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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Bell Atlantic Telephone Companies' ) Comparably Efficient Interconnection ) Plan for the Provision of Basic Payphone) Services ) ) Implementation of the Pay Telephone ) CC Docket No. 96-128 Reclassification and Compensation ) Provisions of the Telecommunications ) Act of 1996 ) ORDER Adopted: April 15, 1997 Released: April 15, 1997 By the Deputy Chief, Common Carrier Bureau: TABLE OF CONTENTS Paragraph I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. SERVICE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . 6 IV. COMPLIANCE ISSUES . . . . . . . . . . . . . . . . . . . . . . . . 8 A. CEI Plan Requirements . . . . . . . . . . . . . . . . . . 8 B. Other Nonstructural Safeguards. . . . . . . . . . . . . . 49 C. Accounting Safeguards . . . . . . . . . . . . . . . . . . 60 D. Other Issues. . . . . . . . . . . . . . . . . . . . . . . 61 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 VI. ORDERING CLAUSE . . . . . . . . . . . . . . . . . . . . . . . . . 92 I. INTRODUCTION 1. On January 6, 1997, pursuant to the requirements of the Commission's orders in the payphone rulemaking proceeding, the Bell Atlantic Telephone Companies (Bell Atlantic) filed a comparably efficient interconnection (CEI) plan for basic payphone service. In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan describing how it will comply with the Commission's Computer III CEI equal access requirements and nonstructural safeguards for the provision of payphone services. BOCs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOC's own payphone operations to provide payphone services. 2. The Commission issued a public notice of Bell Atlantic's CEI plan on January 8, 1997. On February 7, 1997 seven parties filed comments opposing the plan. Bell Atlantic submitted reply comments on February 24, 1997. For the reasons discussed below, we approve Bell Atlantic's CEI plan. II. BACKGROUND 3. The payphone rulemaking proceeding implemented Section 276 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (1996 Act). Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone service. The 1996 Act provided that such safeguards must, at a minimum, include the nonstructural safeguards adopted in the Computer III proceeding. 4. In the Payphone Order, the Commission determined that the Computer III and ONA nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or cross-subsidize in their provision of payphone service." Accordingly, the Commission required the BOCs to file "CEI plans describing how they will comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI requirements as modified by section 222 of the 1996 Act, network disclosure requirements, and installation, maintenance, and quality nondiscrimination requirements." Obtaining approval of its CEI plan is one of the criteria a BOC must meet before its payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established in the payphone proceeding. 5. The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrument-implemented 'smart payphones' or 'dumb' payphones that utilize central office coin services, or some combination of the two in a manner similar to the LECs." Those tariffs must be filed with the applicable state regulatory commission. Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone affiliate to provide payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis. III. SERVICE DESCRIPTION 6. Bell Atlantic represents that it provides two general types of transmission lines for use with payphone service: (1) Network Controlled Lines (NCL) and (2) Station Controlled Lines (SCL). Network Controlled Lines are used in conjunction with so-called "dumb" payphones. Station Controlled Lines are used in conjunction with so-called "smart" payphones. Bell Atlantic represents that the several NCL services described below are the only payphone-related network services that it uses in conjunction with its own payphone operations. Bell Atlantic also avers that the SCL and optional features available with that service have been offered under state tariff for many years to independent PSPs. Bell Atlantic offers six different types of NCL services: - Two-Way Coin NCL. This service provides network access and control for coin payphones controlled by the LEC's network. Network coin control, coin rating and special operator signaling capabilities are included as part of the service. The standard Two-Way Coin NCL allows 7 or 10 digit calling, 1+ toll dialing, and access to operator services through 0+, 0-, 00-, 01+, 011+ and 10XXX-0 dialing. Billed number screening, which prevents the billing of third number and collect charges to the payphone line number, is included with Two-Way NCL service, and call blocking, which includes the blocking of directly dialed calls to pay-per-call numbers (e.g., 900 or 700 numbers), may be included with the Two-Way Coin NCL service at no additional charge. - One-Way Coin NCL. This service provides all of the features and functionalities included in the Two-Way Coin NCL, except the capability to receive incoming calls. - Two-Way Coinless NCL. This service provides network access and operation of coinless payphones, including card reader or credit card phones. Two-way coinless NCL service blocks chargeable (i.e., sent-paid) local or toll calls that are directly dialed without operator intervention or assistance. The only chargeable local, intraLATA toll, and interLATA calls that may be placed from this line are 0+, 0-, 01+, and 00- dialed operator calls and calls placed using an access code (e.g., 10XXX, 1-800). Outward screening is included with this service to indicate that the calls must be alternately billed as collect, third party, or credit card. Billed number screening is also included to prevent the billing of collect or third number calls to the line number. - One-Way Coinless NCL. This service provides all of the features and functionalities included in the Two-Way Coinless NCL, except the capability to receive incoming calls. - One-Way Inmate NCL. This service provides network access and operation of inmate telephone services at correctional institutions. The one-way inmate NCL service restricts all originating calls to 0+ (automated) collect calls to a presubscribed intraLATA carrier or interLATA carrier. No other outgoing calls are permitted. In Maryland, Virginia, and West Virginia, a one-way inmate coin NCL service is also available as a separate line offering, which enables inmates to also make local coin calls. - Two-Way Inmate NCL. The two-way inmate telephone service permits only directly dialed local or toll calls and 0+, 01+ and 011+ automated calls to the presubscribed intraLATA carrier or interLATA carrier. Incoming calls can also be received on this line. 7. Station Controlled Line service provides network access and operation of station controlled payphones (i.e., smart payphones). SCL service offers the option of blocking directly dialed calls to pay per call numbers (e.g., 900 and 700 audiotext prefixes) at no additional charge. In Washington D.C., Maryland, Virginia, West Virginia, and New Jersey, billed number (i.e., inward) screening, which prevents billing of third number and collect charges to the line number, is offered as an option with SCL service. The following features are also available in a number of states in Bell Atlantic's region as options for use with SCL service: - Inward and Outward Blocking. Inward blocking prevents all incoming calls on the SCL. Outward blocking restricts outgoing calls to 0+ or 0- operator handled calls. - Inward and Outward Screening. Inward screening provides an indicator to carriers and operator service providers that collect or third number charges may not be billed to the SCL line number. Outward screening provides an indicator to the operator services provider that all calls originating from the SCL must be alternately billed and cannot billed to the SCL line number. - Line Side Answer Supervision. LSAS provides a positive signal to the station that indicates when the called party has answered and when the called party has terminated the call. - Limited InterLATA Dialing. LID blocks outgoing chargeable interLATA toll calls, including 1+ interLATA and 10XXX+1 dialed calls. Toll free and other nonchargeable calls are not blocked. InterLATA or intraLATA calls placed through an operator service provider, such as 01+ interLATA and 10XXX+0, are also not blocked. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 8. The Commission's CEI requirements were originally established in the Computer III proceeding, in which the Commission adopted a regulatory framework to govern the provision of integrated enhanced and basic services by the BOCs. As applied in the payphone context, the CEI requirements are designed to give independent PSPs equal and efficient access to the regulated basic payphone services that the BOCs use to provide their own payphone services. BOCs must also provide payphone services to independent payphone providers on a nondiscriminatory basis as required in the payphone rulemaking proceeding. The Commission, in its Computer III proceeding, established nine specific CEI requirements, which are discussed below. Bell Atlantic has described in its submissions how it will satisfy each of these nine requirements. We review below Bell Atlantic's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 9. The Payphone Order deregulated LEC payphones and classified those payphones as customer premises equipment (CPE). In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either 'smart' payphones or 'dumb' payphones that utilize central office coin services, a LEC must also tariff unbundled payphone features that the LEC uses or provides on an unbundled basis. Moreover, BOCs, but not other LECs, must unbundle additional network elements when required by a state or requested by payphone providers based on the specific criteria established in the Computer III and ONA proceedings. 10. The Payphone Order requires BOCs to file CEI plans that explain how they will unbundle basic payphone services. Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic service functions that underlie its provision of payphone service. Nonproprietary information used by the BOC in providing the unbundled basic services must be made available as part of CEI. In addition, any options available to a BOC in the provision of such basic services or functions must be included in the unbundled offerings. 11. As described above, the basic services underlying Bell Atlantic's payphone services consist of a Station Controlled Line (SCL) service that is used with 'smart' payphones and a Network Controlled Line (NCL) service that is used with 'dumb' payphones. Bell Atlantic represents that NCL service will provide the same features and functionalities that Bell Atlantic utilizes in providing its own payphone services on a bundled basis, including call screening, call blocking and central office coin control to monitor, verify and return coin deposits. In contrast, Bell Atlantic will offer certain optional features on an unbundled basis in conjunction with its SCL service. 12. Bell Atlantic represents that all of the features and functions associated with these basic services are available to independent payphone providers on the same basis as they are available to Bell Atlantic's payphone operations. In addition, Bell Atlantic represents that it will respond to additional requests from independent payphone providers for unbundled basic services through the existing 120-day ONA process and will make those service available where such requests comply with the factors established by the Commission for selection of initial ONA services. 13. APCC and the Payphone Associations argue that the CEI plan must be rejected because it does not sufficiently unbundle payphone features and functionalities from the payphone access line. APCC argues that Bell Atlantic must be required to offer the basic payphone lines for its COCOT and coin line services and separately offer the features and functions that are provided as part of its basic payphone service offerings. APCC and the Payphone Associations argue that, without such unbundling and separate tariffing, it will not be possible to ensure that Bell Atlantic's payphone offerings are nondiscriminatory and priced according to cost. APCC and the Payphone Associations maintain that PSPs must be able to subscribe to Bell Atlantic's coin line without being required to take and pay for all of the additional features bundled with the line, such as answer supervision and call screening. Moreover, APCC argues that Bell Atlantic should price these additional features at the same rate whether they are used with COCOT or coin lines. The Payphone Associations further contend that Bell Atlantic's claims of technical infeasibility should be rejected. The Payphone Associations also argue that, because certain features are bundled with coin line service, the only way that unaffiliated PSPs will be able to use Bell Atlantic's coin line service is if they discontinue their use of smart payphones. Bell Atlantic responds that its NCL and SCL offerings comply with the CEI unbundling requirement. It argues that this requirement only requires a BOC to unbundle features and functionalities that the BOC itself uses on an unbundled basis. 14. We find that Bell Atlantic's plan satisfies the CEI unbundling requirement contained in the payphone proceeding. The payphone rulemaking proceeding requires BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone services using either "smart" or "dumb" payphones or to offer inmate calling service. In addition, consistent with the requirements of the payphone rulemaking proceeding, BOCs must provide, on a tariffed basis, the unbundled features and functions that they provide to unaffiliated PSPs or to their own payphone operations. Bell Atlantic's plan, as supplemented, satisfies these requirements. We note, however, that Bell Atlantic may choose to unbundle additional payphone-specific features and functions, states may require further unbundling, or independent PSPs may request additional unbundled features and functions through the ONA 120-day service request process. Any other features and functions provided by Bell Atlantic on an unbundled basis must comply with the tariffing and CEI requirements of the payphone proceeding, Computer III and ONA. 15. We reject the contention of APCC and the Payphone Associations that Bell Atlantic must unbundle the coin supervision and other features of its NCL service offerings. As noted in the Clarification Order, the Commission's payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled basis." In the Clarification Order, we stated that, for example, if a BOC provides answer supervision bundled with the basic payphone line, the BOC is not required either to unbundle that service from its state tariff for payphone service, or to tariff that service at the federal level. If the LEC, however, provides answer supervision separately, on an unbundled basis, either to affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal jurisdictions. Because Bell Atlantic offers, and will use, NCL service on a bundled basis, Bell Atlantic is not obligated to unbundle the individual features that comprise that service in its CEI plan. Moreover, Bell Atlantic has unbundled, and has committed to tariffing in the federal jurisdiction, basic features that Bell Atlantic offers to payphone providers that subscribe to its SCL service. No further unbundling is required at this time. Independent PSPs may seek further unbundling of Bell Atlantic's NCL service by making a request pursuant to the ONA process. 2. Interface Functionality 16. The interface functionality requirement obligates the BOC to make available standardized hardware and software interfaces that are able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. 17. Bell Atlantic claims that all PSPs may connect their payphone customer premises equipment ("CPE") to Bell Atlantic's basic network through standard, publicly disclosed network interfaces. Bell Atlantic notes that the technical specifications for these interfaces were identified in August 1996 in Bell Atlantic's Network Disclosure Statement for payphones, which was published in the Bellcore Digest. Bell Atlantic asserts that no specialized interfaces, signaling, abbreviated dialing, or other unique capabilities will be provided to any party, including its own payphone affiliate, in support of their payphone services. As required by the Commission's Network Disclosure requirements, Bell Atlantic also commits to disclosing any new interface in advance of its introduction. 18. Telco asserts that Bell Atlantic's statement that PSPs will obtain access to the network through existing interfaces available through Bell Atlantic's standard network disclosure procedures is insufficient. Telco argues that Bell Atlantic must provide "further explanation or meaningful detail regarding the technical requirements a PSP must meet to connect to network interfaces." Telco also faults Bell Atlantic for providing no description of the interfaces. 19. We find that Bell Atlantic complies with the interface functionality requirement. As stated above, the interface functionality requirement only obligates a BOC to make available standardized hardware and software interfaces that will be able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service provided by the BOC. Bell Atlantic avers that it has done so and Telco does not dispute this representation. Beyond the filing of network disclosures, which Bell Atlantic states that it has filed, as discussed below, this obligation does not require Bell Atlantic to provide technical details in the CEI plan explaining how PSPs will connect to Bell Atlantic network interfaces. 3. Resale 20. The resale requirement established in Computer III obligates a "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anticompetitive pricing in unregulated markets." Based on the requirement in the Payphone Order and the Reconsideration Order, any basic services provided by a BOC to its payphone affiliate, as well as any payphone service provided to others, must be available on a nondiscriminatory basis to other payphone providers. 21. In its CEI plan, Bell Atlantic represents that it "will purchase all underlying basic services at tariffed rates and offer them in conjunction or combination with payphones on an unregulated, detariffed basis." We find that Bell Atlantic's CEI plan meets the resale requirement. We are not persuaded by Telco's argument that Bell Atlantic's plan is insufficient, because it "fails to provide any specificity as to what combinations will be offered for resale, whether resale will be offered on a nondiscriminatory basis, or what mechanisms will exist to enable competitors to ensure that resale obligations are being met." We find that Bell Atlantic's representation that all basic services provided to its payphone operations will be available, pursuant to tariffed arrangements, to all PSPs, is sufficient to meet this CEI requirement. We find that Bell Atlantic is not required to provide in its CEI plan the level of detail sought by Telco in order to comply with the resale CEI requirement. To the extent that Telco's objections are based on concerns that Bell Atlantic's tariffed payphone offerings unlawfully discriminate against unaffiliated PSPs, contrary to Bell Atlantic's representation in this proceeding, such specific, fact-based claims should be addressed in federal or state tariff proceedings or formal complaint actions against Bell Atlantic. 4. Technical Characteristics 22. This requirement obligates a carrier to provide basic services with technical characteristics that are equal to the technical characteristics the carrier uses for its own payphone services. 23. Bell Atlantic represents that the facilities provided to both affiliated and unaffiliated PSPs are comparably efficient in type, quality and all technical parameters. Bell Atlantic also claims that all PSPs will interconnect with Bell Atlantic's basic services through published interfaces. We are not persuaded by Telco's argument that Bell Atlantic's CEI plan fails to explain sufficiently how it will ensure that technical characteristics are nondiscriminatory, because it does not provide any details for the Commission to determine whether there will be any discrimination between affiliated and unaffiliated PSPs. We find that Bell Atlantic is not required by our CEI rules to furnish the additional information requested by Telco in order to satisfy the technical characteristics requirement. We therefore find that Bell Atlantic's CEI plan comports with the technical characteristics requirement. To the extent that Telco obtains credible evidence that Bell Atlantic has unlawfully discriminated against unaffiliated PSPs in the assignment of access lines, Telco may initiate a formal complaint action against Bell Atlantic. 5. Installation, Maintenance, and Repair 24. The Payphone Order requires BOCs to describe in their CEI plans how they will comply with the nondiscrimination requirements in Computer III and ONA regarding the quality of service, installation, and maintenance. This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in a CEI offering to unaffiliated PSPs are the same as those the carrier provides to its own or its affiliated payphone service operations. BOCs also must satisfy reporting and other requirements showing that they have met this requirement. 25. In its CEI plan, Bell Atlantic represents that it will provide the same quality of installation, maintenance and repair service to both affiliated and unaffiliated PSPs. Bell Atlantic indicates that orders for installation, maintenance and repair will be assigned and completed on a nondiscriminatory basis. Bell Atlantic claims that unaffiliated PSPs will be able to report network service problems in the same manner as affiliated PSPs and also will be able to use the same service ordering methods to establish network access. In addition, Bell Atlantic avers that it will provide unaffiliated PSPs with the same scheduling and dispatch processes, so that due dates and times for completion will be provided and scheduled on a nondiscriminatory basis. 26. APCC and Telco argue that Bell Atlantic's CEI plan must provide further detail regarding how it will provide installation and repair on a nondiscriminatory basis to unaffiliated PSPs. APCC contends that Bell Atlantic's plan must discuss the service ordering procedures that apply when a location provider changes its payphone service from a Bell Atlantic payphone to an unaffiliated PSP's payphone or vice versa, especially when a change of ownership of the location provider is involved. APCC asserts that these procedures must be specified to ensure that conflicts that arise in this context are resolved in a nondiscriminatory fashion, and that Bell Atlantic's payphone operations are not given undue preferences. APCC also argues that Bell Atlantic must specify the procedures that it will use to ensure that Bell Atlantic will not engage in unfair marketing practices when Bell Atlantic's payphones are replaced by payphones operated by an unaffiliated PSP. 27. In addition, APCC asserts that Bell Atlantic is required to explain whether it intends to share personnel between its operating company and payphone operations and, if so, the measures it will implement to ensure that the use of shared personnel will not lead to discrimination in the provision of installation, maintenance and repair. Finally, APCC argues that Bell Atlantic should identify for its payphone offerings the demarcation point between the switched network and a payphone provider's inside wire. 28. In its reply, Bell Atlantic represents that as part of its CEI plan, it will provide service ordering, installation and maintenance, including service intervals, on a nondiscriminatory basis to both nonaffiliated and affiliated PSPs. In support, Bell Atlantic submits its IPP Information Booklet which describes its procedures for handling orders for provisioning and repair of network services and the expected service intervals. Bell Atlantic further represents that technical support for installation and maintenance of network services will be provided on a nondiscriminatory basis. According to Bell Atlantic, the same technicians, monitoring systems and testing systems will be used without regard to the affiliation of the PSP. Bell Atlantic affirms that orders, preferred request dates and repair reports will be handled on a first-come, first-served basis, although independent PSPs will be able to request that Bell Atlantic not dispatch repair personnel in response to trouble reports from premise owners, callers, or others unless the PSP authorizes such a dispatch through use of a code word or direct confirmation. With respect to personnel sharing issues, Bell Atlantic avers that only those personnel processing or completing service orders placed by independent PSPs will have access to those accounts. Bell Atlantic asserts that it maintains password restrictions os that other marketing personnel will not have access to this information. 29. Bell Atlantic claims that its IPP Information Booklet also contains information concerning the demarcation point at payphone premises. Bell Atlantic represents that its policies related to establishing the demarcation point will apply equally to independent payphones and payphones already installed by Bell Atlantic, except as provided in the payphone rulemaking proceeding for existing grandfathered payphones. Bell Atlantic avers that the demarcation point between regulated network facilities and deregulated premises wiring and equipment will be at the minimum point of entry of the premises (MPOE), in compliance with the Commission's MPOE standards. For newly installed payphones, Bell Atlantic represents that it will install a network interface device (NID) that will act as the demarcation point in conformance with Part 68 of the Commission's rules. Bell Atlantic avers that when maintenance or repair work is performed for Bell Atlantic's existing payphones grandfathered from the Part 68 requirements, a "virtual" Network Interface Device (NID) will be employed to denote the demarcation point in order to properly account for the regulated and deregulated wiring work. According to Bell Atlantic, although no NID hardware will be physically present, the technicians will still identify the point at which a NID would have been placed for a new installation of an affiliated or unaffiliated payphone. Bell Atlantic represents that technicians have received training on these demarcation policies and that only the work performed up to that point will be treated as regulated services. 30. We find that Bell Atlantic's CEI plan complies with the installation, maintenance, and repair requirement. According to Bell Atlantic, the personnel that Bell Atlantic will use to provide installation, maintenance and repair will be the same for unaffiliated PSPs as well as Bell Atlantic's PSP. Bell Atlantic affirms that the same technicians, monitoring systems and testing systems will be used to install, maintain and repair lines, regardless of whether the requesting party is an affiliated or unaffiliated PSP. Moreover, Bell Atlantic represents that the time intervals for providing installation, maintenance and repair will be the same for all PSPs. We conclude that Bell Atlantic's description of the procedures that it will employ to ensure nondiscriminatory treatment of its own payphone operations and those of unaffiliated PSPs is sufficient for us to conclude that its CEI plan satisfies this parameter. 31. We further find that, so long as Bell Atlantic provides installation, maintenance and repair in a nondiscriminatory fashion and the time intervals for providing such services are the same for all PSPs, Bell Atlantic's payphone operations may share personnel with its regulated operations. We reject APCC's argument that Bell Atlantic must provide further explanation about personnel sharing in order to ensure that there will be no discrimination against unaffiliated PSPs. As stated above, Bell Atlantic represents that no preferences in ordering, installation, maintenance, and repair will be given to its own payphone operations. In the Payphone Order, the Commission specifically declined to require BOCs to provide payphone CPE through a structurally separated affiliate. We note that the Commission's rules require BOCs to allocate properly the costs, including costs associated with the use of personnel, between regulated and nonregulated operations. We also note that, pursuant to section 94.904 of the Commission's rules, LECs that file CAMs are required to have an independent audit performed annually. 32. We also conclude that Bell Atlantic has sufficiently identified the demarcation point to determine when maintenance becomes the payphone provider's responsibility and is not part of the access network service. Finally, we find that APCC's request that service procedures address unfair marketing practices is beyond the scope of the installation, maintenance and repair requirement. To the extent that APCC's concern about unfair marketing practices raises issues about access to CPNI of unaffiliated PSPs, we conclude that Bell Atlantic's plan complies with applicable CPNI requirements. 6. End User Access 33. With regard to payphone services, this parameter requires the BOC to provide to all end users the same network capabilities to activate or obtain access to payphone services that utilize the BOC's facilities. This parameter also requires the BOC to provide all end users equal opportunities to obtain access to basic network facilities. 34. Bell Atlantic represents that end users will be able to place calls from payphones operated by affiliated and unaffiliated PSPs using Bell Atlantic's basic dial tone line services in the same manner. Bell Atlantic also asserts that all PSPs will be able to provide end users the same network dialing and calling capabilities that are available to end users of Bell Atlantic payphones. We find that Bell Atlantic's CEI plan comports with the end user access requirement established by the Commission. 7. CEI Availability 35. This requirement obligates a BOC's CEI offering to be available and fully operational on the date that it offers its corresponding payphone service to the public. The requirement also obligates a BOC to provide a reasonable time prior to that date when prospective users of the CEI offering can use the CEI facilities and services for purposes of testing their payphone service offerings. Past decisions also have referred to this as the 90-day notice requirement. 36. The payphone rulemaking proceeding established the following tariffing requirements for LECs. LECs must file tariffs in the states for basic payphone services that enable independent PSPs to offer payphone services using either smart or dumb payphones and for any unbundled features that the LECs provide to their payphone operations or to others. LECs are not required to file tariffs for the basic payphone line for smart and dumb payphones with the Commission. As stated in the Clarification Order, LECs are required to file state and federal tariffs for "payphone-specific, network-based features and functions" that LECs provide "separately and on an unbundled basis from the basic payphone line, either to [their] own operations or to others." 37. The Clarification Order also granted all LECs a limited waiver of the federal tariffing requirements for unbundled features and functions that a LEC must meet before it is eligible to receive payphone compensation. Pursuant to this waiver, LECs must file interstate tariffs for unbundled features and functions within 45 days of the release date of the Clarification Order. In addition, each individual BOC was required to file, by April 10, 1997, a written ex parte document that advises the Commission on the status of intrastate tariffs for the features and functions that it has not yet federally tariffed, and stating that it commits to filing federal tariffs for such features and functions within 45 days of the release date of that Order. 38. Bell Atlantic represents that all basic network exchange services are currently available or will be available by April 1997 to independent payphone service providers in all geographical areas served by Bell Atlantic. Bell Atlantic notes that existing basic payphone line services to operate smart payphones have been available to nonaffiliated PSPs for a number of years and the payphone line services to operate inmate payphones have been available since 1996. Bell Atlantic further represents that it will make testing capability for the new NCL services available to any independent payphone service providers upon request. Bell Atlantic also filed with its CEI plan illustrative state tariffs for its coin line (NCL) service and for the COCOT (SCL) service. 39. APCC and the Payphone Associations contend that Bell Atlantic's CEI plan must be rejected on the ground that Bell Atlantic did not file federal tariffs. They contend that, pursuant to the Reconsideration Order, Bell Atlantic must file tariffs for unbundled features at both the state and federal levels, and that the only service for which a federal tariff is not required is the basic line for "smart" and "dumb" payphones. APCC argues that all basic payphone services and features other than the access line must be federally tariffed. APCC argues that Bell Atlantic's plan must be rejected because it has not filed all required federal tariffs, including tariffs for coin line features. 40. In response, Bell Atlantic contends that it is in compliance with the payphone rulemaking proceeding's federal tariffing requirement, as implemented by the Clarification Order. In an ex parte filing, Bell Atlantic represents that it will file federal tariffs, in accordance with the requirements of the Clarification Order, for the following unbundled features: Line Side Answer Supervision; Inward/Outward Screening; Outward Screening; Inward Call Blocking; Outward Call Blocking; and Limited InterLATA Dialing. Bell Atlantic also avers that it has already filed state tariffs for basic payphone lines for "smart" and "dumb" payphones, and that, through these state tariffs, its payphone operations will take the same tariffed payphone services that are available to independent PSPs. 41. APCC also argues that Bell Atlantic must be required to disclose where coin line service is not available and whether Bell Atlantic has any payphones currently installed in those areas. In addition, APCC asserts that Bell Atlantic must disclose how many of its payphones are subscribed to COCOT service and how many are subscribed to coin line service. Further, APCC contends that the CEI plan is incomplete because Bell Atlantic only filed an illustrative for one state. In response, Bell Atlantic claims that it provided citations for all the payphone line tariffs for all of the states in its CEI plan. Bell Atlantic also attached each of its state tariffs to its Reply. 42. We find that Bell Atlantic's CEI plan complies with the CEI availability requirement. We reject APCC's argument that Bell Atlantic must file a federal tariff for all payphone service features and functions except for the basic access line for COCOT and coin line services. As stated in the Clarification Order, BOCs need only submit federal tariffs for payphone-specific, network-based features and functions if the BOC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to others. Because Bell Atlantic will use, and offer, the features and functionalities of the NCL service on a bundled basis, Bell Atlantic need not either unbundle those features or file a separate federal tariff for them. As noted, Bell Atlantic has committed to file federal tariffs for the unbundled payphone features offered in conjunction with its SCL service. We also reject APCC's contention that Bell Atlantic may not rely on illustrative or sample tariffs. We do not require carriers to file a complete set of tariffs with their CEI submissions. Sample or illustrative tariffs are sufficient. 43. We also conclude that Bell Atlantic is not required in its CEI plan to identify specific geographic areas where coin line service is not available or to state whether Bell Atlantic has any payphones in such areas or what type of service, NCL or SCL, is being provided. In its CEI plan, Bell Atlantic represents that "access to all basic network exchange services will be available to both affiliated and unaffiliated PSPs by April 1997 in all geographical areas served by Bell Atlantic." Bell Atlantic further represents that "all network controlled line (NCL) services will be made available to unaffiliated payphone service providers in all central offices where such services are provided to its own payphone operations." We find Bell Atlantic's representation about the availability of such services provides adequate information concerning the availability of its coin line services for purposes of our CEI plan requirements. We also find no basis in our CEI requirements or the payphone orders for directing Bell Atlantic to identify how many of its payphones use SCL service and how many use NCL services for purposes of satisfying our CEI requirements. 44. Finally, we waive on our motion the 90-day notice requirement for Bell Atlantic's provision of NCL services. Bell Atlantic may provide and continue to provide NCL service through the use of the CEI offering described herein for such service without first providing a period of time for unaffiliated carriers to test such services. This waiver is reasonable in this context because, unlike the provision of a new enhanced service, Bell Atlantic has been offering NCL service for many years. To bar Bell Atlantic from continuing to offer NCL services to provide payphone service pending completion of a testing period would result in a suspension of service. Bell Atlantic is not, however, relieved of its obligation to permit unaffiliated PSPs to conduct testing, if they deem necessary, of the NCL CEI offering. For purposes of approving this CEI plan, we simply waive the requirement that Bell Atlantic may not offer NCL services before such testing is accomplished. Bell Atlantic represents that if and when other basic services are deployed, Bell Atlantic will make testing capability available to unaffiliated PSPs at the same time that such capability is available to Bell Atlantic. 8. Minimization of Transport Costs 45. This requirement obligates carriers to provide competitors with interconnection facilities that minimize transport costs. 46. Bell Atlantic asserts that the Commission has found this requirement satisfied in the enhanced services context if affiliated and unaffiliated enhanced service providers (ESPs) are charged the same rates for underlying basic services. Bell Atlantic asserts that it will charge affiliated and non-affiliated PSPs the same tariffed rates for basic payphone services. We find that Bell Atlantic's CEI plan complies with the minimization of transport costs requirement. 9. Recipients of CEI 47. This requirement prohibits a BOC from restricting the availability of its CEI offering to any particular class of customer or PSP. 48. Bell Atlantic avers that access to all basic network exchange services will be available, either under existing or newly-filed tariffs, to both affiliated and nonaffiliated PSPs by April 1997 in all central offices where such services are provided by Bell Atlantic to its own payphone operations. Bell Atlantic also represents that it will make CEI testing for the newly-tariffed dumb payphone lines available to any nonaffiliated PSPs that request it. We find that Bell Atlantic has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 49. In addition to the CEI requirements established in Computer III, and applied to BOC provision of payphone services in the Payphone Order, a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination reporting. 1. Customer Proprietary Network Information 50. The Payphone Order requires Bell Atlantic to explain how it will comply with the Computer III CPNI safeguards, to the extent they are not inconsistent with section 222 of the Communications Act of 1934, as amended. Although the requirements of section 222 became effective immediately upon enactment, the Commission has initiated a proceeding to consider regulations interpreting and specifying in more detail a telecommunications carrier's obligations under this provision. The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they do not conflict with section 222. 51. In its payphone CEI plan, Bell Atlantic avers that it will comply with Section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. Bell Atlantic also represents that password restricted access will prevent the sales and marketing personnel of the affiliated PSP from accessing any CPNI of unaffiliated PSPs or others. 52. APCC and Telco claim that Bell Atlantic's payphone CEI plan does not offer sufficient information concerning how Bell Atlantic will comply with CPNI requirements. APCC contends that Bell Atlantic should explain how it will protect, under nondiscriminatory conditions, the CPNI of PSPs, as well as the CPNI of Bell Atlantic's existing customers, including current customers of semi-public payphone service. APCC also argues that, since the existing tariffed semi-public service is being terminated pursuant to section 276, Bell Atlantic's payphone operation has no more right to access and use the CPNI of semi- public service customers than any other PSP. Further, APCC contends that the deregulation of semi-public service presents PSPs with a potential marketing opportunity to replace Bell Atlantic as the payphone service provider for these customers. APCC argues that semi-public customers should be provided notice and a meaningful opportunity to replace Bell Atlantic with another payphone service provider. It contends that Bell Atlantic must disclose how it will provide such notice in a neutral fashion, including giving such customers an opportunity to authorize disclosure of CPNI on a nondiscriminatory basis to interested payphone providers without preference to Bell Atlantic's payphone operations. 53. Bell Atlantic confirms that usage on semi-public payphone lines will be available to the PSP purchasing the underlying access line on the same basis such information is available for the NCL service and SCL service generally. In addition, Bell Atlantic represents that it intends to inform customers of the deregulation and detariffing of their existing service, although it disagrees that special notification to current semi-public customers is mandated. Bell Atlantic further claims that information concerning Bell Atlantic's semi-public payphones customers will remain proprietary customer account information and that no statutory provision or Commission rule prohibits Bell Atlantic from using its own CPNI to market and supply an existing service just because the service has been deregulated. 54. In providing payphone services, Bell Atlantic must comply with the Commission's pre-existing Computer III CPNI requirements, to the extent that they are consistent with section 222 of the 1996 Act, and any regulations adopted by the Commission pursuant to section 222. In its payphone CEI plan, Bell Atlantic represents that it will comply with section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. Accordingly, we find that Bell Atlantic's plan comports with CPNI requirements. In reaching this conclusion, we do not address issues raised by APCC relating to traffic information on the use of semi-public payphones, or Bell Atlantic payphone's access to service order, billing or other statistical information about Bell Atlantic's business or residence customers. Issues relating to the interpretation of section 222, and how it relates to the Computer III CPNI rules, are being addressed in the CPNI rulemaking, and therefore will not be considered here. We do, however, reject APCC's request that we require Bell Atlantic to inform site owners about competitive options for semi-public payphone service, because no such requirement was adopted in the Payphone Order or in the Reconsideration Order, or is otherwise required by our CEI rules. 2. Network Information Disclosure 55. The Payphone Order requires Bell Atlantic to disclose to the payphone services industry information about network changes and new network services that affect the interconnection of payphone services with the network. Bell Atlantic must make that disclosure at the "make/buy" point; that is, when Bell Atlantic decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface through which a PSP interconnects with Bell Atlantic's public switched network. Bell Atlantic must provide that information to members of the payphone services industry that sign a nondisclosure agreement, within 30 days after the execution of such nondisclosure agreement. Bell Atlantic also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that service. 56. In the Payphone Order, the Commission waived the notice period for disclosure of network information relating to the "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory requirements of that order. Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15, 1997. 57. Bell Atlantic represents that all PSPs may connect their payphone CPE to Bell Atlantic's basic network through standard, publicly disclosed network interfaces. Bell Atlantic commits to disclosing any new services or network changes that affect the interoperability of payphone services with the network. As described above, consistent with the requirements of the Payphone Order, Bell Atlantic made the necessary network disclosure for its new network interface in August 1996. We therefore find that Bell Atlantic's CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 58. In the Payphone Order, the Commission directed the BOCs to comply with the Computer III and ONA requirements regarding nondiscrimination in the quality of service, installation, and maintenance. Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semi-annual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of covered service offerings, installation and maintenance. 59. Bell Atlantic represents that it will continue to comply with all existing Commission orders and any future Commission orders related to nondiscrimination reporting. Bell Atlantic commits to modifying its quarterly Installation and Maintenance Nondiscrmination Reports filed pursuant to ONA requirements to include performance data for the basic network services provided to unaffiliated and affiliated payphone service providers. Bell Atlantic also commits to include payphone related information in its annual filing of the ONA Nondiscrimination Maintenance Report. We find that Bell Atlantic's CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 60. In the Payphone Order and the Accounting Safeguards Order, the Commission concluded that it should apply accounting safeguards identical to those adopted in Computer III to BOCs providing payphone service on an integrated basis. Pursuant to Computer III, the BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These safeguards consist of five principal elements: 1) the establishment of effective accounting procedures, in accordance with the Commission's Part 32 Uniform System of Accounts requirements and affiliate transactions rules, as well as the Commission's Part 64 cost allocation standards; 2) the filing of cost allocation manuals (CAMs) reflecting the accounting rules and cost allocation standards adopted by the BOC; 3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with their cost allocation manuals; 4) the establishment of detailed reporting requirements and the development of an automated system to store and analyze the data; and 5) the performance of on-site audits by Commission staff. Bell Atlantic must comply with these accounting safeguards. We note that the approval granted to Bell Atlantic in this order is contingent upon the CAM amendments associated with Bell Atlantic's provision of payphone service going into effect. D. Other Issues 1. Sufficiency 61. APCC, the Payphone Associations, and Telco generally assert that Bell Atlantic's CEI plan insufficiently describes how Bell Atlantic intends to comply with the CEI requirements, and request the Commission to require Bell Atlantic either to amend or to refile its plan. As discussed above, we find that Bell Atlantic adequately complies with each of the CEI requirements. 2. Tariffing Issues 62. APCC and the Payphone Associations raise various objections to the content of Bell Atlantic's state tariffs. APCC and the Payphone Associations contend that the structure of Bell Atlantic's tariffs and Bell Atlantic's failure to disclose its pricing methodologies do not permit an effective comparison of the charges for various services and service elements so as to ensure that the tariffs are cost based and that the coin line service is no longer subsidized by regulated services. For example, both APCC and the Payphone Associations allege that the payphone rates tariffed by Bell Atlantic in Pennsylvania are discriminatory because coin line service costs far more on average than COCOT service, even though the coin line service includes certain features "bundled" with the coin line, while many of these same features must be purchased separately from the COCOT service. Similarly, the Payphone Associations claim that the COCOT rates tariffed by Bell Atlantic in New Jersey are exorbitant and cannot be reasonably claimed to be cost-based. Bell Atlantic responds that complaints about the adequacy of the rates or other aspects of its state tariffs should be raised in state tariff proceedings, not in this CEI proceeding. It argues that the Commission has delegated to the states the responsibility for reviewing Bell Atlantic's coin line tariffs. 63. We agree with Bell Atlantic that the state or federal payphone tariff proceedings are the appropriate fora to address complaints concerning the tariffed rates, terms and conditions. The Commission stated in the Reconsideration Order that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with the requirements of section 276." That order required that the tariffs for these LEC services must be: (1) cost based; (2) consistent with the requirements of section 276 with regard, for example, to the removal of subsidies from exchange and exchange access services; and (3) nondiscriminatory. In addition, the order established that "[s]tates must apply these requirements and the Computer III guidelines for tariffing such intrastate services." The order further stated that "[w]here LECs have already filed intrastate tariffs for these services, states may, after considering the requirements of this order, the Report and Order, and section 276 conclude: 1) that existing tariffs are consistent with the requirements of the Report and Order as revised herein; and 2) that in such case no further filings are required." Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs operating in their state to file these tariffs with the Commission." 3. Screening Codes 64. APCC, AT&T and MCI contend that Bell Atlantic is required, pursuant to the Reconsideration Order, to provide PSPs using COCOT lines (SCL service) screening code digits that uniquely identify their lines as payphone lines. APCC asserts that if Bell Atlantic transmits a unique screening code only on its coin line payphones, which are primarily used only by payphones operated by Bell Atlantic, and not on its COCOT lines, which are primarily used by PSPs, Bell Atlantic is discriminating in favor of its own payphone provider by providing it a great advantage in the collection of per-call compensation from IXCs. In addition, MCI maintains that Bell Atlantic's plan does not provide screening codes digits that can be "transmitted by PSPs for all access methods and from all locations." 65. In reply, Bell Atlantic represents that, in accordance with the Payphone Orders, Bell Atlantic will transmit "27" (NCL) and "07" (SCL) line screening codes based solely on the type of line used by a PSP, not according to whether the PSP is affiliated or unaffiliated. Bell Atlantic also asserts that, pursuant to the Commission's latest OLS order, it has made FLEX ANI available to interexchange carriers by tariff. Using FLEX ANI, Bell Atlantic represents that it will transmit a "70" code that uniquely identifies SCLs as payphone lines. Additionally, Bell Atlantic will provide quarterly COCOT lists identifying all payphone lines in service as well as monthly bill notations indicating that a line is used for a payphone, which will aid carriers in verifying the calls from line numbers that transmitted the 07 code. 66. We find that the issue of whether Bell Atlantic is providing screening information in compliance with the requirements established in the payphone rulemaking proceeding is outside the scope of the CEI review process and is more appropriately addressed in a formal complaint or other proceedings. We note that this issue is currently under review. 4. Numbering Assignments 67. According to APCC, the Payphone Order requires LECs to assign line numbers to payphones on a nondiscriminatory basis. APCC contends that Bell Atlantic's CEI plan is deficient in that it does not describe its number assignment policy or how that policy is applied to Bell Atlantic's payphone division and other PSPs. APCC maintains that Bell Atlantic should be required to reallocate the numbers assigned to the existing base of payphones, without charge, so that an equal percentage of LEC payphones and PSPs are assigned 8000 and 9000 series numbers. In reply, Bell Atlantic asserts that it presently assigns new payphone numbers, including 8000 and 9000 blocking numbers, on a nondiscriminatory, first-come, first-served basis regardless of whether the requesting PSP is affiliated or unaffiliated with Bell Atlantic. 68. We agree with APCC that the Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to reallocate existing number assignments. Bell Atlantic represents that it presently assigns payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by Bell Atlantic in the context of this CEI plan. 5. Dialing Parity 69. MCI asserts that Bell Atlantic does not explain how it will comply with the dialing parity requirement in the Payphone Order, including access to operator services, directory assistance, and directory listings. In reply, Bell Atlantic represents that, in the Payphone rulemaking proceeding, the Commission ruled that the duty to provide intraLATA dialing parity applies to payphones when the duty is generally required. 70. The Payphone Order concluded that the dialing parity requirements adopted pursuant to section 251(b)(3) of the 1996 Act should extend to all payphone location providers. The Commission stated that such dialing parity for payphones should be implemented at the same time as dialing parity for other telephones. Bell Atlantic must, of course, comply with these requirements. We conclude, however, that Bell Atlantic is not required as part of the CEI process to demonstrate how it will comply with the dialing parity requirement. The Commission specified in the Payphone Order that a BOC's CEI plan must describe how it will conform to the CEI requirements with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. Therefore, MCI's request that Bell Atlantic detail how it will comply with the dialing parity requirement is outside the scope of this CEI review proceeding. 6. Uncollectibles 71. AT&T asserts that Bell Atlantic must explain its treatment of uncollectibles due to fraud. AT&T contends that, to the extent Bell Atlantic establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be accorded to non-affiliates. Bell Atlantic represents that, because collect calls, calling card calls, and other alternately billed calls will continue to be offerings of Bell Atlantic's operator services, the risk and responsibility for performing validation through LIDB and the billing and collection for these calls, including attendant fraud losses and uncollectibles, will remain with the operator service provider. We find that, while the Payphone Order generally requires that fraud protection must be available on a nondiscriminatory basis, it does not establish any specific requirements for uncollectibles. Because the issue of the treatment of uncollectibles appears to raise principally accounting matters, that issue will be addressed in review of Bell Atlantic's CAM. 7. Operator Services 72. APCC contends that Bell Atlantic's CEI plan fails to specify whether Bell Atlantic's operator services are part of its deregulated payphone services. APCC claims that, if Bell Atlantic's operator services are regulated, Bell Atlantic must demonstrate that it is not subsidizing its payphone operations or discriminating between its payphone operations and other PSPs in the provision of these services. For example, if Bell Atlantic is offering a commission to its payphone operations for presubscribing its payphones to Bell Atlantic's operator services, then such commissions must be available to independent PSPs on the same terms and conditions. Bell Atlantic responds that its operator services are regulated services and will be offered to affiliated and nonaffiliated PSPs on a nondiscriminatory basis. Bell Atlantic does not plan to "resell" operator services as a deregulated service for either inmate services or payphone services in general. Bell Atlantic represents that, as a carrier and operator service provider, it will bear the same responsibility as other carriers to provide appropriate per call compensation for calls originating from independent provider payphones. 73. Operator services are regulated services. Because Bell Atlantic must offer such services to affiliated and nonaffiliated PSPs on a nondiscriminatory, tariffed basis, Bell Atlantic's CEI plan is not deficient because it does not address whether Bell Atlantic considers operator services to be part of its deregulated payphone service. We note that, in the Reconsideration Order, the Commission declined to require LECs to make available, on a nondiscriminatory basis, any commission payments provided to their own payphone divisions in return for the presubscription of operator service traffic to the LEC, because the Commission concluded that the level of 0+ commissions paid pursuant to contract on operator service calls was beyond the scope of section 276 and the Payphone proceeding. We conclude that Bell Atlantic has sufficiently addressed the concerns raised by APCC. 8. Inmate Calling Services Issues 74. The Inmate Calling Service Provider Coalition (ICSPC) raises a number of issues related to Bell Atlantic's provision of inmate calling services (ICS). ICSPC contends that Bell Atlantic should be required to identify the network support and tariffed services it will provide to its ICS operations. ICSPC also argues that Bell Atlantic must disclose whether its regulated operations will provide its ICS operations with inmate call processing and call control functions and information for fraud protection, and the validation of called numbers. ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. According to ICSPC, Bell Atlantic's failure to describe its provision of ICS in detail prevents the Commission from determining whether Bell Atlantic has complied with the requirements of section 276. In addition, ICSPC asserts that Bell Atlantic should be required to disclose whether its payphone operations will be responsible for the cost of ICS calls for which they are unable to collect. 75. ICSPC also asserts that Bell Atlantic must show that any call processing and call control system used for its ICS is being provided on a deregulated basis, regardless of whether that system is located at a central office or at a customer premises. According to ICSPC, to the extent Bell Atlantic's call processing and call control systems dedicated to ICS are located in Bell Atlantic's central offices, Bell Atlantic must provide physical or virtual collocation to other providers. ICSPC also contends that Bell Atlantic must disclose information on interfaces between Bell Atlantic's equipment dedicated to ICS and its regulated network support services, so that other providers can utilize the same interface if they wish. 76. In a subsequent ex parte filing, ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations because collect calling is fundamental to ICS. According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its network-based operator services division for processing and that division assumes the responsibility and risk associated with billing and collecting for those calls, then the BOC is essentially providing ICS as a regulated service and is still subsidizing that service contrary to the prohibition in section 276. 77. In response to ICSPC's arguments, Bell Atlantic contends that its CEI plan defines payphone services as including inmate payphones and specifically identifies the network services that are available to PSPs that provide payphones to correctional institutions. Bell Atlantic disputes ICSPC's characterization of inmate services as more complex and complicated than other payphone services. Bell Atlantic describes its inmate payphones as payphones that permit only automated collect calls through an operator service provider and, in some cases, limited coin calls. Bell Atlantic claims that the equipment used for inmate call restriction, PIN identification, and related security controls are dedicated to specific correctional facilities and has been classified as deregulated CPE. 78. Bell Atlantic also represents that collect calls from inmate facilities will continue to be offerings of Bell Atlantic's operator services and, therefore, the risk and responsibility for performing billing validation, including attendant fraud losses and uncollectibles, remains with Bell Atlantic's operator services, which is the same treatment accorded to all calls that use Bell Atlantic's operator services. Bell Atlantic does not intend to "resell" operator services as a deregulated service. Bell Atlantic represents, however, that its operator services will continue to serve independent payphone providers and Bell Atlantic payphones on a non-discriminatory basis. When a call is handed off from Bell Atlantic pay telephones to Bell Atlantic's operator services, which is a regulated service, the call will be handled as a regulated call, in the same way as any other call handed off to Bell Atlantic's operator services. Bell Atlantic represents that, in most of its inmate facilities, it uses a store and forward technology to transmit the calls by contracting with a third party vendor that processes the calls for both Bell Atlantic and the presubscribed IXC using equipment owned by the vendor. Bell Atlantic claims that the vendor charges fees to both Bell Atlantic and the IXC for its services and delivers the message detail to each for billing purposes. Bell Atlantic notes that these calls are then billed in the same manner and at the same rates as collect calls generally. Bell Atlantic represents that the call processing in these instances is viewed as adjunct to Bell Atlantic's operator services. 79. ICSPC argues that this approach not only conflicts with section 276 and the Payphone Order, but also violates the Commission's Declaratory Ruling on ICS equipment, issued a year ago. ICSPC contends that, to prevent subsidies and discrimination in connection with deregulated inmate calling services, Bell Atlantic must ensure that uncollectibles are directly assigned to regulated and unregulated operations, and that all network services supporting the deregulated ICS operation must be unbundled from the inmate calling service and made generally available under tariff to ICS providers, and purchased for resale by Bell Atlantic's own ICS operation. 80. Section 276 specifically defines payphone service to include the provision of inmate telephone service in correctional institutions. In the Reconsideration Order, we clarified that the requirements of the Payphone Order apply to inmate payphones that were deregulated in an earlier order. Thus, Bell Atlantic is required to reclassify as unregulated assets all of its payphone assets related to its provision of ICS, with the exception of the loops connecting the inmate telephones to the network, the central office "coin service" used to provide the ICS, and the operator service facilities used to support the ICS. In addition, Bell Atlantic is required to offer on a tariffed basis any basic payphone service or network feature used by its payphone operations to provide ICS. 81. We conclude that Bell Atlantic's CEI plan comports with our CEI requirements with respect to its provision of ICS. Bell Atlantic avers that it will treat as deregulated all of its payphone equipment, including that used for ICS, and that the underlying network services used to interconnect Bell Atlantic's ICS are available on a tariffed basis to all PSPs under the same terms, prices, and conditions. Additionally, Bell Atlantic will purchase the newly-tariffed Inmate NCL service to provide its inmate calling services. Although we agree with ICSPC that any call processing and call control equipment related to Bell Atlantic's provision of ICS must be reclassified as nonregulated, regardless of whether that equipment is located at a customer premises or a Bell Atlantic central office, it appears that Bell Atlantic has done so. We find no support in the Payphone Order or Reconsideration Order for ICSPC's contention that Bell Atlantic is required to provide collect calling as a nonregulated service when used with inmate payphones. 82. We conclude that the other issues raised by ICSPC related to the provision of ICS either have already been addressed in this Order or are beyond the scope of this proceeding. We find that there is no requirement in the Commission's rules, and ICSPC has cited no authority, that obligates Bell Atlantic to allow the collocation of nonaffiliated providers' call processing and call control equipment in a central office. As previously noted, the issue of the treatment of uncollectibles will be addressed in the review of Bell Atlantic's CAM. Finally, with regard to the disclosure of interface information, we have already concluded that Bell Atlantic's CEI plan comports with the Commission's network information disclosure requirements. 9. Primary Interexchange Carrier (PIC) Selection 83. Oncor asserts that in order for Bell Atlantic's CEI plan to comply with the "spirit" of the Commission's CEI requirements, the plan must address various issues concerning the payphone PIC selection process. AT&T also asserts that Bell Atlantic's CEI plan should describe how Bell Atlantic will ensure that the PIC selection process for payphones will be performed on a nondiscriminatory basis. Bell Atlantic responds that both independent payphone providers and Bell Atlantic will be able to select and control, in the same manner, their "PIC" of a presubscribed interexchange carrier for their payphone lines. 84. We conclude that Bell Atlantic is not required, as part of the CEI process, to demonstrate how it will administer the PIC selection process for payphones. In the Payphone Order, the Commission specified that a BOC's CEI plan must describe how it will conform to the CEI parameters with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. The payphone rulemaking proceeding, however, did not require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as requested by AT&T and Oncor. Therefore, arguments raised by parties regarding Bell Atlantic's role as PIC administrator are beyond the scope of this proceeding. 10. Subscriber-Selected Call-Rating 85. APCC and the Payphone Associations contend that, in order to meet the Commission's CEI requirements, Bell Atlantic must provide a coin line service that allows unaffiliated PSPs both to set their own end user rates for local and intraLATA calls and to establish the length of initial and overtime periods. An example of an initial rate is $0.25 for the first five minutes. An example of an overtime rate is $0.05 for each additional three minute period after the first five minutes. APCC and the Payphone Associations therefore request the Commission to require Bell Atlantic to develop a more flexible rating feature for its coin line service. Likewise, APCC continues, Bell Atlantic should specify how directory assistance (DA) rates are set. In reply, Bell Atlantic maintains that it is not required, under the terms of the Reconsideration Order, to disassemble the NCL line and provide separate calling rating functionalities under state tariff. Further, Bell Atlantic represents that the switch capability to apply different rates for directory assistance and toll calls on a line-by-line basis is not available today. Bell Atlantic notes that the Commission's 120-day process for new BSEs is available and should be used by independent payphone providers that seek to disassemble the basic lines or create new functionalities associated with the NCL line. 86. We find that the Payphone Order did not require the BOCs to provide to independent PSPs an unbundled call rating feature for coin line services. In addition, in its Reconsideration Order, in response to a request that it require access to, inter alia, call rating capabilities, the Commission specifically declined to require this type of unbundling. As previously noted, independent PSPs may seek additional unbundling through the 120-day ONA process. State regulatory commissions also may impose further unbundling requirements. 11. Operator Service Provider (OSP) Selection 87. APCC requests that the Commission require Bell Atlantic to unbundle operator services from its coin line service so that PSPs may select their own operator service provider for intraLATA calls. APCC asserts that, under section 276, PSPs are entitled to select their OSP of choice for intraLATA, including local, operator-assisted calls, and therefore that, to the extent Bell Atlantic does not permit OSP selection for its coin line service, its CEI plan is inconsistent with section 276. In reply, Bell Atlantic represents that when dialing parity is implemented under section 251(b)(3) of the Communications Act, all payphone service providers will be able to use processes similar to those used in the interexchange PIC selection process to choose a presubscribed carrier for intraLATA calls. We find that APCC's request goes beyond the scope of this proceeding, which is limited to determining whether Bell Atlantic's CEI plan complies with the Commission's Computer III CEI requirements. 12. Interim Compensation Scheme 88. Finally, Telco argues that apart from the numerous deficiencies in Bell Atlantic's CEI plan, the Commission should refrain from allowing Bell Atlantic or any BOC to participate in the interim compensation scheme outlined in the Payphone Order. We find this argument is beyond the scope of this CEI proceeding. Moreover, the interim compensation rules were addressed at length in the payphone rulemaking proceeding. 13. Payphone Subsidy 89. The Payphone Associations argue that Bell Atlantic has not provided enough information in its CEI plan to ensure that the subsidy to Bell Atlantic's payphone services is eliminated. Although we recognize that, under the requirements of the payphone rulemaking proceeding, Bell Atlantic must be able to certify that it has complied with the requirement to eliminate any subsidies provided to its payphone operations, we conclude that it is not required to make such a demonstration as part of its CEI plan. 14. Semi-Public Service Issues 90. APCC maintains that to the extent that Bell Atlantic's payphone operation continues to offer a "semi-public-like" payphone service that involves charging location providers for lines and usage on their payphones, Bell Atlantic must disclose how such a service will be supported by its network operations and how charges for the service will be treated on the subscriber's bill. We find these semi-public service issues to be beyond the scope of the CEI review process. V. CONCLUSION 91. We conclude that Bell Atlantic's CEI plan complies with the Computer III requirements. Accordingly, in this Order, we approve Bell Atlantic's CEI plan to offer basic payphone service, as described herein. We also grant Bell Atlantic a waiver of the testing requirement for the provision of its coin line (NCL) service, as described above. VI. ORDERING CLAUSE 92. IT IS HEREBY ORDERED that, pursuant to Sections 1, 4(i) and (j), 201, 202, 203, 205, 218, 222, 276 of the Communications Act of 1934, as amended, 47 U.S.C.  151, 154(i) and (j), 201, 202, 203, 205, 218, 222, and 276 and authority delegated thereunder pursuant to Sections 0.91, 0.291 and 1.3 of the Commission's rules, 47 C.F.R.  0.91, 0.291 and 1.3, Bell Atlantic's Comparably Efficient Interconnection Plan for the Provision of Basic Payphone Service IS APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger, Jr. Deputy Chief, Common Carrier Bureau