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 Federal  Communications  Commission  FCC  03-  228 
 SEPARATE  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 


 Re:  Application  by  SBC  Communications  Inc.,  Michigan  Bell  Telephone  Company,  and  Southwestern  Bell  Communications  Services,  Inc.  for  Authorization  to  Provide  In-  Region, 
 InterLATA  Services  in  Michigan  (WC  Docket  No.  03-  138). 
 Today,  we  grant  SBC  authority  to  provide  in-  region,  interLATA  service  originating  in  the  state  of  Michigan.  I  congratulate  SBC  for  opening  its  operations  in  Michigan  to 
 competition.  Obtaining  Section  271  authority  for  the  first  state  in  the  former  Ameritech  region  marks  a  significant  achievement  and  holds  promise  for  Michigan  consumers.  I 
 also  extend  my  thanks  to  the  Michigan  Public  Service  Commission  and  to  the  staff  of  our  Wireline  Competition  Bureau  for  their  hard  work  reviewing  this  application. 


 I  am  pleased  to  support  this  Order.  At  the  same  time,  I  would  like  to  address  two  areas  that  warrant  special  attention  on  a  going-  forward  basis  --  the  provision  of  wholesale  bills 
 to  competitive  LEC  customers  and  the  processes  for  line  splitting,  the  method  by  which  competitive  carriers  may  offer  both  voice  and  DSL  services  over  the  same  local  loop. 


 Section  271  requires  the  Bell  Companies  to  provide  nondiscriminatory  access  to  unbundled  network  elements,  which  includes  the  obligation  to  provide  competitors  with 
 complete,  accurate,  and  timely  wholesale  bills.  Much  of  the  record  in  this  proceeding  has  focused  on  the  adequacy  of  SBC’s  wholesale  billing  practices  and  I  want  to  thank  the 
 Department  of  Justice  for  its  contributions  to  this  analysis.  This  Order  finds  that  SBC  has  satisfied  the  standard  required  under  our  precedent  for  wholesale  billing,  based  in  part  on 
 a  recognition  that  the  complexity  of  telephone  company  billing  systems  and  the  high  volume  of  transactions  make  some  level  of  carrier-  to-  carrier  disputes  inevitable.  Given 
 the  importance  of  timely  and  accurate  billing  to  the  carrier-  customer  relationship,  I  believe  that  it  is  imperative  that  both  SBC  and  its  wholesale  customers  continue  to 
 develop  and  enhance  the  billing  processes. 
 Similarly,  this  Order  notes  concerns  raised  about  line  splitting  processes  in  Michigan.  To  date,  Michigan  competitors  have  sparingly  used  line  splitting,  but  I  expect  that  decisions 
 in  the  Triennial  Review  Order  will  increase  demand  for  line  splitting.  If  competitors  are  to  successfully  bring  broadband  services  to  the  mass  market,  it  is  essential  that  there  be 
 effective  line  splitting  processes  that  can  accommodate  increasing  volumes.  I  am  pleased  that  SBC  is  engaged  in  collaborative  testing  of  new  line  splitting  procedures  that  would 
 address  many  of  the  concerns  raised. 
 In  the  Public  Interest  section  of  this  order,  we  find  sufficient  assurance  that  local  markets  in  Michigan  will  remain  open  even  after  SBC  receives  Section  271  authorization.  This 
 finding  is  a  prerequisite  for  a  successful  application,  given  Congress’  direction  in  Section  271(  d)(  6)  that  the  market-  opening  provisions  of  Section  271  are  an  on-  going  obligation. 
 With  this  provision  in  mind,  I  would  like  to  encourage  SBC,  the  Michigan  Commission,  and  our  staff  here  at  the  FCC  to  continue  their  diligent  efforts  to  ensure  that  Congress’ 
 standard  is  met. 
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