Click here for Adobe Acrobat version
Click here for Microsoft Word version
********************************************************
NOTICE
********************************************************
This document was converted from Microsoft Word.
Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.
All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.
Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.
If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.
*****************************************************************
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 all of the states within
its region - New York, Massachusetts, Connecticut, Pennsylvania,
Rhode Island, Vermont, Maine, New Jersey, New Hampshire,
Delaware, Virginia, West Virginia, Maryland and Washington, D.C.
On July 2, 2002 and January 23, 2003, we sent Verizon letters
regarding the Enforcement Bureau's Section 271 Compliance Review
Program for the eleven states approved at that time.1 We now
include the three recently approved states - Maryland, Virginia
and the District of Columbia -- 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 Trent
Harkrader, Attorney, and Jeff Stover, Auditor, for the former
Bell Atlantic North states3; and Raelynn Tibayan Remy, Attorney,
Andrew Skadin, Auditor, and Austin O'Connor, Auditor, for the
former Bell Atlantic South states.4
During the review, the Team will closely monitor 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 decision covering
Maryland, Washington, D.C. and West 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
Chief, Investigations and
Hearings Division
Enforcement Bureau
Maryland, Washington, D.C., West Virginia
Commission Identified Compliance Review Subjects5
I. Checklist Item 2: Unbundled Network Elements
A. Operations Support Systems
1. Ordering (Verizon MD/DC/WVA Order at ¶¶ 21-24)
2. Provisioning (id. at ¶ 25)
3. Wholesale Billing (id. at ¶¶ 26-34)
4. Maintenance and Repair (id. at ¶¶ 35-36)
5. UNE Combinations (id. at ¶¶ 37-38)
B. Pricing (id. at ¶¶ 39-96)
II. Checklist Item 12: Dialing Parity (id. at ¶¶ 97-101)
III. Checklist Item 1: Interconnection (id. at ¶¶ 102-
118)
IV. Checklist Item 4: Unbundled Local Loops
IV.A. xDSL Loops, Digital Loops, Voice Grade Loops, and
Hot Cuts (id. at ¶ 121)
IV.B. High-Capacity Loops (id. at ¶ 122)
IV.C. Dark Fiber (id. at ¶¶ 123-126)
V. Checklist Item 7: 911-E911 Access and Directory
Assistance/Operator Services (id. at ¶¶ 127-128)
VI. Checklist Item 8: White Pages (id. at ¶¶ 129-137)
VII. Checklist Item 10: Databases and Associated Signaling
(id. at ¶¶ 138-139)
VIII. Checklist Item 11: Number Portability (id. at ¶¶ 140-
142)
IX. Checklist Item 13: Reciprocal Compensation (id. at ¶¶ 143-
152)
X. Checklist Item 14: Resale (id. at ¶¶ 153-158)
_________________________
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''); Letter from
Maureen F. Del Duca, Acting Chief, Investigations and Hearings
Division, Enforcement Bureau, to Gerald Asch, Director, Federal
Regulatory, Verizon, dated January 23, 2003 (``January 23, 2003
Letter'').
2 See Application by Verizon Maryland Inc., Verizon Washington,
D.C. Inc, Verizon West Virginia Inc. et al. for Authorization to
Provide In-Region, InterLATA Services in Maryland, Washington,
D.C. and West Virginia,, Memorandum Opinion and Order, FCC 03-37
(rel. March 19, 2003) (``Verizon MD/DC/WVA Order'').
3 Those states include New York, Massachusetts, Connecticut,
Rhode Island, Vermont, Maine, and New Hampshire.
4 Those jurisdictions include Pennsylvania, New Jersey, Delaware,
Maryland, Virginia, West Virginia, and Washington, D.C.
5 The Bureau may monitor for enforcement purposes other
subjects or performance indicators not expressly noted by the
Commission in the Verizon MD/DC/WVA Order or this letter.