# PUBLIC NOTICE

FEDERAL COMMUNICATIONS COMMISSION

445 12th Street, S.W.

WASHINGTON, D.C. 20554

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
**[DA 99-2480]{.underline}**

News media information 202/418-0500 Fax-On-Demand 202/418-2830 Internet:
http://www.fcc.gov ftp.fcc.gov TTYs-Network Services 202/418-0484 and
Informal Complaints 202/418-0485

**OVERSIGHT TEAM CREATED TO MONITOR SBC's COMPLIANCE WITH MERGER
CONDITONS**

#### ASD 99-49

### Released: November 8, 1999

The Commission staff has established a team composed of members of the
Common Carrier Bureau and the Enforcement Bureau to monitor SBC
Communications Inc.'s (SBC) compliance with the conditions associated
with its recent merger with Ameritech. The purpose of this team is
primarily three-fold. First, the team will actively monitor SBC\'s
compliance with the merger conditions and ensure that SBC is executing
the conditions consistently with the Commission\'s stated intent.
Second, the team will serve as a point of contact for state commissions,
competitors, and other interested parties to report any perceived
instances of possible noncompliance. This informal process will enable
the Commission to assist parties in quickly resolving disputes
concerning SBC\'s compliance with the merger conditions. Third, the team
will recommend appropriate enforcement action for any noncompliance by
SBC with the conditions.

On October 8, 1999 the Commission issued an order granting the
SBC/Ameritech merger subject to 30 conditions. These conditions were
designed to accomplish five public interest goals: promote equitable and
efficient advanced services deployment; ensure open local markets;
foster significant out-of-region competition for the first time by a
Bell Operating Company; improve residential phone service; and ensure
compliance with the enforcement of the conditions. A timeline showing
the dates for implementation of the conditions is attached to assist in
tracking progress under the Merger Conditions.[^1] The timeline, and
additional information related to oversight of the Merger Conditions, is
available on the Internet at http://www.fcc.gov/ccb/mcot/.

The team leaders of the merger oversight team are Anthony Dale, a senior
attorney in the Accounting Safeguards Division of the Common Carrier
Bureau and Radhika Karmarkar, Assistant Chief of the Market Disputes
Resolution Division, Enforcement Bureau The team will report to the
Chief of the Common Carrier Bureau and, with respect to possible
enforcement matters, to the Chief of the Enforcement Bureau. Mr. Dale,
<adale@fcc.gov>, and Radhika Karmarkar, rkarmark@fcc.gov, can be
contacted by phone at (202) 418-2260 and (202) 418-1628, respectively.
They can also be contacted by U.S. mail at the address listed above with
copies to the Chiefs of the Common Carrier and Enforcement Bureaus.

News media contacts: Michael Balmoris, CCB at (202) 418-0253 or John
Winston, EB at (202) 418-7450.

## By the Chiefs, Common Carrier Bureau and Enforcement Bureau 

# **SBC MERGER COMMITMENT IMPLEMENTATION TIMELINE**

+----------------------+-----------------------------------------------+
| **Date**             | **Required Action**                           |
+======================+===============================================+
| **Prior to the       | File for any state certifications or          |
| Merger Closing       | approvals necessary for the separate          |
| Date**               | affiliate(s) to provide Advanced Services     |
|                      | (¶¶ 4, 5)                                     |
+----------------------+-----------------------------------------------+
|                      | Negotiate agreements between Advanced         |
|                      | Services subsidiar(ies) and ILECs and file    |
|                      | them for approval (¶ 5)                       |
+----------------------+-----------------------------------------------+
|                      | Incorporate Advanced Services subsidiar(ies)  |
|                      | for SBC/Ameritech States (¶ 5)                |
+----------------------+-----------------------------------------------+
|                      | File a collocation tariff and/or offer        |
|                      | agreement amendments containing standard      |
|                      | terms and conditions for collocation (¶ 38)   |
+----------------------+-----------------------------------------------+
|                      | Retain one or more independent auditors to    |
|                      | examine and issue an attestation report       |
|                      | regarding the compliance with the collocation |
|                      | rules (¶ 39)                                  |
+----------------------+-----------------------------------------------+
|                      | Select an independent auditor to conduct a    |
|                      | full collocation compliance audit (¶ 40)      |
+----------------------+-----------------------------------------------+
|                      | Recommend to the Commission an independent    |
|                      | auditor to conduct the first annual           |
|                      | compliance review (¶ 66)                      |
+----------------------+-----------------------------------------------+
|                      | Engage an independent auditor to perform an   |
|                      | agreed-upon procedures review regarding       |
|                      | compliance with separate Advanced Services    |
|                      | affiliate requirements (¶ 67)                 |
+----------------------+-----------------------------------------------+
| **Friday, October 8, | Provide Advanced Services through separate    |
| 1999**               | affiliates in Ameritech States (¶ 6)          |
|                      |                                               |
| (Merger Closing      |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
|                      | Provide access to non-discriminatory,         |
|                      | electronic pre-order OSS access to            |
|                      | theoretical loop length on an individual      |
|                      | address basis, in all SBC States except       |
|                      | Connecticut and Nevada (¶ 20)                 |
+----------------------+-----------------------------------------------+
|                      | Provide the FCC with an OSS Process           |
|                      | Improvement Plan (¶ 25)                       |
+----------------------+-----------------------------------------------+
|                      | Continue providing UNEs under the same terms  |
|                      | and conditions that UNEs were made available  |
|                      | on January 24, 1999 (¶ 53)                    |
+----------------------+-----------------------------------------------+
|                      | File tariffs and/or offer amendments to       |
|                      | interconnection agreements to implement the   |
|                      | interim shared transport solution in the      |
|                      | Ameritech States (¶ 55)                       |
+----------------------+-----------------------------------------------+
|                      | Withdraw Ameritech's proposal for the FCC to  |
|                      | establish a separate transit service rate to  |
|                      | be charged in conjunction with shared         |
|                      | transport (¶ 55)                              |
+----------------------+-----------------------------------------------+
|                      | Continue participation in the Network         |
|                      | Reliability and Interoperability Council or a |
|                      | successor organization, if any (¶ 64)         |
+----------------------+-----------------------------------------------+
| **First billing      | Eliminate all flat-rate monthly charges for   |
| cycle** that begins  | access to the Remote Access Facility and the  |
| after the Merger     | Information Services Call Center, and extra   |
| Closing Date         | manual processing charges for access to       |
|                      | standard, non-electronic order processing     |
|                      | facilities used for orders of 30 lines or     |
|                      | less (¶ 35)                                   |
+----------------------+-----------------------------------------------+
| **Monday, October    | File tariffs necessary for the separate       |
| 18, 1999**           | Advanced Services affiliate to provide        |
|                      | Advanced Services that were provided by the   |
| (5 business days/10  | ILEC on October 8, 1999, in Ameritech States  |
| days after the       | (¶ 6)                                         |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
|                      | File tariffs necessary for the separate       |
|                      | Advanced Services affiliate to provide        |
|                      | Advanced Services to customers that are       |
|                      | providers of Internet services, in SBC States |
|                      | (¶ 6)                                         |
+----------------------+-----------------------------------------------+
|                      | File with the Secretary of the Commission the |
|                      | independent auditor's report(s) on            |
|                      | collocation terms and conditions and          |
|                      | associated methods and procedures (¶ 39)      |
+----------------------+-----------------------------------------------+
| **Monday, October    | Provide a written offer to amend each CLEC's  |
| 18, 1999**\          | interconnection agreement to incorporate the  |
| continued            | unbundled loop discount for                   |
|                      | carrier-to-carrier promotions (¶ 45)          |
+----------------------+-----------------------------------------------+
|                      | Provide a written offer to amend each CLEC's  |
|                      | interconnection agreement to incorporate the  |
|                      | resale discount for carrier-to-carrier        |
|                      | promotions (¶ 47)                             |
+----------------------+-----------------------------------------------+
|                      | Provide a written offer to amend each CLEC's  |
|                      | interconnection agreement to incorporate      |
|                      | carrier-to-carrier promotions for UNE         |
|                      | platforms (¶ 50)                              |
+----------------------+-----------------------------------------------+
| **Monday, October    | General effective date for conditions unless  |
| 25, 1999**           | otherwise specified (App. C at 1)             |
|                      |                                               |
| (10 business days    |                                               |
| following the Merger |                                               |
| Closing Date)        |                                               |
+----------------------+-----------------------------------------------+
|                      | Provide direct access to SORD, and            |
|                      | Ameritech's and SNET's equivalent service     |
|                      | order processing systems for pre-ordering and |
|                      | ordering xDSL and Advanced Services (¶ 15)    |
+----------------------+-----------------------------------------------+
|                      | Provide access to Ameritech's existing EDI    |
|                      | interface in Ameritech States (¶ 15)          |
+----------------------+-----------------------------------------------+
|                      | Offer to develop a method of direct access to |
|                      | SBC/Ameritech's service order processing      |
|                      | systems for requesting CLECs (¶ 29)           |
+----------------------+-----------------------------------------------+
|                      | Offer to develop and deploy enhancements to   |
|                      | the existing EBI interface for OSS that       |
|                      | support maintenance/repair (¶ 30)             |
+----------------------+-----------------------------------------------+
|                      | Provide collocation consistent with the       |
|                      | Commission's rules (¶ 37)                     |
+----------------------+-----------------------------------------------+
|                      | Implement waiver, credit, or refund to        |
|                      | telecommunications carriers of 100 percent of |
|                      | the total nonrecurring collocation costs for  |
|                      | qualifying collocation projects if            |
|                      | SBC/Ameritech misses the collocation due date |
|                      | by more than 60 calendar days (¶ 41)          |
+----------------------+-----------------------------------------------+
|                      | Offer to implement MFN provision based on     |
|                      | out-of-region agreements (¶ 42)               |
+----------------------+-----------------------------------------------+
|                      | Offer to implement MFN provision based on     |
|                      | in-region agreements (¶ 43)                   |
+----------------------+-----------------------------------------------+
|                      | Offer to negotiate an interconnection and/or  |
|                      | resale agreement covering the provision of    |
|                      | interconnection arrangements, services,       |
|                      | and/or UNEs in two or more SBC/Ameritech      |
|                      | States (¶ 44)                                 |
+----------------------+-----------------------------------------------+
|                      | Implement an alternative dispute resolution   |
|                      | process to resolve carrier-to-carrier         |
|                      | disputes, including disputes related to       |
|                      | existing and effective interconnection        |
|                      | agreements (¶ 54 & Attachment D)              |
+----------------------+-----------------------------------------------+
|                      | Offer to conduct a trial with one or more     |
|                      | interested, unaffiliated CLECs in each of     |
|                      | five large cities within the SBC/Ameritech    |
|                      | States to identify the procedures and         |
|                      | associated costs required to provide CLECs    |
|                      | with access to cabling within MDUs and        |
|                      | multi-tenant premises, where SBC/Ameritech    |
|                      | controls the cables (¶ 57)                    |
+----------------------+-----------------------------------------------+
|                      | Subject to owner approval, install and        |
|                      | provide the new cables in a manner that will  |
|                      | permit CLECs a single point of interface      |
|                      | (¶ 58)                                        |
+----------------------+-----------------------------------------------+
|                      | Appoint senior corporate compliance officer   |
|                      | to ensure deadlines being met (¶ 65)          |
+----------------------+-----------------------------------------------+
| **Monday, November   | Performance Measurements: Implement and       |
| 1, 1999**            | provide 2 months of performance data for      |
|                      | Performance Measurements shown on Attachments |
|                      | A-2a and A-5a in SBC States except            |
|                      | California, Nevada, and Connecticut (¶ 24)    |
+----------------------+-----------------------------------------------+
| **Monday, November   | Provide new activations of all non-xDSL       |
| 8, 1999**            | Advanced Services through separate affiliates |
|                      | in Ameritech States (compliance can be met 30 |
| (30 days after the   | days after approval of necessary tariffs,     |
| Merger Closing Date  | whichever is later) (¶ 6)                     |
| falls on Sunday,     |                                               |
| November 7)          |                                               |
+----------------------+-----------------------------------------------+
| **Monday, November   | Until SBC/Ameritech has developed and         |
| 8, 1999\             | deployed OSS options for pre-ordering and     |
| **continued          | ordering xDSL and other Advanced Services     |
|                      | components and the EDI interface is used by   |
|                      | the Advanced Services affiliate for           |
|                      | pre-ordering and ordering a substantial       |
|                      | majority of Advanced Services components,     |
|                      | make available through the inclusion of       |
|                      | appropriate terms in interconnection          |
|                      | agreements, a discount of 25 percent from the |
|                      | recurring and nonrecurring charges that       |
|                      | otherwise would be applicable for unbundled   |
|                      | local loops used to provide Advanced Services |
|                      | in the same relevant geographic area (¶ 18)   |
+----------------------+-----------------------------------------------+
|                      | Begin negotiation with interested CLECs a     |
|                      | uniform change management process. Twelve     |
|                      | months after the commencement of              |
|                      | negotiations, develop and offer to state      |
|                      | commissions a uniform change management       |
|                      | process for acceptance and approval, and      |
|                      | implement those aspects of the uniform change |
|                      | management process that are consistent with   |
|                      | state commission rulings, agreed-to with the  |
|                      | CLEC participants, and feasible (¶ 32)        |
+----------------------+-----------------------------------------------+
|                      | Designate and make available to qualifying    |
|                      | CLECs (for a minimum of 36 months) one or     |
|                      | more teams of a sufficient number of OSS      |
|                      | experts, provided such qualifying CLECs have  |
|                      | contracted for OSS in their interconnection   |
|                      | agreements and attended any required training |
|                      | (¶ 36)                                        |
+----------------------+-----------------------------------------------+
|                      | Begin an Offering Window period to offer      |
|                      | promotional discounted prices on monthly      |
|                      | recurring charges for unbundled local loops   |
|                      | used in the provision of local service to     |
|                      | residential end user customers, ordered after |
|                      | October 8, 1999 (¶ 46)                        |
+----------------------+-----------------------------------------------+
|                      | Begin an Offering Window period to offer      |
|                      | promotional resale discounts on               |
|                      | telecommunications services that              |
|                      | SBC/Ameritech provides at retail to           |
|                      | subscribers who are not telecommunications    |
|                      | carriers, where such services are resold to   |
|                      | residential end user customers and ordered    |
|                      | after October 8, 1999 (¶¶ 48-49)              |
+----------------------+-----------------------------------------------+
|                      | Begin an Offering Window period to offer      |
|                      | promotional, end-to-end combinations of UNEs  |
|                      | to provide CLECs with residential POTS        |
|                      | service and residential Basic Rate Interface  |
|                      | ISDN service, where such combinations are     |
|                      | ordered after October 8, 1999 (¶¶ 51-52)      |
+----------------------+-----------------------------------------------+
|                      | Offer to file tariff for enhanced lifeline    |
|                      | plan with state commission and copy to FCC    |
|                      | (except in Ohio), with conditions comparable  |
|                      | to the Ohio Universal Service Assistance      |
|                      | plan, to be filed within 60 days of           |
|                      | acceptance of the offer (¶ 61)                |
+----------------------+-----------------------------------------------+
|                      | Offer, at the state commission's option, to   |
|                      | extend Ameritech's Universal Service          |
|                      | Assistance Lifeline plan until January 6,     |
|                      | 2003, in Ohio (¶ 61)                          |
+----------------------+-----------------------------------------------+
| **Tuesday, November  | File a notice with the Secretary of the       |
| 16, 1999**           | Commission regarding satisfaction of the      |
|                      | requirement to implement and provide 2 months |
| (10 business days    | of performance data for Performance           |
| after November 1)    | Measurements shown on Attachments A-2a and    |
|                      | A-5a in SBC States except California, Nevada, |
|                      | and Connecticut (¶ 24)                        |
+----------------------+-----------------------------------------------+
| **Monday, November   | Independent auditor to submit preliminary     |
| 22, 1999**           | audit requirements to FCC audit staff (¶ 66)  |
|                      |                                               |
| (45 days after the   |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
|                      | Independent auditor to submit preliminary     |
|                      | audit requirements to FCC audit staff         |
|                      | regarding compliance with the Advanced        |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **Wednesday,         | Performance Measurements: Implement and       |
| December 1, 1999**   | provide 2 months of performance data for      |
|                      | performance measurements shown on Attachments |
| (First day of the    | A-2b and A-5b in California and Nevada, using |
| first month that     | the California business rules described in    |
| begins more than 30  | Attachment A-2b (¶ 24)                        |
| days after the       |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
| **Tuesday, December  | Target date for completion of Phase 1 of the  |
| 7, 1999**            | development and deployment of enhancements to |
|                      | existing Datagate and EDI interfaces (¶ 15)   |
| (60 days after the   |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
|                      | Notify all qualifying CLECs certificated and  |
|                      | who have interconnection agreements with      |
|                      | SBC/Ameritech operating in SBC/Ameritech      |
|                      | States of the availability of OSS expert      |
|                      | teams (¶ 36)                                  |
+----------------------+-----------------------------------------------+
|                      | Independent auditor to submit preliminary     |
|                      | audit requirements, including the proposed    |
|                      | scope of the audit and the extent of          |
|                      | compliance and substantive testing, to the    |
|                      | Commission's Audit Staff (¶ 40) (collocation  |
|                      | audit)                                        |
+----------------------+-----------------------------------------------+
|                      | Offer generic interconnection and resale      |
|                      | terms and conditions covering the             |
|                      | SBC/Ameritech Service Area in all             |
|                      | SBC/Ameritech States (¶ 44)                   |
+----------------------+-----------------------------------------------+
|                      | Submit plan for compliance with established   |
|                      | conditions (¶ 65)                             |
+----------------------+-----------------------------------------------+
|                      | File a letter with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to submit a plan for compliance   |
|                      | with established conditions (¶ 65)            |
+----------------------+-----------------------------------------------+
| **Friday, December   | File a notice with the Secretary of the       |
| 10, 1999**           | Commission regarding satisfaction of the      |
|                      | target for completion of Phase 1 of the       |
| (60 days + 3         | development and deployment of enhancements to |
| business days after  | existing Datagate and EDI interfaces (¶ 15)   |
| the Merger Closing   |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
| **Wednesday,         | File a notice with the Secretary of the       |
| December 15, 1999**  | Commission regarding satisfaction of the      |
|                      | requirement to implement and provide 2 months |
| (10 business days    | of performance data for performance           |
| after the first day  | measurements shown on Attachments A-2b and    |
| of the first month   | A-5b in California and Nevada, using the      |
| that begins more     | California business rules described in        |
| than 30 days after   | Attachment A-2b (¶ 24)                        |
| the Merger Closing   |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
| **Thursday, January  | Begin Phase 2 of the development and          |
| 6, 2000**            | deployment of enhancements to existing        |
|                      | Datagate and EDI interfaces, if one or more   |
| (90 days after the   | CLEC(s) has requested enhancements that are   |
| Merger Closing Date) | different from what is contained in the Plan  |
|                      | of Record. If no CLEC has requested           |
|                      | enhancements, Phase 2 will be considered      |
|                      | completed (¶ 15)                              |
+----------------------+-----------------------------------------------+
|                      | Provide non-discriminatory access to loop     |
|                      | make-up information that is available in      |
|                      | SBC/Ameritech's records, in response to       |
|                      | address-specific written requests (¶ 20)      |
+----------------------+-----------------------------------------------+
|                      | Reasonably classify all SBC/Ameritech wire    |
|                      | centers as either urban or rural wire         |
|                      | centers, in consultation with state           |
|                      | commissions should the state commission       |
|                      | choose to engage in such consultation (¶ 22)  |
+----------------------+-----------------------------------------------+
|                      | Implement and provide 2 months of performance |
|                      | data for Performance Measurements 2, 4-5,     |
|                      | 10-13, 15, and 17-19, as shown on Attachments |
|                      | A-2a and A-5a, in Ameritech States (¶ 24)     |
+----------------------+-----------------------------------------------+
|                      | Identify and discuss in one or more CLEC      |
|                      | forums training and procedures beneficial to  |
|                      | qualifying CLECs operating in the             |
|                      | SBC/Ameritech States (¶ 36)                   |
+----------------------+-----------------------------------------------+
|                      | File on a quarterly basis, state-by-state     |
|                      | service quality reports in accordance with    |
|                      | the retail service quality reporting          |
|                      | recommendations of the NARUC Technology       |
|                      | Policy Subgroup, in SBC/Ameritech States      |
|                      | except California and Nevada (¶ 62)           |
+----------------------+-----------------------------------------------+
| **Thursday, January  | Continue to report ARMIS data required by the |
| 6, 2000\             | Commission separately for each operating      |
| **continued          | company, and make service quality data based  |
|                      | on NARUC report available on an SBC/Ameritech |
|                      | website or to state commissions in            |
|                      | SBC/Ameritech States (¶ 63)                   |
+----------------------+-----------------------------------------------+
|                      | Determine, making good-faith efforts with the |
|                      | Chief of the Common Carrier Bureau and the    |
|                      | independent auditor, the procedures to be     |
|                      | used in the agreed-upon procedures engagement |
|                      | regarding compliance with the separate        |
|                      | Advanced Services affiliate requirements      |
|                      | (¶ 67)                                        |
+----------------------+-----------------------------------------------+
| **Tuesday, January   | File a notice with the Secretary of the       |
| 11, 2000**           | Commission regarding completion of Phase 2 of |
|                      | the development and deployment of Datagate or |
| (90 days + 3         | EDI interfaces, if no CLEC has requested      |
| business days after  | enhancements that are different from what is  |
| the Merger Closing   | contained in the Plan of Record (¶ 15)        |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
| **Friday, January    | File a notice with the Secretary of the       |
| 21, 2000**           | Commission regarding satisfaction of the      |
|                      | requirement to implement and provide 2 months |
| (90 days + 10        | of performance data for Performance           |
| business days after  | Measurements 2, 4-5, 10-13, 15, and 17-19, as |
| the Merger Closing   | shown on Attachments A-2a and A-5a, in        |
| Date)                | Ameritech States (¶ 24)                       |
+----------------------+-----------------------------------------------+
| **Monday, February   | Notify all qualifying CLECs certificated and  |
| 7, 2000**            | operating in SBC/Ameritech States of training |
|                      | and procedures (¶ 36)                         |
| (120 days after the  |                                               |
| Merger Closing Date  |                                               |
| falls on Saturday,   |                                               |
| February 5)          |                                               |
+----------------------+-----------------------------------------------+
| **Monday, March 6,   | Implement and provide 2 months of performance |
| 2000**               | data for Performance Measurements 1, 3, 6-9,  |
|                      | 14, 16, and 20, as shown in Attachments A-2a  |
| (150 days after the  | and A-5a, in Ameritech States (¶ 24)          |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
|                      | Target date for completion of Phase 1 of the  |
|                      | development and deployment of uniform         |
|                      | application-to-application interfaces and     |
|                      | graphical user interfaces (¶ 28)              |
+----------------------+-----------------------------------------------+
| **Thursday, March 9, | File a notice with the Secretary of the       |
| 2000**               | Commission regarding satisfaction of the      |
|                      | target for completion of Phase 1 of the       |
| (150 days + 3        | development and deployment of uniform         |
| business days after  | application-to-application interfaces and     |
| the Merger Closing   | graphical user interfaces (¶ 28)              |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
| **Wednesday, March   | File annual compliance report for 1999 (¶ 65) |
| 15, 2000**           |                                               |
+----------------------+-----------------------------------------------+
| **Monday, March 20,  | File a notice with the Secretary of the       |
| 2000**               | Commission regarding satisfaction of the      |
|                      | requirement to implement and provide 2 months |
| (150 days + 10       | of performance data for Performance           |
| business days after  | Measurements 1, 3, 6-9, 14, 16, and 20, as    |
| the Merger Closing   | shown in Attachments A-2a and A-5a, in        |
| Date)                | Ameritech States (¶ 24)                       |
+----------------------+-----------------------------------------------+
| **Wednesday, April   | Date after which incumbent LEC employees may  |
| 5, 2000**            | only access the incumbent LEC's loop          |
|                      | information through the same interfaces, OSS, |
| (180 days after the  | processes, and procedures as are made         |
| Merger Closing Date) | available to unaffiliated telecommunications  |
|                      | carriers, as described in ¶¶ 15, 19, 20, when |
|                      | performing joint marketing activities with a  |
|                      | separate Advanced Services affiliate in all   |
|                      | states except Connecticut (¶¶ 3, 4)           |
+----------------------+-----------------------------------------------+
|                      | Date after which a separate Advanced Services |
|                      | affiliate may not obtain network planning,    |
|                      | engineering, design, and assignment services  |
|                      | for Advanced Services Equipment, as defined   |
|                      | in ¶ 3d, on an exclusive basis from an        |
|                      | incumbent LEC (¶ 3)                           |
+----------------------+-----------------------------------------------+
| **Wednesday, April   | Provide Advanced Services through separate    |
| 5, 2000** continued  | affiliates in SBC States for the embedded     |
|                      | base of Advanced Services customers that are  |
|                      | providers of Internet services (compliance    |
|                      | date can also be 30 days after state approval |
|                      | of all necessary agreements, or 30 days after |
|                      | approval of any necessary tariffs, whichever  |
|                      | is later). If such services are determined to |
|                      | be jurisdictionally intrastate and state      |
|                      | certification is required, the obligation     |
|                      | shall apply 30 days after state approval of   |
|                      | any required certification (¶ 6)              |
+----------------------+-----------------------------------------------+
|                      | Provide Advanced Services through separate    |
|                      | affiliates in SBC States for the embedded     |
|                      | base of Advanced Services customers that are  |
|                      | not providers of Internet services            |
|                      | (compliance date can also be 30 days after    |
|                      | state approval of any necessary               |
|                      | certification, tariffs, or any other required |
|                      | state authorization; or 30 days after state   |
|                      | approval of all necessary agreements,         |
|                      | whichever is later). The transition period    |
|                      | may be prolonged in Connecticut as a          |
|                      | consequence of state-law restrictions (¶ 6)   |
+----------------------+-----------------------------------------------+
|                      | Order facilities and/or services needed to    |
|                      | provide Advanced Services in SBC/Ameritech    |
|                      | States through separate affiliates utilizing  |
|                      | the same interfaces as unaffiliated providers |
|                      | of Advanced Services (¶ 6)                    |
+----------------------+-----------------------------------------------+
|                      | Provide access to the same pre-order          |
|                      | interface(s) utilized by SBC/Ameritech's      |
|                      | retail operations to obtain theoretical local |
|                      | loop length information, or in the            |
|                      | alternative, utilize the same Datagate and/or |
|                      | Verigate pre-order interfaces that are        |
|                      | available to unaffiliated telecommunications  |
|                      | carriers, in SBC States except Connecticut    |
|                      | (¶ 15)                                        |
+----------------------+-----------------------------------------------+
|                      | File cost studies and proposed rates for      |
|                      | conditioning xDSL loops in each SBC/Ameritech |
|                      | State that has not already started or         |
|                      | completed cost proceedings for these services |
|                      | (¶ 21)                                        |
+----------------------+-----------------------------------------------+
|                      | File on a quarterly basis with the            |
|                      | Commission, a status report of xDSL roll-out  |
|                      | (¶ 22)                                        |
+----------------------+-----------------------------------------------+
|                      | Begin trial, if requested, to identify        |
|                      | procedures and associated costs required to   |
|                      | provide CLECs with access to cabling within   |
|                      | MDUs and MTUs, for a period not greater than  |
|                      | 12 months, if requested by a CLEC (¶ 57)      |
+----------------------+-----------------------------------------------+
|                      | File on a quarterly basis, state-by-state     |
|                      | Service Quality reports in accordance with    |
|                      | the retail service quality reporting          |
|                      | recommendations of the NARUC Technology       |
|                      | Policy Subgroup, in California and Nevada     |
|                      | (¶ 62)                                        |
+----------------------+-----------------------------------------------+
| **Wednesday, July 5, | Transfer any non-xDSL Advanced Services       |
| 2000**               | provided by Ameritech on a retail or          |
|                      | wholesale basis in the Ameritech States prior |
| (270 days after the  | to October 8, 1999 to a separate affiliate,   |
| Merger Closing Date  | in Ameritech States (compliance date can also |
| falls on Tuesday,    | be 30 days after state approval of all        |
| July 4)              | necessary agreements with the affiliated      |
|                      | incumbent LEC, or 30 days after approval of   |
|                      | any tariffs necessary for the separate        |
|                      | affiliate to provide such services, whichever |
|                      | is later) (¶ 6)                               |
+----------------------+-----------------------------------------------+
| **Tuesday, August 1, | Obligation to begin making voluntary          |
| 2000**               | performance payments to the U.S. Treasury, in |
|                      | SBC and Ameritech States except Connecticut   |
| (First month that    | (¶ 24)                                        |
| starts at least 270  |                                               |
| days after the       |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
| **Tuesday, August 8, | Independent auditor to submit final           |
| 2000**               | collocation audit report to the Commission's  |
|                      | Audit Staff (¶ 40)                            |
| (10 months after the |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
| **Friday, September  | File final audit report for 1999 (¶ 66)       |
| 1, 2000**            | (overall compliance audit)                    |
+----------------------+-----------------------------------------------+
|                      | File final audit report for 1999 regarding    |
|                      | compliance with the separate Advanced         |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **Tuesday, October   | Conclude transition period for incumbent LECs |
| 10, 2000**           | to receive and process Advanced               |
|                      | Services-related trouble reports and perform  |
| (12 months after the | related trouble isolation, as described in    |
| Merger Closing Date  | ¶ 4j, on behalf of a separate Advanced        |
| falls on Sunday,     | Services affiliate on an exclusive basis      |
| October 8; Monday,   | (¶¶ 3, 4)                                     |
| October 9 is a       |                                               |
| holiday)             |                                               |
+----------------------+-----------------------------------------------+
|                      | Provide access to non-discriminatory,         |
|                      | electronic pre-order Internet access to       |
|                      | theoretical loop length based upon a zip code |
|                      | of end users in a wire center, at no          |
|                      | additional charge (¶ 20)                      |
+----------------------+-----------------------------------------------+
|                      | Implement and provide 2 months of performance |
|                      | data for all Performance Measurements in      |
|                      | Connecticut (¶ 24)                            |
+----------------------+-----------------------------------------------+
|                      | Provide availability of shared transport in   |
|                      | Ameritech States under terms and conditions,  |
|                      | other than rate structure and price, that are |
|                      | substantially similar to the most favorable   |
|                      | terms SBC/Ameritech offers to CLECs in Texas  |
|                      | as of August 27, 1999 (¶ 56)                  |
+----------------------+-----------------------------------------------+
|                      | Install local switch for new markets or       |
|                      | otherwise obtain switching capability in      |
|                      | Boston, Miami, and Seattle (¶ 59)             |
+----------------------+-----------------------------------------------+
|                      | Provide facilities-based local exchange       |
|                      | service to 3 unaffiliated business and/or     |
|                      | non-employee residential customers in Boston, |
|                      | Miami, and Seattle (¶ 59)                     |
+----------------------+-----------------------------------------------+
| **Friday, October    | File a notice with the Secretary of the       |
| 13, 2000**           | Commission regarding satisfaction of the      |
|                      | requirement to install a local switch for new |
| (12 months + 3       | markets or otherwise obtain switching         |
| business days after  | capability in Boston, Miami, and Seattle      |
| the Merger Closing   | (¶ 59)                                        |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to provide facilities-based local |
|                      | exchange service to 3 unaffiliated business   |
|                      | and/or non-employee residential customers in  |
|                      | Boston, Miami, and Seattle (¶ 59)             |
+----------------------+-----------------------------------------------+
| **Tuesday, October   | File a notice with the Secretary of the       |
| 24, 2000**           | Commission regarding satisfaction of the      |
|                      | requirement to implement and provide 2 months |
| (12 months + 10      | of performance data for all Performance       |
| business days after  | Measurements in Connecticut (¶ 24)            |
| the Merger Closing   |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
| **Tuesday, October   | Meet with audit staff regarding changes to    |
| 31, 2000**           | the audit program (¶ 66) (overall compliance  |
|                      | audit)                                        |
| (60 days after       |                                               |
| submission of the    |                                               |
| audit)               |                                               |
+----------------------+-----------------------------------------------+
|                      | Meet with audit staff regarding changes to    |
|                      | the audit program for compliance with the     |
|                      | separate Advanced Services affiliate          |
|                      | requirements (¶ 67)                           |
+----------------------+-----------------------------------------------+
| **Friday, December   | Develop and deploy enhancements to the        |
| 8, 2000**            | existing Datagate or EDI interfaces for       |
|                      | pre-ordering xDSL and other Advanced Services |
| (14 months after the | components, and enhancements to the existing  |
| Merger Closing Date) | EDI interface for ordering xDSL and other     |
|                      | Advanced Services components, in              |
|                      | SBC/Ameritech States except Connecticut       |
|                      | (assuming the duration of Phase 2, the        |
|                      | collaborative process with CLECs, is no       |
|                      | longer than 30 days) (¶ 15)                   |
+----------------------+-----------------------------------------------+
| **Thursday, February | Obligation to begin making voluntary          |
| 1, 2001**            | performance payments to the U.S. Treasury, in |
|                      | Connecticut (¶ 24)                            |
| (First month that    |                                               |
| starts at least 15   |                                               |
| months after the     |                                               |
| Merger Closing Date) |                                               |
+----------------------+-----------------------------------------------+
| **Thursday, March    | File annual compliance report for 2000 (¶ 65) |
| 15, 2001**           |                                               |
+----------------------+-----------------------------------------------+
| **Monday, April 9,   | Install local switch for new markets or       |
| 2001**               | otherwise obtain switching capability in 12   |
|                      | additional markets (¶ 59)                     |
| (18 months after the |                                               |
| Merger Closing Date  |                                               |
| falls on Sunday,     |                                               |
| April 8)             |                                               |
+----------------------+-----------------------------------------------+
|                      | Provide facilities-based local exchange       |
|                      | service to 3 unaffiliated business and/or     |
|                      | non-employee residential customers in 12      |
|                      | additional markets (¶ 59)                     |
+----------------------+-----------------------------------------------+
| **Thursday, April    | File a notice with the Secretary of the       |
| 12, 2001**           | Commission regarding satisfaction of the      |
|                      | requirement to install local switch for new   |
| (18 months + 3       | markets or otherwise obtain switching         |
| business days after  | capability in 12 additional markets (¶ 59)    |
| the Merger Closing   |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to provide facilities-based local |
|                      | exchange service to 3 unaffiliated business   |
|                      | and/or non-employee residential customers in  |
|                      | 12 additional markets (¶ 59)                  |
+----------------------+-----------------------------------------------+
| **Wednesday, August  | Date after which incumbent LEC employees may  |
| 8, 2001**            | only access the incumbent LEC's loop length   |
|                      | information through the same pre-order OSS    |
| (22 months after the | access as is made available to unaffiliated   |
| Merger Closing Date) | telecommunications carriers, as described in  |
|                      | ¶ 20, when performing joint marketing         |
|                      | activities with a separate Advanced Services  |
|                      | affiliate in Connecticut (¶ 3)                |
+----------------------+-----------------------------------------------+
|                      | Provide non-discriminatory, electronic        |
|                      | pre-order OSS access to theoretical loop      |
|                      | length on an individual address basis, in     |
|                      | Connecticut and Ameritech States (¶ 20)       |
+----------------------+-----------------------------------------------+
| **Tuesday, September | File final audit report for 2000 (¶ 66)       |
| 4, 2001**            | (overall compliance audit)                    |
|                      |                                               |
| (September 1 is a    |                                               |
| Saturday; Monday is  |                                               |
| a holiday)           |                                               |
+----------------------+-----------------------------------------------+
|                      | File final audit report for 2000 regarding    |
|                      | compliance with the separate Advanced         |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **Tuesday, October   | Develop and deploy commercially ready,        |
| 9, 2001**            | uniform application-to-application interfaces |
|                      | in SBC/Ameritech States except Connecticut    |
| (24 months after the | (assuming the duration of Phase 2, the        |
| Merger Closing Date  | collaborative process with CLECs, is no       |
| falls on Monday,     | longer than 30 days) (¶ 26)                   |
| October 8, a         |                                               |
| holiday)             |                                               |
+----------------------+-----------------------------------------------+
|                      | Develop and deploy uniform graphical user     |
|                      | interfaces in SBC/Ameritech States except     |
|                      | Connecticut (assuming the duration of Phase   |
|                      | 2, the collaborative process with CLECs, is   |
|                      | no longer than 30 days) (¶ 27)                |
+----------------------+-----------------------------------------------+
|                      | Have collocated facilities (physical, virtual |
|                      | or otherwise) in 10 wire centers in market    |
|                      | that can be used to offer facilities-based    |
|                      | local services to customers served by those   |
|                      | wire centers in Boston, Miami, and Seattle    |
|                      | (¶ 59)                                        |
+----------------------+-----------------------------------------------+
|                      | Offer facilities-based local exchange         |
|                      | services to all business and residential      |
|                      | customers served by wire centers in market    |
|                      | where collocated in Boston, Miami, and        |
|                      | Seattle (¶ 59)                                |
+----------------------+-----------------------------------------------+
|                      | Offer local exchange service to all business  |
|                      | and residential customers that are within (i) |
|                      | local service area of incumbent RBOC within   |
|                      | the PMSA or (ii) incumbent service area of a  |
|                      | Tier 1 ILEC serving at least 10% of access    |
|                      | lines in the PMSA in Boston, Miami, and       |
|                      | Seattle (¶ 59)                                |
+----------------------+-----------------------------------------------+
| **Friday, October    | File a notice with the Secretary of the       |
| 12, 2001**           | Commission regarding satisfaction of the      |
|                      | requirement to have collocated facilities in  |
| (24 months + 3       | 10 wire centers in Boston, Miami, and Seattle |
| business days after  | (¶ 59)                                        |
| the Merger Closing   |                                               |
| Date)                |                                               |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer facilities-based local   |
|                      | exchange services to all business and         |
|                      | residential customers served by wire centers  |
|                      | in market where collocated in Boston, Miami,  |
|                      | and Seattle (¶ 59)                            |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer local exchange service   |
|                      | to all business and residential customers     |
|                      | that are within (i) local service area of     |
|                      | incumbent RBOC within the PMSA or (ii)        |
|                      | incumbent service area of a Tier 1 ILEC       |
|                      | serving at least 10% of access lines in the   |
|                      | PMSA in Boston, Miami, and Seattle (¶ 59)     |
+----------------------+-----------------------------------------------+
| **Monday, November   | Meet with audit staff regarding changes to    |
| 5, 2001**            | audit program (¶ 66) (overall compliance      |
|                      | audit)                                        |
| (60 days after       |                                               |
| submission of the    |                                               |
| audit is Saturday,   |                                               |
| November 3)          |                                               |
+----------------------+-----------------------------------------------+
|                      | Meet with audit staff regarding changes to    |
|                      | the audit program for compliance with the     |
|                      | separate Advanced Services affiliate          |
|                      | requirements (¶ 67)                           |
+----------------------+-----------------------------------------------+
| **Friday, March 15,  | File annual compliance report for 2001 (¶ 65) |
| 2002**               |                                               |
+----------------------+-----------------------------------------------+
| **Monday, April 8,   | Date after which incumbent LEC employees may  |
| 2002**               | only access the incumbent LEC's loop          |
|                      | information through the same Datagate/EDI     |
| (30 months after the | interfaces as are made available to           |
| Merger Closing Date) | unaffiliated telecommunications carriers, as  |
|                      | described in ¶ 15, when performing joint      |
|                      | marketing activities with a separate Advanced |
|                      | Services affiliate in Connecticut (¶ 3)       |
+----------------------+-----------------------------------------------+
|                      | Develop and deploy enhancements to the        |
|                      | existing Datagate or EDI interfaces for       |
|                      | pre-ordering xDSL and other Advanced Services |
|                      | components, and enhancements to the existing  |
|                      | EDI interface for ordering xDSL and other     |
|                      | Advanced Services components in Connecticut   |
|                      | (¶ 15)                                        |
+----------------------+-----------------------------------------------+
|                      | Develop and deploy commercially ready,        |
|                      | uniform application-to-application interfaces |
|                      | in Connecticut (assuming the duration of      |
|                      | Phase 2, the collaborative process with       |
|                      | CLECs, is no longer than 30 days) (¶ 26)      |
+----------------------+-----------------------------------------------+
|                      | Develop and deploy uniform graphical user     |
|                      | interfaces in Connecticut (assuming the       |
|                      | duration of Phase 2, the collaborative        |
|                      | process with CLECs, is no longer than 30      |
|                      | days) (¶ 27)                                  |
+----------------------+-----------------------------------------------+
|                      | Develop with CLECs, and deploy either (i) a   |
|                      | software solution that shall ensure that      |
|                      | CLEC-submitted local service requests are     |
|                      | consistent with SBC/Ameritech's business      |
|                      | rules, or (ii) uniform business rules for     |
|                      | completing CLEC local service requests,       |
|                      | excluding those differences caused by state   |
|                      | regulatory requirements and product           |
|                      | definitions (assuming the duration of Phase   |
|                      | 2, the collaborative process with CLECs, is   |
|                      | no longer than 30 days) (¶ 31)                |
+----------------------+-----------------------------------------------+
|                      | Install local switch for new markets or       |
|                      | otherwise obtain switching capability in last |
|                      | 15 markets (compliance date may instead be 60 |
|                      | days after authorization to provide interLATA |
|                      | service to 60% of access lines, whichever is  |
|                      | later) (¶ 59)                                 |
+----------------------+-----------------------------------------------+
|                      | Provide facilities-based local exchange       |
|                      | service to 3 unaffiliated business and/or     |
|                      | non-employee residential customers in last 15 |
|                      | markets (compliance date may instead be 60    |
|                      | days after authorization to provide interLATA |
|                      | service to 60% of access lines, whichever is  |
|                      | later) (¶ 59)                                 |
+----------------------+-----------------------------------------------+
|                      | Have collocated facilities (physical, virtual |
|                      | or otherwise) in 10 wire centers in market    |
|                      | that can be used to offer facilities-based    |
|                      | local services to customers served by those   |
|                      | wire centers, in 12 additional markets (¶ 59) |
+----------------------+-----------------------------------------------+
|                      | Offer facilities-based local exchange         |
|                      | services to all business and residential      |
|                      | customers served by wire centers in market    |
|                      | where collocated, in 12 additional markets    |
|                      | (¶ 59)                                        |
+----------------------+-----------------------------------------------+
|                      | Offer local exchange service to all business  |
|                      | and residential customers that are within (i) |
|                      | local service area of incumbent RBOC within   |
|                      | the PMSA or (ii) incumbent service area of a  |
|                      | Tier 1 ILEC serving at least 10% of access    |
|                      | lines in the PMSA, in 12 additional markets   |
|                      | (¶ 59)                                        |
+----------------------+-----------------------------------------------+
| **Thursday, April    | File a notice with the Secretary of the       |
| 11, 2002**           | Commission regarding satisfaction of the      |
|                      | requirement to install a local switch for new |
| (30 months + 3       | markets or otherwise obtain switching         |
| business days after  | capability in last 15 markets (filing date    |
| the Merger Closing   | may instead be 60 days + 3 business days      |
| Date)                | after authorization to provide interLATA      |
|                      | service to 60% of access lines, whichever is  |
|                      | later) (¶ 59)                                 |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to provide facilities-based local |
|                      | exchange service to 3 unaffiliated business   |
|                      | and/or non-employee residential customers in  |
|                      | last 15 markets (filing date may instead be   |
|                      | 60 days + 3 business days after authorization |
|                      | to provide interLATA service to 60% of access |
|                      | lines, whichever is later) (¶ 59)             |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to have collocated facilities in  |
|                      | 10 wire centers in each of 12 additional      |
|                      | markets (¶ 59)                                |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer facilities-based local   |
|                      | exchange services to all business and         |
|                      | residential customers served by wire centers  |
|                      | in market where collocated, in 12 additional  |
|                      | markets (¶ 59)                                |
+----------------------+-----------------------------------------------+
|                      |                                               |
+----------------------+-----------------------------------------------+
|                      |                                               |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer local exchange service   |
|                      | to all business and residential customers     |
|                      | that are within (i) local service area of     |
|                      | incumbent RBOC within the PMSA or (ii)        |
|                      | incumbent service area of a Tier 1 ILEC       |
|                      | serving at least 10% of access lines in the   |
|                      | PMSA, in 12 additional markets (¶ 59)         |
+----------------------+-----------------------------------------------+
| **Tuesday, September | File final audit report for 2001 (¶ 66)       |
| 3, 2002**            | (overall compliance audit)                    |
|                      |                                               |
| (September 1 is      |                                               |
| Sunday; Monday is a  |                                               |
| holiday)             |                                               |
+----------------------+-----------------------------------------------+
|                      | File final audit report for 2001 regarding    |
|                      | compliance with the separate Advanced         |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **Monday, November   | Meet with audit staff regarding changes to    |
| 4, 2002**            | audit program (¶ 66) (overall compliance      |
|                      | audit)                                        |
| (60 days after       |                                               |
| submission of the    |                                               |
| audit is Saturday,   |                                               |
| November 2)          |                                               |
+----------------------+-----------------------------------------------+
|                      | Meet with audit staff regarding changes to    |
|                      | the audit program for compliance with the     |
|                      | separate Advanced Services affiliate          |
|                      | requirements (¶ 67)                           |
+----------------------+-----------------------------------------------+
| **Monday, March 17,  | File annual compliance report for 2002 (¶ 65) |
| 2003**               |                                               |
+----------------------+-----------------------------------------------+
| **Tuesday, April 8,  | Have collocated facilities (physical, virtual |
| 2003**               | or otherwise) in 10 wire centers in market    |
|                      | that can be used to offer facilities-based    |
| (42 months after the | local services to customers served by those   |
| Merger Closing Date) | wire centers, in last 15 markets (compliance  |
|                      | date may instead be 14 months after           |
|                      | authorization to provide interLATA service to |
|                      | 60% of access lines) (¶ 59)                   |
+----------------------+-----------------------------------------------+
|                      | Offer facilities-based local exchange         |
|                      | services to all business and residential      |
|                      | customers served by wire centers in market    |
|                      | where collocated, in last 15 markets          |
|                      | (compliance date may instead be 14 months     |
|                      | after authorization to provide interLATA      |
|                      | service to 60% of access lines) (¶ 59)        |
+----------------------+-----------------------------------------------+
|                      | Offer local exchange service to all business  |
|                      | and residential customers that are within (i) |
|                      | local service area of incumbent RBOC within   |
|                      | the PMSA or (ii) incumbent service area of a  |
|                      | Tier 1 ILEC serving at least 10% of access    |
|                      | lines in the PMSA, in last 15 markets         |
|                      | (compliance date may instead be 14 months     |
|                      | after authorization to provide interLATA      |
|                      | service to 60% of access lines) (¶ 59)        |
+----------------------+-----------------------------------------------+
| **Friday, April 11,  | File a notice with the Secretary of the       |
| 2003**               | Commission regarding satisfaction of the      |
|                      | requirement to have collocated facilities in  |
| (42 months + 3       | 10 wire centers in each of the last 15        |
| business days after  | markets (filing date may instead be 14        |
| the Merger Closing   | months + 3 business days after authorization  |
| Date)                | to provide interLATA service to 60% of access |
|                      | lines) (¶ 59)                                 |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer facilities-based local   |
|                      | exchange services to all business and         |
|                      | residential customers served by wire centers  |
|                      | in market where collocated, in last 15        |
|                      | markets (filing date may instead be 14        |
|                      | months + 3 business days after authorization  |
|                      | to provide interLATA service to 60% of access |
|                      | lines) (¶ 59)                                 |
+----------------------+-----------------------------------------------+
|                      | File a notice with the Secretary of the       |
|                      | Commission regarding satisfaction of the      |
|                      | requirement to offer local exchange service   |
|                      | to all business and residential customers     |
|                      | that are within (i) local service area of     |
|                      | incumbent RBOC within the PMSA or (ii)        |
|                      | incumbent service area of a Tier 1 ILEC       |
|                      | serving at least 10% of access lines in the   |
|                      | PMSA, in last 15 markets (filing date may     |
|                      | instead be 14 months + 3 business days after  |
|                      | authorization to provide interLATA service to |
|                      | 60% of access lines) (¶ 59)                   |
+----------------------+-----------------------------------------------+
| **Tuesday, September | File final audit report for 2002 (¶ 66)       |
| 2, 2003**            | (overall compliance audit)                    |
|                      |                                               |
| (September 1 is a    |                                               |
| holiday)             |                                               |
+----------------------+-----------------------------------------------+
|                      | File final audit report for 2002 regarding    |
|                      | compliance with the separate Advanced         |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **Monday, November   | Meet with audit staff regarding changes to    |
| 3, 2003**            | audit program (¶ 66) (overall compliance      |
|                      | audit)                                        |
| (60 days after       |                                               |
| submission of the    |                                               |
| audit is Saturday,   |                                               |
| November 1)          |                                               |
+----------------------+-----------------------------------------------+
|                      | Meet with audit staff regarding changes to    |
|                      | the audit program for compliance with the     |
|                      | separate Advanced Services affiliate          |
|                      | requirements (¶ 67)                           |
+----------------------+-----------------------------------------------+
| **Monday, March 15,  | File annual compliance report for 2003 (¶ 65) |
| 2004**               |                                               |
+----------------------+-----------------------------------------------+
| **Wednesday,         | File final audit report for 2003 (¶ 66)       |
| September 1, 2004**  | (overall compliance audit)                    |
+----------------------+-----------------------------------------------+
|                      | File final audit report for 2003 regarding    |
|                      | compliance with the separate Advanced         |
|                      | Services affiliate requirements (¶ 67)        |
+----------------------+-----------------------------------------------+
| **March 15, 200\_**  | File annual compliance report for prior year, |
|                      | if SBC had obligations under the Merger       |
|                      | Conditions in that year (¶ 65)                |
+----------------------+-----------------------------------------------+
| **September 1,       | File final audit report for the prior year,   |
| 200\_**              | if SBC had obligations under the Merger       |
|                      | Conditions in that year. \[If necessary for a |
|                      | subsequent audit, meet with audit staff       |
|                      | regarding changes to audit program 60 days    |
|                      | after submission of the audit.\] (¶ 66)       |
|                      | (overall compliance audit)                    |
+----------------------+-----------------------------------------------+
|                      | File final audit report for the prior year,   |
|                      | if SBC had obligations under the Merger       |
|                      | Conditions in that year regarding compliance  |
|                      | with the separate Advanced Services affiliate |
|                      | requirements. \[If necessary for a subsequent |
|                      | audit, meet with audit staff regarding        |
|                      | changes to audit program 60 days after        |
|                      | submission of the audit.\] (¶ 67)             |
+----------------------+-----------------------------------------------+

  -----------------------------------------------------------------------
  **Timing Dependent on  
  External Factors**     
  ---------------------- ------------------------------------------------
  **Date**               **Required Action**

  30 days after state    Provide Advanced Services through a separate
  approval of all        affiliate in SBC States for new activation of
  necessary agreements   customers that are providers of Internet
  with the affiliated    services. Compliance can also be met 30 days
  incumbent LEC          after approval of any necessary tariffs,
                         whichever is later. If such services are
                         determined to be jurisdictionally intrastate,
                         and state certification is required to provide
                         new activations of Advanced Services to
                         customers that are providers of Internet
                         services, the obligation shall apply 30 days
                         after state approval of any certification that
                         the state deems required (¶ 6)

                         Provide Advanced Services through a separate
                         affiliate in SBC States for new activations of
                         Advanced Services to customers that are not
                         providers of Internet services. Compliance can
                         also be met 30 days after: state approval of any
                         certification that the state deems required for
                         the separate Advanced Services affiliate, or
                         approval of any tariffs necessary for the
                         separate Advanced Services affiliate, whichever
                         is later (¶ 6)

  3 business days after  File any tariffs necessary for the separate
  state approval of any  Advanced Services affiliate to provide Advanced
  certification that the Services to customers that are not providers of
  state deems required   Internet services, in SBC States (¶ 6)
  for the separate       
  Advanced Services      
  affiliate to provide   
  Advanced Services in   
  that state             

  3 business days after  File tariff changes with the Commission and/or
  obtaining all          state commission to terminate the offering of
  necessary              new activations by the incumbent LEC, and cease
  certifications,        pro-active marketing or sales of new activations
  authorizations, and/or from the tariffs of the incumbent LEC (¶ 6)
  approvals to provide   
  new activations of an  
  Advanced Service       
  through a separate     
  affiliate in a state   

  180 days after         Provide non-discriminatory, electronic pre-order
  electronic, pre-order  OSS access to theoretical loop length on an
  OSS access to          individual address basis in Nevada (¶ 20)
  theoretical loop       
  length is made         
  available in the       
  SBC/Ameritech Service  
  area within California 

  After Wednesday, April Deploy xDSL in wire centers from the Low Income
  5, 2000, by the time   Urban Pool for at least 10 percent of the urban
  SBC/Ameritech has      wire centers in a state in which SBC/Ameritech
  deployed xDSL in at    deploys xDSL (¶ 22)
  least 20 urban wire    
  centers in a           
  particular state       

  After Wednesday, April Deploy xDSL in wire centers from the Low Income
  5, 2000, by the time   Rural Pool for at least 10 percent of the rural
  SBC/Ameritech has      wire centers a state in which SBC/Ameritech
  deployed xDSL in at    deploys xDSL (¶ 22)
  least 20 rural wire    
  centers in a           
  particular state       

  Within 12 months of a  Develop and deploy enhancements to the existing
  completed contract     EBI interface for OSS that support
                         maintenance/repair in SWBT, PacBell, and Nevada
                         Bell States (¶ 30)

  Within 12 months of a  Provide enhancements to the EBI interface in
  completed contract (or Connecticut and Ameritech States (¶ 30)
  in conjunction with    
  the introduction of    
  the EBI interface,     
  whichever is later)    

  36 months from a date  Promotional period for unbundled local loop
  a qualifying unbundled discounts (promotional period may instead last
  local loop is          through the period during which the loop remains
  installed and          in service at the same location and for the same
  operational            carrier, whichever is shorter) (¶ 46)

  36 months from a date  Promotional period for resale discounts
  a qualifying resold    (promotional period may instead last through the
  service is installed   period during which the resold service remains
  and operational        in service at the same location and for the same
                         carrier, whichever is shorter) (¶ 48)

  36 months from the     Promotional period for promotional UNE platform
  date a promotional UNE (promotional period may instead last during the
  platform is installed  period in which the UNE platform remains in
  and operational        service at the same location and for the same
                         carrier, whichever is shorter) (¶ 51)

  First day after the    No minimum monthly or minimum flat rate charge
  Merger Closing Date on on interLATA services provided to any in-region
  which interLATA        or out-of-region residential customer in the
  services provided      U.S. (except those imposed by government
  under Section 271 in   entities or voluntary, optional calling plans)
  an SBC/Ameritech       (¶ 60)
  State, or when local   
  telephone exchange     
  service provided to    
  residential customers  
  in any National Local  
  market                 
  -----------------------------------------------------------------------

##  

##   {#section-1 .unnumbered}

## 

[^1]: The deadlines specified in the *Merger Order*, and the
    Commission's rules for the computation of time, control the
    implementation of the Merger Conditions. *See* Applications of
    Ameritech Corp., Transferor, and SBC Communications, Inc.,
    Transferee, For Consent to Transfer Control of Corporations Holding
    Commission Licenses and Lines Pursuant to Sections 214 and 310(d) of
    the Communications Act and Parts 5, 22, 24, 25, 63, 90, 95, and 101
    of the Commission's Rules, CC Docket 98-141, *Memorandum Opinion and
    Order*, FCC 99-279, Appendix C (rel. Oct. 8, 1999) ("*SBC/Ameritech
    Merger Order*"); *see also* 47 C.F.R. § 1.4.