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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 10, 2003


VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED
and FACSIMILE (202) 408-4805

Michelle Thomas
Executive Director
Federal Regulatory
SBC Communications, Inc.
1401 I Street, N.W., Suite 1100
Washington, DC 20005

Re:  Consolidated Section  271  Compliance  Review  Programs  for 
California and Nevada
     EB-02-IH-0856 and EB-03-IH-0085

Dear Ms. Thomas:

     This letter memorializes discussions held during a telephone 
conference on May 20, 2003, among representatives of SBC 
Communications, Inc. (``SBC'') and the Enforcement Bureau 
(``Bureau'').1  The discussions focused on (a) consolidating the 
Bureau's Section 271 Compliance Programs for California2 and 
Nevada3; and (b) establishing the categories of information that 
SBC shall produce to the Bureau, and the deadlines for doing so, 
pursuant to a Consolidated Section 271 Compliance Program for 
both states.  

     As a result of our discussions, we hereby establish the 
following schedule, which will henceforth govern SBC's 
submissions during Phase 1 of the Bureau's Consolidated Section 
271 Compliance Program for California and Nevada.4 
I.  MONTHLY SUBMISSIONS 

     A.  Information to be Produced on a Monthly Basis for 
California

          1.  Monthly Performance Measurement Reports:  
     Commencing in January 2003 and continuing through, at a 
     minimum, March 1, 2004, SBC shall provide directly to the 
     Bureau complete and final copies of  its monthly Section 271 
     Performance Measurement Tracking Report for California 
     (``PMT Report'') and its Hit or Miss Report (``HOMR'').  
     Each monthly PMT Report shall contain performance 
     measurement data accompanied by appropriate charts analyzing 
     SBC's performance over the preceding 12-month period.  Each 
     monthly HOMR submission shall contain data in side-by-side 
     format with the last column identifying the number of 
     performance failures over the preceding three-month period.  
     In addition, the HOMR report shall contain both CLEC and SBC 
     volumes.  SBC shall provide all reports in hard copy and on 
     computer disc in Microsoft® Excel format.  SBC shall submit 
     all such materials to the Bureau no later than five (5) 
     business days after the date on which SBC has delivered 
     copies of the same materials to the California State Public 
     Utility Commission.  SBC shall provide all corrections or 
     restatements to the Bureau within five (5) business days of 
     the date the data is corrected or restated.  All corrections 
     or restatements shall include an explanation of the reason 
     for the correction or restatement.  SBC will inform the 
     Bureau of all changes to the business rules governing its 
     performance measurements within five (5) business days of 
     such modifications.  SBC will also submit to the Bureau the 
     results of all audits of its California performance 
     measurement data.  SBC shall direct all such information to:  
     Connie Hellmer, Investigations & Hearings Division, 
     Enforcement Bureau, Federal Communications Commission, 445 
     12th Street, S.W., Room 3-A336, Washington, D.C.  20054.  
     SBC shall also concurrently transmit the information via e-
     mail to Ms. Hellmer at: Connie.Hellmer@fcc.gov.   

          SBC shall comply with the foregoing filing obligations 
     through March 1, 2004.  The Bureau will inform SBC if SBC 
     must continue with some or all of the foregoing filing 
     obligations beyond that date.  

          2.  Performance Incentive Plan Payment Reports:  
     Commencing in January 2003 and continuing through, at a 
     minimum, March 1, 2004, SBC shall provide directly to the 
     Bureau complete and final copies of all reports that SBC 
     submits, formally or informally, to the California State 
     Public Utility Commission or staff thereof, including, but 
     not limited to, its Poison Ivy Report, its PB Performance 
     Incentive Report for California (commonly referred to as 
     ``Jungle Spider Report''), its Sage Green Report, and its 
     Extended Chronic Deficiencies Report.  SBC shall provide all 
     reports in hard copy and on computer disc in Microsoft® 
     Excel format.  SBC shall submit all such materials to the 
     Bureau no later than five (5) business days after the date 
     on which SBC has delivered the same materials to the 
     California State Public Utilities Commission or staff 
     thereof.  SBC shall provide all corrections or restatements 
     to the Bureau within five (5) business days of the date the 
     data is corrected or restated.  All corrections or 
     restatements shall include an explanation of the reason for 
     the correction or restatement.  SBC shall send the reports 
     to Ms. Hellmer at the above-referenced address.  SBC shall 
     also concurrently transmit the reports via e-mail to Ms. 
     Hellmer at the above-referenced e-mail address.

          SBC shall comply with the foregoing filing obligations 
     through March 1, 2004.  The Bureau will inform SBC if SBC 
     must continue with some or all of the foregoing filing 
     obligations beyond that date.        

     B.  Information to be Produced on a Monthly Basis for Nevada

          1.  Monthly Performance Measurement Reports:  
     Commencing in April 2003, and continuing through, at a 
     minimum, March 1, 2004, SBC shall provide directly to the 
     Bureau complete and final copies of  its monthly Section 271 
     Performance Measurement Tracking Report for Nevada (``PMT 
     Report'') and its Hit or Miss Report (``HOMR'').  Each 
     monthly PMT Report shall contain performance measurement 
     data accompanied by appropriate charts analyzing SBC's 
     performance over the preceding 12-month period.  Each 
     monthly HOMR submission shall contain data in side-by-side 
     format with the last column identifying the number of 
     performance failures over the preceding three-month period.  
     In addition, the HOMR report shall contain both CLEC and SBC 
     volumes.  SBC shall provide all reports in hard copy and on 
     computer disc in Microsoft® Excel format.  SBC shall submit 
     all such materials to the Bureau no later than five (5) 
     business days after the date on which SBC has delivered 
     copies of the same materials to the Nevada Public Utilities 
     Commission.  SBC shall provide all corrections or 
     restatements to the Bureau within five (5) business days of 
     the date the data is corrected or restated.  All corrections 
     or restatements shall include an explanation of the reason 
     for the correction or restatement.  SBC will inform the 
     Bureau of all changes to the business rules governing its 
     performance measurements within five (5) business days of 
     such modifications.  SBC will also submit to the Bureau the 
     results of all audits of its Nevada performance measurement 
     data.  SBC shall direct all such information to:  Connie 
     Hellmer, Investigations & Hearings Division, Enforcement 
     Bureau, Federal Communications Commission, 445 12th Street, 
     S.W., Room 3-A336, Washington, D.C.  20054.  SBC shall also 
     concurrently transmit the information via e-mail to Ms. 
     Hellmer at:  Connie.Hellmer@fcc.gov.  

          SBC shall comply with the foregoing filing obligations 
     through March 1, 2004.  The Bureau will inform SBC if SBC 
     must continue with some or all of the foregoing filing 
     obligations beyond that date 

          2.  Performance Incentive Plan Payment Reports:  
     Commencing in April 2003 and continuing for each month 
     thereafter through, at a minimum, March 1, 2004, SBC shall 
     provide directly to the Bureau complete and final copies of 
     all reports that SBC submits, formally or informally, to the 
     Nevada Public Utilities Commission or staff thereof, 
     including, but not limited to, its Sage Green Report, and 
     any reports regarding chronic and extended chronic 
     deficiencies.   SBC shall provide all reports in hard copy 
     and on computer disc in Microsoft® Excel format.  SBC shall 
     submit all such materials to the Bureau no later than five 
     (5) business days after the date on which SBC has delivered 
     the same materials to the Nevada State Public Utilities 
     Commission or staff thereof.  SBC shall provide all 
     corrections or restatements to the Bureau within five (5) 
     business days of the date the data is corrected or restated.  
     All corrections or restatements shall include an explanation 
     of the reason for the correction or restatement.  SBC shall 
     send the reports to Ms. Hellmer at the above-referenced 
     address.  SBC shall also concurrently transmit the reports 
     via e-mail to Ms. Hellmer at the above-referenced e-mail 
     address.

          SBC shall comply with the foregoing filing  obligations 
     through March 1, 2004.   The Bureau will  inform SBC if  SBC 
     must continue  with  some or  all  of the  foregoing  filing 
     obligations beyond that date.        

II.  PHASE 1 SUBMISSION

     A.  Overview

     The Consolidated Phase 1 Review for California and Nevada 
shall encompass, as to SBC's compliance in California, the period 
from the date of release of the California Order through August 
29, 2003, and, as to SBC's compliance in Nevada, the period from 
the date of release of the Nevada Order through August 29, 2003.  
On August 29, 2003, SBC shall produce to the Bureau its 
Consolidated Phase I Review Submission containing, at a minimum, 
the information identified below.  At any time during the 
Consolidated Phase 1 Review for California and Nevada, the Bureau 
may require SBC to provide additional information not referenced 
below.  Such information may relate to, or serve to supplement, 
the information referenced below or encompass new inquiries.  In 
addition, at any time during the Consolidated Phase 1 Review for 
California and Nevada, the Bureau may require SBC to arrange for 
certain of its employees with subject matter expertise to meet 
with Commission personnel.  

     B.  Information to be Produced on August 29, 2003

     SBC's Consolidated Phase 1 Review Submission for California 
and Nevada shall consist of the following: (a) a narrative 
discussion of SBC's compliance, covering the period from the date 
of release of the California Order through August 29, 2003, with 
the conditions of its approval to provide in-region, interLATA 
long distance service in California contained in the California 
Order; (b) a narrative discussion of SBC's compliance, covering 
the period from the date of release of the Nevada Order through 
August 29, 2003, with the conditions of its approval to provide 
in-region, interLATA long distance service in Nevada contained in 
the Nevada Order; (c) a thorough analysis, accompanied by 
supporting data (as applicable), relating to SBC's performance in 
California during the period from the date of release of the 
California Order through August 29, 2003; and (d) a thorough 
analysis, accompanied by supporting data (as applicable), 
relating to SBC's performance in Nevada during the period from 
the date of release of the Nevada Order to August 29, 2003.  Such 
analysis and data shall encompass, at a minimum, the checklist 
items and other information requests identified below for the two 
states.  For the performance measurement-related items, SBC's 
Consolidated Phase 1 Review Submission shall also include, for 
each state, the number of observations or volumes, both SBC and 
CLEC, for each month subsequent to the grant of Section 271 
authority.  

     SBC shall submit its Consolidated Phase 1 Review Submission 
in hard copy and on computer disc in Microsoft® Excel and Word 
formats, as appropriate.  SBC shall direct its Consolidated Phase 
1 Review Submission to: Gary Schonman and Connie Hellmer, 
Investigations and Hearings Division, Enforcement Bureau, Federal 
Communications Commission, 445 12th Street, S.W., Room 3B-443, 
Washington, D.C. 20054.  SBC shall also concurrently transmit the 
information via e-mail to Mr. Schonman and Ms. Hellmer at: 
Gary.Schonman@fcc.gov and Connie.Hellmer@fcc.gov.

          C.  California Checklist Items

          Checklist Item 2:  Unbundled Network Elements

          Pre-Ordering
               · PM 1 - Average Response Time (to pre-Order 
                 Queries)
               · PM 3 - Average Reject Notice Interval

          Ordering and Provisioning
               · PM 2 - Average FOC/LSC Notice Interval - 
                 Electronic/Manual
               · PM 6 - Average Jeopardy Notice Interval
               · PM 11 - Percent of Due Dates Missed - UNE-P
               · PM 18 - Average Completion Notice Interval

          Maintenance and Repair
               · PM 19 - Customer Trouble Report Rate
               · PM 21 - Average Time to Restore
               · PM 32 - Frequency of Repeat Trouble in 30-Day 
                 Period

          Billing
               · PM 31 - Usage Completeness
               · PM 32 - Recurring Charge Completeness
               · PM 33 - Non-Recurring Charge Completeness
               · PM 34 - Bill Accuracy

          Checklist Item 4:  Unbundled Local Loops

               · PM 20 - High Capacity Loops: Percentage of 
                 Customer Troubles Not Resolved Within Estimated 
                 Time
               · PM 21 -  High Capacity Loops: Average Time to 
                 Restore

          Checklist Item 11:  Local Number Portability

               · PM 15 - Time to Restore Provisioning Troubles
               · PM 17 - Percentage Trouble in 10 Days for Non-
                 Special Orders

     D.  Other Information Requests for California

          Billing Adjustments

          SBC shall provide to the Bureau a full and 
          complete description of all billing adjustments 
          since the release of the aforementioned MO&O that 
          were previously performed manually but 
          subsequently performed electronically.

          Change Management and Technical Assistance

          SBC shall provide to the Bureau copies of all 
          orders, instructions or guidelines issued by any 
          state public utility commission in any SBC region 
          since the release of the aforementioned MO&O 
          relating to SBC's Change Control Process or SBC's 
          operation of that Change Control Process.  SBC's 
          submission shall also include the minutes of any 
          change control plan meetings held at the direction 
          of any state public utility commission in any SBC 
          region. 

          Voice Grade Loops and High Capacity Loops

          SBC shall provide to the Bureau a Status Report 
          describing the status of operational modifications 
          or revisions implemented to improve maintenance of 
          voice-grade loops and of high-capacity loops.  

          Local Number Portability

          SBC shall provide to the Bureau a Status Report 
          describing the status of the implemented 
          mechanized NPAC check required by the California 
          Public Utility Commission.  

          Primary Interexchange Carrier

          SBC shall provide to the Bureau the final report 
          on the investigation initiated by the California 
          Public Utility Commission into SBC's PIC 
          administration practices to assess the feasibility 
          and need for the creation of a third-party PIC 
          administrator.
     
          Deficient Performance Measurements 

          SBC shall provide to the Bureau a full and complete 
          explanation for its deficient performance relating to 
          the metrics identified below and a detailed description 
          of all enhancements or actions that SBC has taken or is 
          considering taking , if any, to remedy its deficient 
          performance in these areas:

               · PM 15a-1691400 - Average Time to Restore 
                 Provisioning Troubles (Prior to Service Order 
                 Completion)
               · PM 19-1993600 - Customer Trouble Report Rate:  
                 Statewide Platform Basic Port and Loop
               · PM 19-1994100 - Customer Trouble Report Rate:  
                 Statewide UNE Loop 2-Wire Digital Line Sharing
               · PM 21-2196001 - Average Time to Restore:  
                 Statewide UNE Loop 4-Wire Digital 1.544
               · PM 21-2197401 - Average Time to Restore:  
                 Statewide UNE Platform Basic Port
               · PM 23-2392801 - Frequency of Repeat Troubles in 
                 a 30-Day Period:  Statewide UNE Loop 2-Wire 
                 Digital XDSL Capable
               · PM 23-2394000 - Frequency of Repeat Troubles in 
                 a 30-Day Period:  Statewide UNE Loop 2-Wire 
                 Digital Line Sharing

     E.  Nevada Checklist Items

          Checklist Item 2 - Unbundled Network Elements

          Pre-Ordering
               · PM 1 - NV Average Response Time

          Ordering and Provisioning
               · PM 2 - CA Average FOC/LSC Notice Interval
               · PM 6 - CA Average Jeopardy Notice Interval
               · PM 11 - CA Percent of Due Dates Missed

          Maintenance and Repair
               · PM 19 - CA Customer Trouble Report Date
               · PM 20 - CA Percentage of Customer Trouble 
                  Not Resolved Within   Estimated Time
               · PM 21 - CA Average Time to Restore
               · PM 23 - CA Frequency of Repeat Troubles in 
                  30-Day Period

          Checklist Item 4 - Unbundled Local Loops

          Voice-Grade Loops 
               · PM 23-2392601 - CA Frequency of Repeat 
                 Troubles Within 30 Days

          High-Capacity Loops 
               · PM 5-523300 - CA Percent of Orders Given 
                 Jeopardy Notice
               · PM 11 - CA Percent of Due Dates Missed
               · PM 12 - CA Percent of Due Dates Missed Due 
                 to Lack of Facilities
               · PM 21-2195801 - CA Average Time to Restore
               · PM 23-2392801 - CA Frequency of Repeat 
                 Troubles in a 30-Day Period
               · PM 1-105600 - CA Average Time to Pre-Order 
                 Mechanical Loop 

          Qualification Actual - Verigate
               · PM  1-106007 - CA Average Time to Pre-
                 Order Mechanical Loop 

          Qualification Actual - EDI-CORBA
               · PM 6-648200 - CA Average Jeopardy Notice 
                 Interval
               · PM 21-2196001 - CA Average Time to Restore 
                 UNE Loop 4-WireDigital HDSL

          Checklist Item 1 - Interconnection

               · PM 24 - 240010 - NV Percent Blocking on 
                 Common Trunks

     F.  Other Information Requests for Nevada

          Deficient Performance Measurement 

          SBC shall provide to the Bureau a full and complete 
          explanation for its deficient performance relating to 
          the metric identified below and a detailed description 
          of all enhancements or actions that SBC has taken or is 
          considering taking, if any, to remedy its deficient 
          performance in this area:

               · PM 7- 705900 - Average Completion Interval:  
                 Interconnection Trunks


III.  PHASE II SUBMISSION

     The Consolidated Phase II Review for California and Nevada 
shall encompass, as to SBC's compliance in California, the period 
from the date of release of the California Order through March 1, 
2004, and, as to SBC's compliance in Nevada, the period from the 
date of release of the Nevada Order through March 1, 2004.  On 
March 1, 2004, SBC shall produce to the Bureau its Consolidated 
Phase II Review Submission containing information to be described 
in a subsequent directive from the Bureau.  At the present time, 
the Bureau anticipates that SBC will be required to provide in 
its Consolidated Phase II Review Submission, at a minimum, 
updated information of that required to be filed by SBC in its 
Consolidated Phase I Submission.  

     Thank you for your cooperation during the Bureau's 
Consolidated Compliance Review of California and Nevada.  If you 
have any questions, please contact Gary Schonman of my staff at 
202-418-1795.

                              Sincerely,



                              William H. Davenport
                              Deputy Division Chief              
                              Investigations     and     Hearings 
                         Division
                              Enforcement Bureau
_________________________

1  We acknowledge receipt of SBC's follow-up letter to the May 
20, 2003, conference call.  See Letter from Paul M Beck, 
Associate Director - Federal Regulatory, SBC Telecommunications, 
Inc., to Constance Heller, Auditor, Investigations and Hearings 
Division, Enforcement Bureau, FCC, dated May 21, 2003.

2  The Bureau commenced its Section 271 Compliance Program for 
California following the Commission's grant of SBC's application 
to provide in-region, interLATA long distance service in 
California.  See In the Matter of Application by SBC 
Communications, Inc., Pacific Bell Telephone Company, and 
Southwestern Bell Communications Services Inc., for Authorization 
to Provide In-Region InterLATA Services in California, FCC 02-330 
(rel. December 19, 2002) (``California Order'').

3  The Bureau commenced its Section 271 Compliance Program for 
Nevada following the Commission's grant of SBC's application to 
provide in-region, interLATA long distance service in Nevada.  
See In the Matter of Application by SBC Communications Inc., 
Nevada Bell Telephone Company, and Southwestern Bell 
Communications Services, Inc., for Authorization To Provide In-
Region, InterLATA Services in Nevada,  FCC 03-80 (rel. April 14, 
2003) (``Nevada Order'').

4  The schedule set forth herein applicable to SBC's submission 
of information for California supercedes all previously specified 
deadlines.  No deadlines have previously been established for the 
submission of information by SBC for Nevada.