Common use of STAFF’S POSITION Clause in Contracts

STAFF’S POSITION. Staff reviewed the agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this section, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a portion thereof, discriminates against a Telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement does not discriminate against a Telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, in a separate binder. Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff has reviewed the agreement Amendment, based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) subsection: if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by Commission approve the CommissionAmendment, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated averred that the Agreement Amendment meets the standards set forth in the Act and that it is consistent with the public interest. Staff concluded that, since similarly-situated carriers can enter into essentially the same contract, the Amendment should not be deemed to be discriminatory. Staff concluded that the Agreement Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement contract and that the implementation of the Agreement Amendment would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement the Amendment is discriminatory or contrary to the public interest. Staff recommends also recommended that the Commission require Ameritech toAT&T Illinois, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement within five (5) days from the date upon which the Agreement Amendment is approved, with to modify its tariffs to include the Office of Amendment to the negotiated agreement for each service provided. Also, the Chief Clerk, in a separate binder. Clerk should place the Amendment on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and they should be adopted.

STAFF’S POSITION. Staff has reviewed the agreement Amendment to the Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Amendment to the Agreement should be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇ ▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Amendment to the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff noted that all of the services in the Amendment are priced at or above their respective Long Run Service Incremental Costs (“LRSICs”). Staff concluded that the Amendment to the Agreement does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement Amendment would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this the Amendment to the Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Amendment to the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved Amendment to the agreement is the same as the Amendment to the Agreement filed in a separate binderthis Docket with the Verified Petition. Staff also recommends that the Chief Clerk place the Amendment on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and they should be adopted.

STAFF’S POSITION. Staff reviewed the agreement Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech SBC-ASI to file a copy of the approved Agreement file, within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved agreement is the same as the Agreement filed in a separate binderthis Docket with the Verified Petition. Staff also recommends that the Chief Clerk place the Agreement on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff reviewed the agreement Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved agreement is the same as the Agreement filed in a separate binderthis Docket with the Verified Petition. Staff also recommends that the Chief Clerk place the Agreement on the Commission's web site under "Interconnection Agreements." Finally, Staff recommends that Ameritech file, within five (5) days from the date upon which the Agreement is approved, modify its tariffs to reference the negotiated agreement. The following section of Ameritech’s tariffs should reference the Agreement between American and ▇▇▇▇▇▇ and Ameritech Illinois: Agreements with Telecommunications Carriers (ICC No. 21, Section 19.15). Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff reviewed the agreement First Amendment based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement First Amendment meets the standards set forth in the Act and is consistent with the public interest. ▇▇. ▇▇▇▇▇▇ noted that several of the amendments to the interconnection agreement address issues that are currently before the commission, such as rates and terms for DSL and Line-sharing (No. 00-0393); non-recurring charges; (No. 98-0396); collocations terms and rates (No. 99-0615); dark fiber provisioning (Nos. 00-0538 and 00-0539) and shared transport and UNE-Platform (00- 0700). ▇▇. ▇▇▇▇▇▇ noted that the DSL and UNE Remand Appendices both have sections reserving the rights of the parties to alter this agreement to comply with future Commission or FCC orders. Staff concluded that the Agreement First Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Chief Clerk place the First Amendment on the Commission's web site under "Interconnection Agreements." Staff also recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, in a separate binderverified statement that the approved Agreement is the same as the Agreement to be placed on the Commission's web site under "Interconnection Agreements." Finally, Staff recommends that the Commission require Ameritech Illinois to, within five (5) days from the date the Agreement is approved, modify its tariffs to reference the negotiated agreement for each service. Specifically, the following sections of Ameritech Illinois' tariffs should reference the Ameritech Illinois-Maxcess Interconnection Agreement: Agreements with Telecommunications Carriers at Ill. Commerce Commission No. 21, Section 19.15. Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff has reviewed the agreement Second Amendment to the Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) subsection: if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be Commission approved by the CommissionSecond Amendment to the Agreement, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Second Amendment to the Agreement meets the standards set forth in the Act and that it is consistent with the public interest. Staff concluded that, since similarly- situated carriers can enter into essentially the same contract, the Amendment should not be deemed to be discriminatory. Staff concluded that the Agreement Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement Amendment would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this the Amendment to the Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends recommended that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Amendment to the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved Amendment to the Agreement is the same as the Amendment filed in a separate binderthis Docket with the Verified Petition. Staff also recommended that the Chief Clerk place the Amendment on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and they should be adopted.

STAFF’S POSITION. Staff has reviewed the agreement First Amendment to the Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) subsection: if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by Commission approve the CommissionAmendment to the Agreement, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇ ▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the First Amendment to the Agreement meets the standards set forth in the Act and that it is consistent with the public interest. Staff concluded that, since similarly-situated carriers can enter into essentially the same contract, the Amendment should not be deemed to be discriminatory. Staff concluded that the Agreement Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Amendment to the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this the Agreement is discriminatory or contrary to the public interest. In addition, Staff recommends recommended that the Commission require Ameritech toSBC to file, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement within five (5) days from the date upon which the Amendment to the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved Amendment to the Agreement is the same as the Agreement filed in a separate binderthis Docket with the Verified Petition. Staff also recommended that the Chief Clerk place the Amendment to the Agreement on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and they should be adopted.

STAFF’S POSITION. Staff reviewed the agreement Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved agreement is the same as the one as the Agreement filed in a separate binderthis docket with the Verified Petition. Staff also recommends that the Chief Clerk place the Agreement on the Commission's web site under Interconnection Agreements. Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff reviewed the agreement based on Amendment in this docket in the standards set forth context of the Amendments contained in the dockets cited above and in the context of the criteria contained in Section 252(e)(2252(e)(2)(A) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection Subsection (a) only if it finds that (i) the agreement, or a portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such an agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in In the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ Statements cited in Staff’s Motion, Staff stated that the Agreement meets Amendments meet the standards set forth in the Telecommunications Act of 1996 since they do not discriminate against telecommunications carriers not party to the Amendments, and is they are consistent with the public interest, convenience and necessity. Staff concluded represented that the Agreement does not discriminate against a Telecommunications carrier Amendment in this docket is substantially the same as the Amendments in the dockets cited above and recommended the Commission approve the Amendment in this case for the same reasons. Staff recommended in the Verified Statements that is not a party in order to the Agreement and ensure that the implementation of Amendment is in the Agreement would not be inconsistent with public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to SBC Illinois should implement the public interest. Staff recommends that the Commission require Ameritech toAmendment by filing, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement within five (5) days from of approval by the date upon which the Agreement is approvedCommission, a verified statement with the Office Chief Clerk of the Commission that the approved Amendment is the same as the Amendment filed in this docket with the verified petition. Staff further recommended that that the Chief Clerk, in a separate binder. Staff's Clerk place the Amendments on the Commission’s web site under “Interconnection Agreements.” These recommendations regarding implementation of the Agreement are reasonable and should be adoptedadopted in this proceeding.

STAFF’S POSITION. Staff reviewed the agreement Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement Amendment meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Amendment to the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Amendment to the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved agreement is the same as the one as the Agreement filed in a separate binderthis docket with the Verified Petition. Staff also recommends that the Chief Clerk place the agreement on the Commission's web site under "Interconnection Agreements." Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff reviewed the agreement Agreement based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under subsection (a) if it finds that (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. Staff recommended that the Agreement be approved by the Commission, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff concluded that the Agreement does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement would not be inconsistent with the public interest, convenience or necessity. There are no contested issues in this docket. No party contended that this Agreement is discriminatory or contrary to the public interest. Staff recommends that the Commission require Ameritech to, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement file, within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, a verified statement that the approved agreement is the same as the one as the Agreement filed in a separate binderthis docket with the Verified Petition. Staff also recommends that the Chief Clerk place the agreement on the Commission's web site under Interconnection Agreements. Staff's recommendations regarding implementation of the Agreement are reasonable and should be adopted.

STAFF’S POSITION. Staff has reviewed the agreement very same Amendment, between SBC and other carriers, in dockets 03-0451, 03-0453 and several other dockets, based on the standards set forth in Section 252(e)(2) of the Act. Under this sectionSection, the Commission may only reject an agreement, or any portion thereof, adopted by negotiation under this subsection (a) if it finds that that: (i) the agreement, or a any portion thereof, discriminates against a Telecommunications telecommunications carrier that is not a party to the agreement; or (ii) the implementation of such agreement, or a portion thereof, is not consistent with the public interest, convenience and necessity. In the Verified Statements in 03-0451 and 03-0453, Staff recommended that has concluded that, since similarly-situated carriers can enter into essentially the same contract, the Amendment to the Agreement should not be approved by the Commissiondeemed to be discriminatory. Also in those dockets, for the reasons set forth in the Verified Statement of ▇▇. ▇▇▇▇▇▇▇. ▇▇. ▇▇▇▇▇▇▇ stated that the Agreement meets the standards set forth in the Act and is consistent with the public interest. Staff has concluded that the Agreement Amendment does not discriminate against a Telecommunications telecommunications carrier that is not a party to the Agreement and that the implementation of the Agreement Amendment would not be inconsistent with the public interest, convenience or necessity. Staff has represented that the Amendment in this docket is uniform in nature, and that the Amendment here is identical in substance to the previously mentioned dockets. Staff also represent that it cannot conceive of a situation in which its recommendation for approval would change. There are no contested issues issue in this docket. No Moreover, no party has contended that this Agreement the Amendment is discriminatory or contrary to the public interest. In the Verified Statements in 03-0451 and 03-0453, Staff recommends recommended that the Commission require Ameritech toSBC to file, within five days of the date upon which the Agreement is approved, modify its tariffs to reference the Negotiated Agreement. Staff states that this requirement is consistent with the Commission's orders in previous negotiated agreement dockets and it allows interested parties access to the Agreement. Staff recommends that such reference be included in the following section of Ameritech's tariffs: Agreements with Telecommunications Carriers (I.C.C. No. 21, Section 19.15). In addition, Staff recommends that the Commission require Ameritech to file a copy of the approved Agreement within five (5) days from the date upon which the Agreement is approved, with the Office of the Chief Clerk, in a separate binder. Staff's recommendations regarding implementation of verified statement that the approved Amendment to the Agreement is the same as the Amendment filed in this Docket with the Verified Petition. Staff also recommended that the Chief Clerk place the Amendment on the Commission's web site under "Interconnection Agreements." These recommendations are reasonable and they should be adoptedadopted in this proceeding.