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 Before  the  FEDERAL  COMMUNICATIONS  COMMISSION 
 Washington,  DC  20554 
 In  the  Matter  of  )  ) 
 Qwest  Communications  )  WC  Docket  No.  02-148  International  Inc.  ) 
 )  Consolidated  Application  for  Authority  ) 
 to  Provide  In-Region,  InterLATA  Services  )  in  Colorado,  Idaho,  Iowa,  Nebraska  ) 
 and  North  Dakota  ) 

 DECLARATION  OF  JUDITH  L.  BRUNSTING 
 Section  271(d)(3)(B)  Compliance  with  Section  272  by  the  272  Affiliate 
4
 1 
 29.  Section  272(b)(2)  requires  the  272  Affiliate  to  maintain  books, 
 records,  and  accounts  separate  from  the  books,  records,  and  accounts  of  the  BOC. 
 Several  facts  show  that  the  272  Affiliate  satisfies  this  provision: 
 a.  The  272  Affiliate  follows  Generally  Accepted  Accounting  Principles 
 (GAAP),  as  adopted  by  the  FCC  in  Docket  96-150.  GAAP  requires 
 accrual  accounting,  which  is  the  practice  followed  by  the  272  Affiliate. 
 The  272  Affiliates  books,  records,  and  accounts  are  maintained  in 
 accordance  with  GAAP  and  consolidated  into  Qwest  Communications 
 International  Inc.s  financials.  Qwest  Communications  International 
 Inc.  is  a  publicly  held  corporation  subject  to  federal  securities  statutes 
 and  reports  its  financial  activities  in  accordance  with  GAAP.  QCII  is 
 unable  to  certify  its  current  financials  because  the  beginning  balances 
 for  the  current  quarter  are  derived  from  prior  quarters  and  must 
 include  a  cumulative  effect  with  respect  to  data  for  past  matters 
 requiring  a  restatement  of  QCIIs  financial  reports.  This  inability  to 
 certify  current  financial  statements  does  not  indicate  any  issue  with 
 the  manner  in  which  QCC  and  QC  are  conducting  business  today  or 
 accounting  for  transactions  on  a  going-forward  basis.  None  of  the  past 
 matters  under  review  are  transactions  between  QCC  and  QC.  See  also 
 the  verified  letter  of  Oren  G.  Shaffer,  dated  August  26,  2002,  that 
 addresses  the  issue  of  restatement  of  financials  as  it  relates  to  GAAP 
 compliance  for  the  272  Affiliate. 
5

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 Before  the  FEDERAL  COMMUNICATIONS  COMMISSION 
 Washington,  DC  20554 
 In  the  Matter  of  )  ) 
 Qwest  Communications  )  WC  Docket  No.  02-189  International  Inc.  ) 
 )  Consolidated  Application  for  Authority  ) 
 to  Provide  In-Region,  InterLATA  Services  )  in  Montana,  Utah,  Washington,  ) 
 and  Wyoming  ) 

 DECLARATION  OF  JUDITH  L.  BRUNSTING 
 Section  271(d)(3)(B)  Compliance  with  Section  272  by  the  272  Affiliate 
7
 1 
 29.  Section  272(b)(2)  requires  the  272  Affiliate  to  maintain  books, 
 records,  and  accounts  separate  from  the  books,  records,  and  accounts  of  the  BOC. 
 Several  facts  show  that  the  272  Affiliate  satisfies  this  provision: 
 a.  The  272  Affiliate  follows  Generally  Accepted  Accounting  Principles 
 (GAAP),  as  adopted  by  the  FCC  in  Docket  96-150.  GAAP  requires 
 accrual  accounting,  which  is  the  practice  followed  by  the  272  Affiliate. 
 The  272  Affiliates  books,  records,  and  accounts  are  maintained  in 
 accordance  with  GAAP  and  consolidated  into  Qwest  Communications 
 International  Inc.s  financials.  Qwest  Communications  International 
 Inc.  is  a  publicly  held  corporation  subject  to  federal  securities  statutes 
 and  reports  its  financial  activities  in  accordance  with  GAAP.  QCII  is 
 unable  to  certify  its  current  financials  because  the  beginning  balances 
 for  the  current  quarter  are  derived  from  prior  quarters  and  must 
 include  a  cumulative  effect  with  respect  to  data  for  past  matters 
 requiring  a  restatement  of  QCIIs  financial  reports.  This  inability  to 
 certify  current  financial  statements  does  not  indicate  any  issue  with 
 the  manner  in  which  QCC  and  QC  are  conducting  business  today  or 
 accounting  for  transactions  on  a  going-forward  basis.  None  of  the  past 
 matters  under  review  are  transactions  between  QCC  and  QC.  See  also 
 the  verified  letter  of  Oren  G.  Shaffer,  dated  August  26,  2002,  that 
 addresses  the  issue  of  restatement  of  financials  as  it  relates  to  GAAP 
 compliance  for  the  272  Affiliate. 
8

9
 Schwartz  Section  272  Declaration 
 Before  the  FEDERAL  COMMUNICATIONS  COMMISSION 
 Washington,  DC  20554 
 In  the  Matter  of  )  ) 
 Qwest  Communications  )  WC  Docket  No.  02-148  International  Inc.  ) 
 )  Consolidated  Application  for  Authority  ) 
 to  Provide  In-Region,  InterLATA  Services  )  in  Colorado,  Idaho,  Iowa,  Nebraska  ) 
 and  North  Dakota  ) 

 DECLARATION  OF  MARIE  E.  SCHWARTZ 
 Section  271(d)(3)(B)  Compliance  with  Section  272  by  the  BOC 
10
 Schwartz  Section  272  Declaration 
 1 
 48.  The  BOC  follows  Generally  Accepted  Accounting  Principles 
 (GAAP),  including  accrual  accounting,  to  properly  record  expenses  in  the  period 
 incurred.  The  audit  opinion  of  Qwests  external  auditors,  Arthur  Andersen,  L.L.P. 
 (Arthur  Andersen)  confirms  that  the  BOC  follows  GAAP  in  all  material  respects. 
 See  Exhibit  MES-272-6,  the  Report  of  Independent  Public  Accountants  filed  with 
 the  Qwest  Corporation  Annual  Report  10-K  for  year  2001.  The  BOC  also  follows 
 regulatory  accounting  rules  as  required  by  the  FCC.  The  BOCs  books,  records,  and 
 accounts  are  maintained  in  accordance  with  USOA,  Part  32.27,  and  Part  64.901, 
 Allocation  of  Costs.  In  the  past,  the  FCCs  Part  64  and  CAM  audits  have  never 
 reported  a  finding  that  the  BOC  was  not  following  GAAP.  Annual  reports  are  filed 
 publicly  via  the  FCCs  Automated  Reporting  Management  Information  System 
 (ARMIS)  and  are  accompanied  by  the  report  of  independent  accountants,  Arthur 
 Andersen,  which  also  has  found  no  material  departures  from  GAAP.  1  The  Report  of 
 Independent  Public  Accountants  that  was  filed  with  the  FCC  ARMIS  43-03  report 
 for  2001  is  attached  as  Exhibit  MES-272-7.  QCII  is  unable  to  certify  its  current 
 financials  because  the  beginning  balances  for  the  current  quarter  are  derived  from 
 prior  quarters  and  must  include  a  cumulative  effect  with  respect  to  data  for  past 
 matters  requiring  a  restatement  of  QCIIs  financial  reports.  As  part  of  an  ongoing 

 1  /  In  Comprehensive  Review  of  the  Accounting  Requirements  and  ARMIS 
 Reporting  Requirements  for  Incumbent  Local  Exchange  Carriers:  Phase  I,  Report  and  Order,  CC  Docket  No.  99-253,  FCC  00-78,  15  FCC  Rcd  8690  (rel.  Mar.  8,  2000), 

 the  FCC  gave  carriers  the  option  of  choosing  an  attest  examination  or  financial  audit  every  two  years  covering  the  prior  two-year  period.  The  rules  became 
 effective  September  28,  2000.  See  65  Fed.  Reg.  58,661  (2000).  Thus,  the  audit 
11
 Schwartz  Section  272  Declaration 
 2 
 review,  we  are  analyzing  whether  any  adjustment  to  QCs  past  financial  statements 
 is  necessary.  This  inability  to  certify  current  financial  statements  does  not  indicate 
 any  issue  with  the  manner  in  which  QC  is  conducting  business  today  or  accounting 
 for  transactions  on  a  going-forward  basis.  None  of  the  past  matters  under  review 
 are  transactions  between  QCC  and  QC.  See  also  the  verified  letter  of  Oren  G. 
 Shaffer,  dated  August  26,  2002,  that  addresses  the  issue  of  restatement  of  financials 
 as  it  relates  to  GAAP  compliance  for  the  BOC. 

 engagement  for  the  year  2000  was  combined  with  2001  and  the  report  was  issued  in  2002. 
12

13
 Schwartz  Section  272  Declaration 
 Before  the  FEDERAL  COMMUNICATIONS  COMMISSION 
 Washington,  DC  20554 
 In  the  Matter  of  )  ) 
 Qwest  Communications  )  WC  Docket  No.  02-189  International  Inc.  ) 
 )  Consolidated  Application  for  Authority  ) 
 to  Provide  In-Region,  InterLATA  Services  )  in  Montana,  Utah,  Washington,  ) 
 and  Wyoming  ) 

 DECLARATION  OF  MARIE  E.  SCHWARTZ 
 Section  271(d)(3)(B)  Compliance  with  Section  272  by  the  BOC 
14
 Schwartz  Section  272  Declaration 
 1 
 47.  The  BOC  follows  Generally  Accepted  Accounting  Principles 
 (GAAP),  including  accrual  accounting,  to  properly  record  expenses  in  the  period 
 incurred.  The  audit  opinion  of  Qwests  external  auditors,  Arthur  Andersen,  L.L.P. 
 (Arthur  Andersen)  confirms  that  the  BOC  follows  GAAP  in  all  material  respects. 
 See  Exhibit  MES-272-6,  the  Report  of  Independent  Public  Accountants  filed  with 
 the  Qwest  Corporation  Annual  Report  10-K  for  year  2001.  The  BOC  also  follows 
 regulatory  accounting  rules  as  required  by  the  FCC.  The  BOCs  books,  records,  and 
 accounts  are  maintained  in  accordance  with  USOA,  Part  32.27,  and  Part  64.901, 
 Allocation  of  Costs.  In  the  past,  the  FCCs  Part  64  and  CAM  audits  have  never 
 reported  a  finding  that  the  BOC  was  not  following  GAAP.  Annual  reports  are  filed 
 publicly  via  the  FCCs  Automated  Reporting  Management  Information  System 
 (ARMIS)  and  are  accompanied  by  the  report  of  independent  accountants,  Arthur 
 Andersen,  which  also  has  found  no  material  departures  from  GAAP.  1  The  Report  of 
 Independent  Public  Accountants  that  was  filed  with  the  FCC  ARMIS  43-03  report 
 for  2001  is  attached  as  Exhibit  MES-272-7.  QCII  is  unable  to  certify  its  current 
 financials  because  the  beginning  balances  for  the  current  quarter  are  derived  from 
 prior  quarters  and  must  include  a  cumulative  effect  with  respect  to  data  for  past 
 matters  requiring  a  restatement  of  QCIIs  financial  reports.  As  part  of  an  ongoing 

 1  /  In  Comprehensive  Review  of  the  Accounting  Requirements  and  ARMIS 
 Reporting  Requirements  for  Incumbent  Local  Exchange  Carriers:  Phase  I,  Report  and  Order,  CC  Docket  No.  99-253,  FCC  00-78,  15  FCC  Rcd  8690  (rel.  Mar.  8,  2000), 

 the  FCC  gave  carriers  the  option  of  choosing  an  attest  examination  or  financial  audit  every  two  years  covering  the  prior  two-year  period.  The  rules  became 
 effective  September  28,  2000.  See  65  Fed.  Reg.  58,661  (2000).  Thus,  the  audit 
15
 Schwartz  Section  272  Declaration 
 2 
 review,  we  are  analyzing  whether  any  adjustment  to  QCs  past  financial  statements 
 is  necessary.  This  inability  to  certify  current  financial  statements  does  not  indicate 
 any  issue  with  the  manner  in  which  QC  is  conducting  business  today  or  accounting 
 for  transactions  on  a  going-forward  basis.  None  of  the  past  matters  under  review 
 are  transactions  between  QCC  and  QC.  See  also  the  verified  letter  of  Oren  G. 
 Shaffer,  dated  August  26,  2002,  that  addresses  the  issue  of  restatement  of  financials 
 as  it  relates  to  GAAP  compliance  for  the  BOC. 

 engagement  for  the  year  2000  was  combined  with  2001  and  the  report  was  issued  in  2002. 
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