
include the issuance of a request for information directing
Verizon to update information submitted previously, or to provide
additional information concerning its performance since the Phase
I review. The information responsive to such a request will be
due at the end of the Phase II review period. As in Phase I, 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 information the Team may have required in Phase
2.
At any time during this review, the Team may ask Verizon to
provide additional information or to attend meetings or
conference calls 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 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
New Hampshire
Commission Identified Compliance Review Subjects5
I. Checklist Item 2: Unbundled Network Elements
A. Pricing of Unbundled Network Elements (See Verizon New
Hampshire/Delaware Order at ¶¶ 34-65)
B. Operations Support Systems
1. Order Processing Notifiers (id. at ¶¶ 99-101)
2. Flow-through (id. at ¶ 102)
3. Billing Accuracy (id. at ¶ 103)
II. Checklist Item 4: Unbundled Local Loops
A. High Capacity Loops (id. at ¶¶ 112-114)
B. Digital Loops (id. at ¶¶ 116-117)
C. Dark Fiber (id. at ¶¶ 118-122)
Delaware
Commission Identified Compliance Review Subjects6
I. Checklist Item 2: Unbundled Network Elements
A. Pricing of Unbundled Network Elements
1. Switching Rates (See Verizon New Hampshire/Delaware
Order at ¶¶ 74-80)
2. Loop Rates (id. at ¶ 81)
3. Non-Recurring Charges (id. at ¶¶ 82-92)
II. Checklist Item 4: Unbundled Local Loops
A. Voice-Grade Loops (id at ¶¶ 108-110)
B. Hot Cut Activity (id at ¶ 111)
C. Digital Loops (id at ¶ 115) Virginia
Commission Identified Compliance Review Subjects7
I. Checklist Item 2: Unbundled Network Elements
A. OSS
1. Pre-Ordering - Loop Qualification Information (See
Verizon Virginia Order at ¶¶ 28-37)
2. Wholesale Billing
a. Complete, Accurate and Auditable Carrier Bills (id
at ¶¶ 41-47)
b. Double Billing (id at ¶ 48)
c. Billing Dispute Resolution (id at ¶¶ 49-52)
d. Other Billing Issues (id at ¶¶ 53-55)
3. Change Management (id at ¶¶ 56-58)
B. UNE Combinations (id at ¶¶ 59-61)
C. Pricing of Unbundled Network Elements
1. Recurring Loop Rates (id at ¶¶ 90-95)
2. Recurring Non-Loop Rates (id at ¶¶ 96-121)
3. Non-Recurring Charges (id at ¶¶ 122-131)
4. Entrance Facility Rate (id at ¶¶ 132-133)
· II. Checklist Item 4: Unbundled Local Loops
A. High Capacity Loops (id. at ¶¶ 140-144)
B. Dark Fiber (id. at ¶¶ 145-147)
C. Voice Grade Loops (id. at ¶ 148)
D. xDSL Loops (id. at ¶ 149)
E. Other Loop Issues (id. at ¶ 150)
F. Line Sharing and Line Splitting (id. at ¶ 151)
III. Checklist Item 8: White Pages
A. Processing Errors (id. at ¶¶ 155-166)
B. Use of Listing Verification Process (id at ¶¶ 167-168)
C. Alpha/Numeric Listing Identifiers (id at ¶¶ 169-170)
_________________________
1 See Letter from Maureen F. Del Duca, Deputy Chief,
Investigations and Hearings Division, Enforcement Bureau, to
Gordon R. Evans, Vice President, Federal Regulatory, Verizon,
dated July 2, 2002 (``July 2, 2002 Letter'').
2 See Application by Verizon-New England, Inc., et al., for
Authorization to Provide In-Region, InterLATA Services in New
Hampshire and Delaware, Memorandum Opinion and Order, FCC 02-262
(rel. Sept. 25, 2002) (``Verizon New Hampshire/Delaware Order'');
Application by Verizon Virginia Inc., et al., for Authorization
to Provide In-Region, InterLATA Services in Virginia, Memorandum
Opinion and Order, FCC 02-297 (rel. Oct. 30, 2002) (``Verizon
Virginia Order'').
3 Those states include New York, Massachusetts, Connecticut,
Rhode Island, Vermont, Maine, and New Hampshire. We note that
all of the states in the former Bell Atlantic North region have
now received section 271 approval.
4 Those jurisdictions include Pennsylvania, New Jersey,
Delaware, Maryland, Virginia, West Virginia, and the District of
Columbia.
5 The Bureau may monitor for enforcement purposes other
subjects or performance indicators not expressly noted by the
Commission in the Verizon New Hampshire/Delaware Order or this
letter.
6 The Bureau may monitor for enforcement purposes other
subjects or performance indicators not expressly noted by the
Commission in the Verizon New Hampshire/Delaware Order or this
letter.
7 The Bureau may monitor for enforcement purposes other
subjects or performance indicators not expressly noted by the
Commission in the Verizon Virginia Order or this letter.