**KEY FACTS REGARDING NEW YORK**

## I. COMPETITION IN NEW YORK 

-   New York State has some of the most intensely competitive local
    exchange and local exchange access markets in the nation. This track
    record of successful competition places Bell Atlantic's section 271
    application in a different context than prior filings.

-   Competitors in New York serve at least 651,793 lines using their own
    facilities, 152,055 lines using the UNE platform, and 314,332 lines
    through resale for a total of at least 1,118,180 lines.

-   Competitors in New York serve at least 35,753 residential lines over
    their own facilities, provide service to 137,342 residential
    customers using the UNE platform and resell another 63,547
    residential lines.

II. **[THIRD PARTY TESTING OF BELL ATLANTIC OSS]{.underline}**

-   Incumbent LECs use a variety of systems, databases, and personnel
    (collectively referred to as OSS) to provide service to their
    customers at a certain level of quality, accuracy and timeliness.
    The Commission has found that nondiscriminatory access to OSS is a
    prerequisite to the development of meaningful local competition. For
    example, new entrants must have access to the functions performed by
    the incumbent's OSS in order to formulate and place orders for
    network elements or resale services, to install service to their
    customers, to maintain and repair network facilities, and to bill
    customers.

-   The New York Commission retained KPMG Peat Marwick (KPMG) to conduct
    an independent, third-party test of the readiness of Bell Atlantic's
    OSS, interfaces, documentation and processes. Over the course of
    fifteen months, KPMG evaluated 855 separate items relating to
    pre-ordering, ordering, provisioning, maintenance and repair,
    billing, and relationship management and infrastructure, by
    performing both transaction and operational tests.

-   In performing these tests, KPMG adopted a military-style test
    philosophy, or a mindset of "test until you pass." Thus, when
    situations arose where testing revealed that a Bell Atlantic
    process, document, or system did not meet expectations, Bell
    Atlantic would generally implement a fix and KPMG would retest the
    process, document, or system until satisfied.

-   To the greatest extent possible, the KPMG test was both independent
    and blind. For example, KPMG required that all documents provided to
    them were generally available to all competing carriers. The New
    York Commission monitored phone calls between KPMG and Hewlett
    Packard and Bell Atlantic, and competing carriers were invited to
    attend conference calls. Hewlett Packard acted as a competing
    carrier information technology group, establishing electronic
    bonding with Bell Atlantic, translating back and forth between
    business and EDI rule formats, and resolving problems with missing
    orders and responses.

-   The rigorous, comprehensive third party testing in New York
    identified numerous shortcomings in Bell Atlantic's OSS performance
    that were subsequently corrected and re-tested. The
    pseudo-competitive LEC, KPMG, released its final report on August 6,
    1999, concluding that Bell Atlantic's OSS was commercially available
    and sufficient to handle reasonable, anticipated commercial volumes.

III. **[NEW YORK DEVELOPMENT OF PERFORMANC MEASURES AND
     STANDARDS]{.underline}**

-   The New York Commission developed, and continues to refine,
    inter-carrier performance measures and service quality standards in
    its *Carrier-to-Carrier* proceeding. For example, the New York
    Commission has instituted collaborative proceedings to address xDSL
    issues and is developing xDSL specific performance measures and
    standards.

-   To ensure that the company's performance data or "metrics" are
    reported reliably in accordance with the New York Commission's
    definitions, New York staff and KPMG reviewed the adequacy of
    internal controls surrounding the data collection process. In
    addition, the New York Commission's staff verifies on a monthly
    basis that Bell Atlantic's reported results conform to the
    definitions developed in the *Carrier-to-Carrier* proceeding. The
    definitions and standards developed in that proceeding have done
    much to foster the development of consistent and meaningful data
    concerning Bell Atlantic's performance. This gives us greater
    confidence that our decision is based on performance data that
    accurately measures Bell Atlantic's actual performance.

IV. **[NEW YORK PERFORMANCE ASSURANCE PLAN]{.underline}**

-   New York has adopted a self-effectuating performance assurance plan
    that will provide significant financial incentives for Bell Atlantic
    to maintain an open market and prevent "backsliding" in the future
    provision of service by Bell Atlantic to competitive LECs.

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-   The New York Commission is committed to supervising the
    implementation of these plans.