WPCB 2 BJZCourier3|jx6X@`7X@HP LaserJet 5SiHPLAS5SI.PRSx  @\"[X@ X-#X\  P6G;ɒP#X01Í ÍX01Í Í#Xj\  P6G;ynXP#2B<KTXKCourierTimes New Roman"i~'^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+999999S9S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNl,,28Default Paragraph Fo V Z"i~'K2^18MSS888S8888SSSSSSSSSS88Jxir{icx{8Aui{x`xoYi{xxxl888SS8JSJSJ8SS..S.SSSS>A.SSxSSJJSJS+SSSSS8SSSSSSSSS.xJxJxJxJxJorJiJiJiJiJ8.8.8.8.{SxSxSxSxS{S{S{S{SxSxJ{SxSxSxS{S`SxIxSxIqIqIrSrS{dgIiSiSgIxSxSxSxSxS{S{S8.SSSS8Sz]SSuSg/gFZBy.X80,ɒX\  P6G;P 7jC:,ynXj\  P6G;XP7nC:,\4  pG;\{,W80,%BZW*f9 xr G;X  L"$&.(*,6024V8@:<R>'PHBDFTX!#%'/)+-7135W9A;=S?QICEGUYK X- X   ( X-w  #XP\  P6QynXP#Federal Communications Commission`(#DA 97791 ă  yxdddy (Պ#Xj\  P6G;ynXP#+2 Before the w Federal Communications Commission  X-Washington, D.C. 20554 ă xR#XP\  P6QynXP#) In the Matter of R) R) Bell Atlantic Telephone Companies'R) Comparably Efficient InterconnectionR) Plan for the Provision of Basic PayphoneR) ServicesR) R)  X -Implementation of the Pay TelephoneR)hCC Docket No. 96128 Reclassification and CompensationR) Provisions of the TelecommunicationsR) Act of 1996R)  Xb-9c ORDER T TP  X- Adopted: April 15, 1997hh@h Released: April 15, 1997 By the Deputy Chief, Common Carrier Bureau:  X|-  TABLE OF CONTENTS ă  Xe-  כ`(#"Paragraphă    XxPI. INTRODUCTION p>"(#L 1 XxPII. BACKGROUND p>"(#L 3 XxPIII. SERVICE DESCRIPTION p>"(#L 6 XxPIV. COMPLIANCE ISSUES p>"(#L 8  X"-XxX` ` xA.` ` CEI Plan Requirements ` p>"(#L 8  X#-XxX` ` xB.` ` Other Nonstructural Safeguards ` p"(#I 49  Xh$-XxX` ` xC.` ` Accounting Safeguards ` p"(#I 60  XQ%-XxX` ` xD.` ` Other Issues ` p"(#I 61 XxPV. CONCLUSION p"(#I 91 XxPVI. ORDERING CLAUSE p"(#I 92"(,))ZZ'"Ԍ X-ԛ MI. INTRODUCTION ă  X-  X-x1.` ` On January 6, 1997, pursuant to the requirements of the Commission's orders  X-in the payphone rulemaking proceeding, yO4-ԍXxImplementation of the Pay Telephone Reclassification and Compensation Provisions of the  yO-Telecommunications Act of 1996, CC Docket No. 96128, Report and Order, FCC 96388 (rel. Sept. 20,  yO-1996) (Payphone Order), appeal docketed sub nom., Illinois Public Telecommunications Assn. v. FCC  yO-and United States, Case No. 961394 (D.C. Cir., filed Oct. 17, 1996), recon., FCC 96439 (rel.  yOT-November 8, 1996) (Reconsideration Order); Order, DA 97678 (Common Carrier Bureau rel. April 4,  yO -1997) (Clarification Order).(# the Bell Atlantic Telephone Companies (Bell  X-Atlantic) filed a comparably efficient interconnection (CEI) plan for basic payphone service.$@ yO -ԍXxBell Atlantic Plan to Offer Comparably Efficient Interconnection to Payphone Service Providers (filed Jan. 6, 1997) (Bell Atlantic CEI Plan). Bell Atlantic filed the Payphone CEI plan on behalf of all of the Bell Atlantic telephone companies, which include Bell Atlantic Delaware, Inc., Bell Atlantic Maryland, Inc., Bell Atlantic New Jersey, Inc., Bell Atlantic Pennsylvania, Inc., Bell Atlantic Virginia, Bell Atlantic Washington, D.C., and Bell Atlantic West Virginia, Inc.(#$ In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an  Xv-initial CEI plan describing how it will comply with the Commission's Computer III v  yO-ԍXxAmendment of Section 64.702 of the Commission's Rules and Regulations, CC Docket No. 85229,  yO-PhaseI, 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987) (Phase I  yO-Reconsideration Order), further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Reconsideration.  yOo-Order), second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further Reconsideration), Phase  yO7-I Order and Phase I Reconsideration Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir. 1990)  yO-(California I); Phase II, 2 FCC Rcd 3072 (1987) (Phase II Order), recon., 3 FCC Rcd 1150 (1988)  yO-(Phase II Reconsideration Order), further recon., 4 FCC Rcd 5927 (1989) (Phase II Further  yO-Reconsideration Order), PhaseII Order vacated, California I, 905 F.2d 1217 (9th Cir. 1990); Computer  yOW-III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA Remand Order), recon., 7 FCC Rcd 909  yO-(1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (California II);  yO-Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier1 Local Exchange  yO-Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order), recon. dismissed in part,  yOw-Order, CC Docket Nos.90623 & 92256, FCC 96222 (rel. May17, 1996); BOC Safeguards Order  yO?-vacated in part and remanded, California v. FCC, 39 F.3d 919 (9th Cir. 1994) (California III), cert.  yO-denied, 115 S.Ct. 1427 (1995) (referred to collectively as the ComputerIII proceeding).(#Ƭ CEI equal access requirements and nonstructural safeguards for the provision of payphone  XH-services.\Hp yOi -ԍXxPayphone Order, at para. 202.(#\ 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  X -own payphone operations to provide payphone services.Y  yO#-ԍXxId. at paras. 146, 20004.(#Y  X -" ,-(-(ZZA "Ԍ X-x2. ` ` The Commission issued a public notice of Bell Atlantic's CEI plan on January  X-8, 1997. yOb-ԍXxPleading Cycle Established for Comments on Comparably Efficient Interconnection Plan for Payphone  yO*-Service Providers, Public Notice, CC Docket No. 96128, DA 9731 (released Jan. 8, 1997).(# On February 7, 1997 seven parties filed comments opposing the plan.  yO-ԍXxComments of the American Public Communications Council on Bell Atlantic Telephone Companies CEI Plan (APCC Comments); Joint Comments and Objections of the Central Atlantic Payphone Association, the New Jersey Payphone Association, the New Jersey Payphone Group and the Atlantic Payphone Association to Bell Atlantic's CEI Plan (Payphone Associations Comments); MCI Telecommunications Corporation Comments (MCI Comments); Comments of Telco Communications Group, Inc., on Bell Atlantic's Comparably Efficient Interconnection Plan (Telco Comments); Comments of Oncor Communications, Inc. (Oncor Comments); Comments of the Inmate Calling Service Providers Coalition on Bell Atlantic's CEI Plan (ICSPC Comments); AT&T's Comments On Bell Atlantic's Comparably Efficient Interconnection Plan (AT&T Comments). APCC filed an erratum to its comments on February 12, 1997.(#Ƙ Bell  X-Atlantic submitted reply comments on February 24, 1997.  yO;-ԍXxBell Atlantic filed an erratum to its reply comments on February 25, 1997.(#ƃ For the reasons discussed below,  X-we approve Bell Atlantic's CEI plan.  X-g II. BACKGROUND ă  X_-x3. ` ` The payphone rulemaking proceeding implemented Section 276 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (1996  X1-Act).M 1H  yO*-ԍXx47 U.S.C.  276. (#M 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  X -service.U  yO^-ԍXx47 U.S.C.  276(b)(1)(C).(#U The 1996 Act provided that such safeguards must, at a minimum, include the  X -nonstructural safeguards adopted in the Computer III proceeding.U h yO-ԍXx47 U.S.C.  276(b)(1)(C).(#U  X-x4. ` ` In the Payphone Order, the Commission determined that the Computer III and  Xy-ONA y yO"#-ԍXxOpen Network Architecture (ONA) See Filing and Review of Open Network Architecture Plans, 4 FCC  yO#-Rcd 1, 207 (1988) (BOC ONA Order), recon., 5 FCC Rcd 3084 (1990) (BOC ONA Reconsideration  yO$-Order); 5 FCC Rcd 3103 (1990) (BOC ONA Amendment Order), erratum, 5 FCC Rcd 4045, pets. for  yOz%-review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 97 (1993) (BOC  yOB&-ONA Amendment Reconsideration Order); 6 FCC Rcd 7646 (1991) (BOC ONA Further Amendment  yO '-Order); 8 FCC Rcd 2606 (1993) (BOC ONA Second Further Amendment Order), pet. for review" ' ,-(-(K'"  yO-denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (collectively referred to as the ONA  yOX-Proceeding).(# nonstructural safeguards would "provide an appropriate regulatory framework to"y  ,-(-(ZZ" ensure that BOCs do not discriminate or crosssubsidize in their provision of payphone  X-service."7   yO-ԍXxPayphone Order, at para. 199. In addition, the Commission adopted accounting safeguards for BOC and  yO-incumbent LEC provision of payphone service on an integrated basis. See Implementation of the  yOJ-Telecommunications Act of 1996: Accounting Safeguards Under the Telecommunications Act of 1996,  yO-CC Docket No. 96150, Report and Order, FCC 96490, para. 100 (rel. Dec. 24, 1996) (Accounting  yO-Safeguards Order).(#7 Accordingly, the Commission required the BOCs to file "CEI plans describing  X-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  X-requirements."x yO-ԍXxPayphone Order at para. 199. In its notice of proposed rulemaking regarding the CPNI and other customer information provisions of the 1996 Act, the Commission concluded that its previously established CPNI requirements would remain in effect, pending the outcome of that rulemaking, to  yOf-extent that they do not conflict with the CPNI provisions of the 1996 Act. See Implementation of the Telecommunications Act of 1996: Telecommunication Carriers' Use of Customer Proprietary Network  yO-Information and Other Customer Information, CC Docket No. 96115, Notice of Proposed Rulemaking,  yO-11 FCC Rcd 12513, 12529 (1996) (CPNI NPRM). (# 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  XH-payphone proceeding.fH yO -ԍXxReconsideration Order, at para. 132. In addition to an approved CEI plan, in order to receive  yO-compensation, the Reconsideration Order requires that "a LEC must be able to certify the following: (1) it has an effective cost accounting manual ("CAM") filing; (2) it has an effective interstate CCL tariff reflecting a reduction for deregulated payphone costs and reflecting additional multiline subscriber line charge ("SLC") revenue; (3) it has effective intrastate tariffs reflecting the removal of charges that recover the costs of payphones and any intrastate subsidies; (4) it has deregulated and reclassified or transferred the value of payphone customer premises equipment ("CPE") and related costs as required in  yO-the [Payphone Order]; (5) it has in effect intrastate tariffs for basic payphone services (for "dumb" and "smart" payphones); and (6) it has in effect intrastate and interstate tariffs for unbundled functionalities  yO-associated with those lines." Id. at para. 131.(#f  X -x5. ` ` The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrumentimplemented 'smart payphones' or 'dumb'  X -payphones that utilize central office coin services,cX  yO.$-ԍXxA "smart" payphone has capabilities programmed into it that perform certain functions, such as rating calls or collecting or returning coins. A "dumb" payphone does not have such capabilities, but must instead rely on central office controls to collect and return coins or perform other functions.(#c or some combination of the two in a" ,-(-(ZZ "  X-manner similar to the LECs."c yOy-ԍXxReconsideration Order, at para. 162.(#c Those tariffs must be filed with the applicable state regulatory  X-commission.TX yO-ԍXxId., at para. 16263.(#T 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  X-service or offered by the BOC to unaffiliated PSPs on an unbundled basis. yOT-ԍXxPayphone Order, at para. 146148; Reconsideration Order, at paras. 162163; Clarification Order, at para. 8.(#Ʒ  X- III. SERVICE DESCRIPTION ă  X_-x6. ` ` 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  X1-Controlled Lines (SCL).1@ yO"-ԍXxLetter from Marie Breslin, Director FCC Relations, to William Caton, Acting Secretary, Federal  yO-Communications Commission (March 19, 1997), Attachment 2 at 1 (Bell Atlantic Mar. 19th Ex Parte).(# Network Controlled Lines are used in conjunction with socalled  X -"dumb" payphones.B  yOc-ԍXxId.(#B Station Controlled Lines are used in conjunction with socalled "smart"  X -payphones.B (  yO-ԍXxId.(#B Bell Atlantic represents that the several NCL services described below are the only payphonerelated network services that it uses in conjunction with its own payphone  X -operations.B  yO>-ԍXxId.(#B Bell Atlantic also avers that the SCL and optional features available with that  X -service have been offered under state tariff for many years to independent PSPs.B H  yO-ԍXxId.(#B Bell Atlantic offers six different types of NCL services:  X-  Xy-Xx© TwoWay 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 TwoWay Coin NCL allows 7 or 10 digit calling, 1+ toll dialing, and access to operator services through 0+, 0, 00, 01+, 011+ and 10XXX0 dialing. Billed number screening, which prevents the billing of third number and collect charges to the payphone line number, is included with TwoWay NCL service, and call blocking, which includes the blocking of directly dialed calls to paypercall numbers (e.g., 900",-(-(ZZ" or 700 numbers), "L  may be included with the TwoWay Coin NCL service at no  X-additional charge.J yOb-ԍXxId. at 12.(#J(#  X-Xx© OneWay Coin NCL. This service provides all of the features and functionalities  X-included in the TwoWay Coin NCL, except the capability to receive incoming calls.HX yO-ԍXxId. at 2.(#H(#  Xx-Xx© TwoWay Coinless NCL. This service provides network access and operation of coinless payphones, including card reader or credit card phones. Twoway coinless NCL service blocks chargeable (i.e., sentpaid) 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, 1800). 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  X -number.B  yOD-ԍXxId.(#B(#  X}-Xx© OneWay Coinless NCL. This service provides all of the features and functionalities included in the TwoWay Coinless NCL, except the capability to receive incoming  XQ-calls.BQx yOz-ԍXxId.(#B(#  X#-Xx© OneWay Inmate NCL. This service provides network access and operation of inmate telephone services at correctional institutions. The oneway 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 oneway inmate coin NCL service is also available as a separate line offering, which enables inmates to also make local coin  X-calls.H yOT!-ԍXxId. at 3.(#H(#  Xm-Xx© TwoWay Inmate NCL. The twoway inmate telephone service permits only directly dialed local or toll calls and 0+, 01+ and 011+ automated calls to the presubscribed"X,-(-(ZZ" intraLATA carrier or interLATA carrier. Incoming calls can also be received on this  X-line.B yOb-ԍXxId.(#B(#  X-x7.` ` 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  Xv-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  XH-collect charges to the line number, is offered as an option with SCL service.BHX yOQ -ԍXxId.(#B The following features are also available in a number of states in Bell Atlantic's region as options for use with SCL service:  X -Xx© Inward and Outward Blocking. Inward blocking prevents all incoming calls on the  X -SCL. Outward blocking restricts outgoing calls to 0+ or 0 operator handled calls.B  yOp-ԍXxId.(#B(#   X -Xx© 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  XO-cannot billed to the SCL line number.B!Ox yOx-ԍXxId.(#B(#  X!-Xx© 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  X-the call.B" yO-ԍXxId.(#B(#  X-Xx© 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  Xm-blocked.H#m yO$-ԍXxId. at 4.(#H(#  X?- IV. COMPLIANCE ISSUES"?( #,-(-(ZZ"Ԍ X-ԙA.xCEI Plan Requirements  X-x8. ` ` The Commission's CEI requirements were originally established in the  X-Computer III proceeding, in which the Commission adopted a regulatory framework to govern  X-the provision of integrated enhanced and basic services by the BOCs.$ yO-ԍXxSee Phase I Order, 104 FCC 2d at 1026, para. 128. Requiring BOCs to file CEI plans was one of the nonstructural safeguards adopted by the Commission, in lieu of structural separation, to prevent cross yO-subsidization and discrimination. As a first step in implementing the Computer III framework, the Commission permitted the BOCs, which remained subject to various structural separation requirements, to offer individual enhanced services on an integrated basis following approval of servicespecific CEI plans. BOCs were required to describe in their CEI plans: (1) the enhanced service or services to be offered; (2)how the underlying basic services would be made available for use by competing ESPs; and  yO -(3)how the BOCs would comply with the other nonstructural safeguards imposed by ComputerIII. See  yO] -Phase I Order, 104 FCC 2d at 103459, paras. 142200.(# 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  X_-own payphone services.o%_ yO-ԍXxSee Payphone Order, at paras. 146, 20004.(#o%# BOCs must also provide payphone services to independent payphone providers on a nondiscriminatory basis as required in the payphone rulemaking  X1-proceeding.g$1(  yO -ԍXxReconsideration Order, at paras. 16365.(#g The Commission, in its Computer III proceeding, established nine specific CEI  X -requirements,v%  yO-ԍXxPhase I Order, 104 FCC 2d at 10391043, paras. 154166.(#v 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.  X -x 1.` ` Unbundling of Basic Services  X-x9.` ` The Payphone Order deregulated LEC payphones and classified those  Xy-payphones as customer premises equipment (CPE).\&yH  yOr-ԍXxPayphone Order, at para. 142.(#\ 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  X4-tariff unbundled payphone features that the LEC uses or provides on an unbundled basis.'4 yO"-ԍXxPayphone Order, at para. 146148. Reconsideration Order, at para. 162163, 165; Clarification Order, at para. 8.(#Ƽ Moreover, BOCs, but not other LECs, must unbundle additional network elements when"0',-(-(ZZ)" required by a state or requested by payphone providers based on the specific criteria  X-established in the Computer III and ONA proceedings.( yOb-ԍXxPayphone Order. at 148; Reconsideration Order at para. 165.(#ƀ  X-x 10.` ` The Payphone Order requires BOCs to file CEI plans that explain how they  X-will unbundle basic payphone services.\)X yO-ԍXxPayphone Order, at para. 204.(#\ 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  Xv-service functions that underlie its provision of payphone service.*v yO -ԍXxId. (citing Phase I Order, 104 FCC 2d at 1040); see also Reconsideration Order, at para. 213.(#ƨ Nonproprietary information used by the BOC in providing the unbundled basic services must be made  XH-available as part of CEI.+Hx yOq-ԍXxPayphone Order, at para. 204 (citing Phase I Order, 104 FCC 2d at 1040).(#ƍ In addition, any options available to a BOC in the provision of  X1-such basic services or functions must be included in the unbundled offerings.,1 yO-ԍXxId. See also, Reconsideration Order at para. 213 (citing Phase I Order at 1040, para. 158).(#Ƴ  X -x 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'  X -payphones.N-X  yO-ԍXxBell Atlantic CEI Plan at 5; Bell Atlantic Mar. 19th Ex Parte, Attachment 2. For purposes of this order, SCL service will also be referred to as "customer owned, coin operated telephone" or "COCOT" service and NCL service will also be referred to as "coin line" service.(#N 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  Xy-and return coin deposits.U.y  yO-ԍXxBell Atlantic CEI Plan at 5.(#U In contrast, Bell Atlantic will offer certain optional features on an  Xb-unbundled basis in conjunction with its SCL service.v/bH  yO[-ԍXxBell Atlantic Mar. 19th Ex Parte, Attachment 2 at 34. (#v  X4-x 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  X-are available to Bell Atlantic's payphone operations.W0 yO$-ԍXxBell Atlantic CEI Plan at 45.(#W In addition, Bell Atlantic represents that it will respond to additional requests from independent payphone providers for unbundled basic services through the existing 120day ONA process and will make those service" h0,-(-(ZZ&" available where such requests comply with the factors established by the Commission for  X-selection of initial ONA services.1X yOb-ԍXxId. at 5. The ONA factors are market demand, utility as perceived by the independent payphone  yO*-providers, and technical feasibility. See In the Matter of Filing and Review of Open Network  yO-Architecture Plans, Memorandum Opinion and Order, 4 FCC Rcd. 1, 207 para. 396 (1988).(#ƅhh  X-x 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  X-payphone access line.u2 yO& -ԍXxAPCC Comments at 6; Payphone Associations Comments at 2728.(#u 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  X_-functions that are provided as part of its basic payphone service offerings.N3_x yO -ԍXxAPCC Comments at 67.(#N 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  X -according to cost.i4  yO-ԍXxId.; Payphone Associations Comments at 28.(#i 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  X -additional features bundled with the line, such as answer supervision and call screening.r5  yO5-ԍXxAPCC Comments at 6; Payphone Associations Comments at 28.(#r Moreover, APCC argues that Bell Atlantic should price these additional features at the same  X -rate whether they are used with COCOT or coin lines.M6 (  yO-ԍXxAPCC Comments at 11.(#M The Payphone Associations further  X -contend that Bell Atlantic's claims of technical infeasibility should be rejected.^7  yO-ԍXxPayphone Associations Comments at 28.(#^ 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  Xb-service is if they discontinue their use of smart payphones.a8bH  yO[-ԍXxPayphone Associations Comments at 2427.(#a 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  X-uses on an unbundled basis.R9 yO#-ԍXxBell Atlantic Reply at 2.(#R  X-x 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" h9,-(-(ZZ"  X-either "smart" or "dumb" payphones or to offer inmate calling service.\: yOy-ԍXxPayphone Order, at para. 146.(#\ 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  X-or to their own payphone operations.c;X yO-ԍXxReconsideration Order, at para. 146.(#c Bell Atlantic's plan, as supplemented, satisfies these requirements. We note, however, that Bell Atlantic may choose to unbundle additional payphonespecific features and functions, states may require further unbundling, or independent PSPs may request additional unbundled features and functions through the ONA  X_-120day service request process.f<_ yO -ԍXxClarification Order, at para. 8, n. 23.(#f Any other features and functions provided by Bell Atlantic on an unbundled basis must comply with the tariffing and CEI requirements of the payphone  X1-proceeding, Computer III and ONA.  X -x15. ` ` 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.  X -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  X -provides on an unbundled basis."= x yO-ԍXxClarification Order, at para. 16 (citing Payphone Order at para. 148; Reconsideration Order, at para. 165).(#ƶ 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  X4-feature in both the state and federal jurisdictions.2> 4 yO-ԍXxClarification Order, at para. 16. That Order clarified that the unbundled features and functions addressed in the payphone rulemaking proceeding are network services similar to basic service elements ("BSEs") under the ONA regulatory framework. BSEs are defined as optional unbundled features that  yO -an enhanced service provider may require or find useful in configuring its enhanced service. Id. at para.  yO-17 (citing Filing and Review of Open Network Architecture Plans, Phase I, Memorandum Opinion and  yO-Order, FCC 88381, 4 FCC Rcd 1 (1988) ("BOC ONA Order")). In this case, the unbundled features are payphonespecific, networkbased features and functions used in configuring unregulated payphone operations provided by PSPs or LECs. Some of the LECs use terms such as tariffed "options" and "elective features" to refer to network services that other LECs call features and functions. The  yO"-Clarification Order concluded that "[o]ptions and elective features must be federally tariffed in the same circumstances as features and functions must be federally tariffed, depending on whether they are provided on a bundled basis with the basic network payphone line (state tariff), or separately on an  yO%-unbundled basis (federal and state tariffs)." Id. (citing Application of Open Network and  yO%-Nondiscrimination Safeguards to GTE Corporation, 11 FCC Rcd 5558 (1995)). (#2 Because Bell Atlantic offers, and will use, NCL service on a bundled basis, Bell Atlantic is not obligated to unbundle the individual" >,-(-(ZZ " 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  X-offers to payphone providers that subscribe to its SCL service.? yOK-ԍXxLetter from Marie Breslin, Director FCC Relations, to William Caton, Acting Secretary, Federal  yO-Communications Commission (dated April 10, 1997) (Bell Atlantic Apr. 10th Ex Parte).(# No further unbundling is  X-required at this time.`@  yO-ԍXxPayphone Order, at paras. 14648.(#` Independent PSPs may seek further unbundling of Bell Atlantic's  X-NCL service by making a request pursuant to the ONA process.A yO -ԍXxPayphone Order at para. 148; Reconsideration Order at para. 165.(#ƅ  Xv- x2.` ` Interface Functionality  XH-x16.` ` The interface functionality requirement obligates the BOC to make available standardized hardware and software interfaces that are able to support transmission, switching,  X -and signaling functions identical to those used by the BOC's payphone service.B @ yO -ЍXxPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1039, para. 157.(#Ɲ  X -x17.` ` Bell Atlantic claims that all PSPs may connect their payphone customer premises equipment ("CPE") to Bell Atlantic's basic network through standard, publicly  X -disclosed network interfaces.UC  yO?-ԍXxBell Atlantic CEI Plan at 6.(#U Bell Atlantic notes that the technical specifications for these interfaces were identified in August 1996 in Bell Atlantic's Network Disclosure Statement for  X-payphones, which was published in the Bellcore Digest.D`  yO-ԍXxId.; see also Letter from Marie Breslin Director, FCC Relations, to William Caton, Acting Secretary,  yOi-Federal Communications Commission (Mar. 31, 1997) (Bell Atlantic Mar. 31st Ex Parte).(# 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  XK-services.BEK  yO-ԍXxId.(#B As required by the Commission's Network Disclosure requirements, Bell Atlantic  X4-also commits to disclosing any new interface in advance of its introduction.BF4H  yO-!-ԍXxId.(#B  X-x18.` ` 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" F,-(-(ZZ" connect to network interfaces." Telco also faults Bell Atlantic for providing no description of  X-the interfaces.DG yOb-ԍXxTelco at 2.(#D  X-x19.` ` 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  X1-Atlantic states that it has filed, as discussed below,_H1X yO: -ԍXxSee infra Section III.B.2.(#_ 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.  X -x 3.` ` Resale  X -x20.` ` 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 costshifting to regulated  Xb-operations and anticompetitive pricing in unregulated markets."lIb yO-ԍXxPhase I Order, 104 FCC 2d at 1040, para. 159.(#l Based on the requirement in  XK-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  X-on a nondiscriminatory basis to other payphone providers.Jx yOF-ԍXxPayphone Order, at para. 200; Reconsideration Order, at para. 211.(#Ƈ  X-x21.` ` 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  X-on an unregulated, detariffed basis."MK yOz-ԍxBell Atlantic CEI Plan at 6.M 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  Xe-mechanisms will exist to enable competitors to ensure that resale obligations are being met."ELe yO$-ԍxTelco Comments at 3.E 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"7 ( L,-(-(ZZ" 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, factbased claims should be addressed in federal or state tariff proceedings or formal complaint actions against Bell Atlantic.  XH-x 4.` ` Technical Characteristics  X -x22.` ` 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  X -payphone services.M  yOe -ԍXxPayphone Order, at paras. 199207; Reconsideration Order, at 218220; and Phase I Order, 104 FCC 2d at 1041, para. 160.(#  X -x23.` ` 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  Xy-published interfaces.MNy  yOJ-ԍxBell Atlantic CEI Plan at 6.M 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  X4-whether there will be any discrimination between affiliated and unaffiliated PSPs.EO4 yO-ԍxTelco Comments at 2.E 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.  X|-x 5.` ` Installation, Maintenance, and Repair  XN-x24.` ` The Payphone Order requires BOCs to describe in their CEI plans how they  X7-will comply with the nondiscrimination requirements in Computer III and ONA regarding the  X -quality of service, installation, and maintenance.[P @ yO%-ԍXxPayphone Order at para. 207.(#[ 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"P,-(-(ZZZ"  X-affiliated payphone service operations.Q yOy-ЍxId. at para. 203; Phase I Order, 104 FCC 2d at 1041, para. 161. BOCs also must satisfy reporting and other  X-requirements showing that they have met this requirement.R X yO-ԍXxId. Bell Atlantic must provide quarterly reports on installation and maintenance of its basic services.  yO-Id. at 10551056, paras. 192193. The Payphone Order does not impose any new continuing reporting  yO-requirement because BOCs are already subject to reporting requirements pursuant to Computer III and  yOJ-ONA. BOCs must report on payphone services as they do for basic services.(#  X-x25.` ` 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.  X -x26.` ` 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  X -unaffiliated PSPs.ZS @ yO-ԍxAPCC Comments at 15; Telco Comments at 3.Z 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  Xb-change of ownership of the location provider is involved.MTb yO-ԍXxAPCC Comments at 16.(#M 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  X-preferences.IU`  yO.-ԍXxId. at 17.(#I 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  X-Atlantic's payphones are replaced by payphones operated by an unaffiliated PSP.MV  yO!-ԍXxAPCC Comments at 17.(#M  X-x27.` ` 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" V,-(-(ZZo"  X-discrimination in the provision of installation, maintenance and repair.PW yOy-ԍXxAPCC Comments at 1718.(#P Finally, APCC argues that Bell Atlantic should identify for its payphone offerings the demarcation point  X-between the switched network and a payphone provider's inside wire.MXX yO-ԍXxAPCC Comments at 16.(#M  X-x28.` ` 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  Xv-nondiscriminatory basis to both nonaffiliated and affiliated PSPs.RYv yO -ԍXxBell Atlantic Reply at 9.(#R In support, Bell Atlantic submits its IPP Information Booklet which describes its procedures for handling orders for  XH-provisioning and repair of network services and the expected service intervals.SZXHx yOq-ԍXxId. Bell Atlantic notes that it is in the process of updating this booklet to include its newly tariffed payphone services as well as other relevant information in light of the orders released in the  yO-Commission's payphone rulemaking proceeding. Id.(#S Bell Atlantic further represents that technical support for installation and maintenance of network services  X -will be provided on a nondiscriminatory basis.I[  yOc-ԍXxId. at 10.(#I According to Bell Atlantic, the same technicians, monitoring systems and testing systems will be used without regard to the  X -affiliation of the PSP.B\ (  yO-ԍXxId.(#B Bell Atlantic affirms that orders, preferred request dates and repair reports will be handled on a firstcome, firstserved 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  X-of a code word or direct confirmation.B]  yO-ԍXxId.(#B With respect to personnel sharing issues, Bell Atlantic avers that only those personnel processing or completing service orders placed by  Xb-independent PSPs will have access to those accounts.B^bH  yO[-ԍXxId.(#B Bell Atlantic asserts that it maintains password restrictions os that other marketing personnel will not have access to this  X4-information.B_4 yO"-ԍXxId.(#B  X-x29.` ` Bell Atlantic claims that its IPP Information Booklet also contains information  X-concerning the demarcation point at payphone premises.B`h yO'-ԍXxId.(#B Bell Atlantic represents that its"`,-(-(ZZE" 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  X-payphone rulemaking proceeding for existing grandfathered payphones.Ia yOK-ԍXxId. at 11.(#I 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  X-compliance with the Commission's MPOE standards.bX yO-ԍXxLetter from Marie Breslin Director, FCC Relations, to William Caton, Acting Secretary, Federal  yO^ -Communications Commission (April 11, 1997) (Bell Atlantic Apr. 11th Ex Parte).(# For newly installed payphones, Bell Atlantic represents that it will install a network interface device (NID) that will act as the  X_-demarcation point in conformance with Part 68 of the Commission's rules.Bc_ yO -ԍXxId.(#B 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  X -regulated and deregulated wiring work.^d @ yO-ԍXxId.; Bell Atlantic Reply at 11.(#^ According to Bell Atlantic, although no NID hardware will be physically present, the technicians will still identify the point at which a  X -NID would have been placed for a new installation of an affiliated or unaffiliated payphone.`e  yOV-ԍXxBell Atlantic Apr. 11th Ex Parte.(#` Bell Atlantic represents that technicians have received training on these demarcation policies  X -and that only the work performed up to that point will be treated as regulated services.Bf `  yO-ԍXxId.(#B  Xy-x30.` ` 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.  Xe-x31.` ` 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"7 f,-(-(ZZ" 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.  X-In the Payphone Order, the Commission specifically declined to require BOCs to provide  X-payphone CPE through a structurally separated affiliate.\g yO-ԍXxPayphone Order, at para. 145.(#\ We note that the Commission's rules require BOCs to allocate properly the costs, including costs associated with the use of  X_-personnel, between regulated and nonregulated operations.eh_X yOh -ԍXxSee 47 C.F.R.  64.901, 64.903.(#e We also note that, pursuant to section 94.904 of the Commission's rules, LECs that file CAMs are required to have an  X1-independent audit performed annually.Yi1 yO -ԍXxSee 47 C.F.R.  64.904.(#Y  X -x32.` ` We also conclude that Bell Atlantic has sufficiently identified the demarcation point to determine when maintenance becomes the payphone provider's responsibility and is  X -not part of the access network service.Hj x yO-ԍXxId. at 9.(#H 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.  XK- x6.` ` End User Access  X-x 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  X-users equal opportunities to obtain access to basic network facilities.k yO-ԍXxSee Phase I Order, 104 FCC 2d at 1041, para. 162; Payphone Order, at para. 199.(#ƚ  X-x!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  X|-line services in the same manner.Ul| yO#-ԍXxBell Atlantic CEI Plan at 7.(#U 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"e( l,-(-(ZZ1"  X-users of Bell Atlantic payphones.Bm yOy-ԍXxId.(#B We find that Bell Atlantic's CEI plan comports with the end user access requirement established by the Commission.  X- x7.` ` CEI Availability  X-x"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  X1-testing their payphone service offerings.n1X yO: -ԍXxPhase I Order, 104 FCC 2d at 1041, para.163. The testing period is necessary "to balance the conflicting interests of the carrier, which should have a reasonable period to develop, test, and 'debug' its CEI offerings before making them publicly available, and other CEI users, such as competitors, that might suffer an unfair competitive disadvantage if carriers were able to test and perfect their payphone services particularly, their interconnection with the basic underlying facilities while withholding  yO"-those same basic facilities from others." Id.(#ƍ Past decisions also have referred to this as the 90 X -day notice requirement.o   yO-ԍXxSee e.g., Bell Operating Companies' Joint Petition for Waiver of Computer II Rules, Ameritech's Request for Waiver Related to Minor Amendment to Ameritech's Plan to Provide Comparable Efficient  yO+-Interconnection to Providers of Voice Mail Messaging Service, CCBPol 9623, DA 961894 (rel. Nov.  yO-14, 1996) (Ameritech Minor Amendments).(#  X -x#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  X-others.ip  yO-ԍXxSee Clarification Order, at para. 8.(#i LECs are not required to file tariffs for the basic payphone line for smart and dumb  Xy-payphones with the Commission.hqyH  yOr-ԍXxReconsideration Order, at paras. 162163.(#h As stated in the Clarification Order, LECs are required to file state and federal tariffs for "payphonespecific, networkbased features and functions" that LECs provide "separately and on an unbundled basis from the basic payphone line, either to  X4-[their] own operations or to others."r4 yO"-ԍXxClarification Order, at para. 18; see also Reconsideration Order at para. 163.(#ƙ  X-x$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"hr,-(-(ZZ"  X-Clarification Order.`s yOy-ԍXxClarification Order, at para. 21.(#` In addition, each individual BOC was required to file, by April 10,  X-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  X-date of that Order.OtX yO-ԍXxId. at para. 22.(#O  Xv-x%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  XH-geographical areas served by Bell Atlantic.HuH yO -ԍXxBell Atlantic CEI Plan at 78. Bell Atlantic represents that, at this time, tariffs for the NCL services that its own payphone operations will use are in effect in each state in its region, except for the District of Columbia. Bell Atlantic expects the District of Columbia to approve its tariff on or before April 15, 1997. Letter from Marie Breslin, Director FCC Relations, to William Caton, Acting Secretary, Federal  yO-Communications Commission (April 1, 1997) (Bell Atlantic April 1st Ex Parte)(#H 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  X -available since 1996.Bv  yOL-ԍXxId.(#B Bell Atlantic further represents that it will make testing capability for the new NCL services available to any independent payphone service providers upon  X -request.Hw (  yO-ԍXxId. at 8.(#H Bell Atlantic also filed with its CEI plan illustrative state tariffs for its coin line  X -(NCL) service and for the COCOT (SCL) service.]x  yO'-ԍXxSee Id. at Attachment A.(#]  X-x&39.` ` APCC and the Payphone Associations contend that Bell Atlantic's CEI plan  Xy-must be rejected on the ground that Bell Atlantic did not file federal tariffs.LyyH  yOr-ԍXxAPCC Comments at 5.(#L They contend  Xb-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  X4-is not required is the basic line for "smart" and "dumb" payphones.:z4 yO"-ԍxId.: APCC argues that all  X-basic payphone services and features other than the access line must be federally tariffed.L{h yO6%-ԍXxAPCC Comments at 5.(#L "{,-(-(ZZe" APCC argues that Bell Atlantic's plan must be rejected because it has not filed all required  X-federal tariffs, including tariffs for coin line features.:| yOb-ԍxId.:  X-x'40.` ` In response, Bell Atlantic contends that it is in compliance with the payphone  X-rulemaking proceeding's federal tariffing requirement, as implemented by the Clarification  X-Order.`}X yO-ԍXxBell Atlantic Apr. 10th Ex Parte.(#` In an ex parte filing, Bell Atlantic represents that it will file federal tariffs, in  Xv-accordance with the requirements of the Clarification Order, for the following unbundled features: Line Side Answer Supervision; Inward/Outward Screening; Outward Screening;  XH-Inward Call Blocking; Outward Call Blocking; and Limited InterLATA Dialing.B~H yO -ԍXxId.(#B 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  X -the same tariffed payphone services that are available to independent PSPs.J x yO,-ԍxBell Atlantic Reply at 3.J  X -x(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  X -those areas.E  yO`-ԍxAPCC Comments at ii.E 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  Xy-service.Ly yO-ԍXxAPCC Comments at 4.(#L Further, APCC contends that the CEI plan is incomplete because Bell Atlantic only  Xb-filed an illustrative for one state.Lb(  yO;-ԍXxAPCC Comments at 6.(#L In response, Bell Atlantic claims that it provided citations  XK-for all the payphone line tariffs for all of the states in its CEI plan.RK  yO-ԍXxBell Atlantic Reply at 7.(#R Bell Atlantic also attached each of its state tariffs to its Reply.  X-x)42.` ` We find that Bell Atlantic's CEI plan complies with the CEI availability  X-requirement. H  yO#-ԍXxWe note that our conclusion that Bell Atlantic's CEI plan complies with the CEI availability requirement, and therefore our approval of its CEI plan, is contingent on the effectiveness of Bell Atlantic's state tariffs for payphone services. As noted above, Bell Atlantic represents that its new tariffs for payphone services were effective in each of the states in its region by April 1, 1997, except in the District of Columbia where it expects its new tariffs for payphone services to be effective by April"',-(-(?'" 15, 1997. We note further that, because we are relying on the state regulatory commissions to review LEC tariffs for basic payphone lines, our conclusion that Bell Atlantic has satisfied the CEI availability requirement does not represent a determination that Bell Atlantic's basic payphone lines are tariffed in accordance with the requirements of Section 276. (# We reject APCC's argument that Bell Atlantic must file a federal tariff for all",-(-(ZZ'" payphone service features and functions except for the basic access line for COCOT and coin  X-line services. As stated in the Clarification Order, BOCs need only submit federal tariffs for payphonespecific, networkbased 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  X-to others.` yO -ԍXxClarification Order, at para. 18.(#` 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  X -illustrative tariffs are sufficient.EX @ yO -ԍXxSee Phase I Order, at 1055, para. 190 ("The CEI Plan must also include sample state and federal tariffs for the Basic Interconnection Charge and the distancesensitive transmission charges that satisfy our CEI pricing requirements") (emphasis added).(#E  X -x*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  Xy-geographical areas served by Bell Atlantic."Uy`  yO-ԍXxBell Atlantic CEI Plan at 7.(#U 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  X4-operations."`4  yO-ԍXxBell Atlantic Apr. 11th Ex Parte.(#` 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.  X-x+44. ` ` Finally, we waive on our motion the 90day 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"e ,-(-(ZZ" 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  X1-Bell Atlantic.V1 yO -ԍXxBell Atlantic CEI Plan at 10.(#V  X - x8.` ` Minimization of Transport Costs  X -x,45.` ` This requirement obligates carriers to provide competitors with interconnection  X -facilities that minimize transport costs. X yO-ԍXxPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.164.(#Ɠ  X-x-46.` ` Bell Atlantic asserts that the Commission has found this requirement satisfied in the enhanced services context if affiliated and unaffiliated enhanced service providers  Xb-(ESPs) are charged the same rates for underlying basic services.b yO-ԍXxBell Atlantic CEI Plan at 9 (citing Phase II Reconsideration Order, 3 FCC Rcd at 1155, paras. 3234).(#Ƥ Bell Atlantic asserts that it will charge affiliated and nonaffiliated PSPs the same tariffed rates for basic payphone  X4-services.B4x yO]-ԍXxId.(#B We find that Bell Atlantic's CEI plan complies with the minimization of transport costs requirement.  X-x 9.` ` Recipients of CEI  X-x.47.` ` This requirement prohibits a BOC from restricting the availability of its CEI  X-offering to any particular class of customer or PSP. yOc -ԍXxPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.165.(#Ɠ   X|-x/48.` ` Bell Atlantic avers that access to all basic network exchange services will be available, either under existing or newlyfiled tariffs, to both affiliated and nonaffiliated PSPs by April 1997 in all central offices where such services are provided by Bell Atlantic to its  X7-own payphone operations.u7 yO&-ԍxBell Atlantic CEI Plan at 7; Bell Atlantic Apr. 11th Ex Parte.u Bell Atlantic also represents that it will make CEI testing for the"7( ,-(-(ZZ"  X-newlytariffed dumb payphone lines available to any nonaffiliated PSPs that request it.@ yOy-ԍxId. at 8.@ We find that Bell Atlantic has proposed to provide service to CEI recipients in compliance with the Commission's requirements.  X- B.xOther Nonstructural Safeguards  X-  Xv-x049. ` ` In addition to the CEI requirements established in Computer III, and applied to  X_-BOC provision of payphone services in the Payphone Order,_X yOh -ԍXxPayphone Order, at para. 202. See also Reconsideration Order, at para. 210.(#Ɲ a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network  X1-information (CPNI), disclosure of network information, and nondiscrimination reporting.o1 yO -ԍXxPhase II Order, 2 FCC Rcd at 3082, paras.7375.(#o  X -x 1.` ` Customer Proprietary Network Information  X -x150. ` ` The Payphone Order requires Bell Atlantic to explain how it will comply with  X -the ComputerIII CPNI safeguards,v x yO-ԍXxSee Phase II Order, 2 FCC Rcd at 3095, para.156.(#v to the extent they are not inconsistent with section 222  X -of the Communications Act of 1934, as amended.  yO`-ԍXxPayphone Order, at para. 205 (citing 47 U.S.C.  222, and the CPNI NPRM).(#Ƒ 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  Xb-carrier's obligations under this provision.^b yO-ԍXxCPNI NPRM, 11 FCC Rcd at 12514.(#^ The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent  X4-they do not conflict with section 222.4(  yO -ԍXxId. at 12515 (noting that, to the extent that the 1996 Act requires more of a carrier, or imposes greater restrictions on a carrier's use of CPNI, the statute governs).(#  X-x251. ` ` In its payphone CEI plan, Bell Atlantic avers that it will comply with Section  X-222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding.V  yO #-ԍXxBell Atlantic CEI Plan at 10.(#V Bell Atlantic also represents that password restricted access will prevent the sales and",-(-(ZZ" marketing personnel of the affiliated PSP from accessing any CPNI of unaffiliated PSPs or  X-others.D yOb-ԍXxId. (#D  X-x352. ` ` APCC and Telco claim that Bell Atlantic's payphone CEI plan does not offer  X-sufficient information concerning how Bell Atlantic will comply with CPNI requirements.eX yO-ԍXxAPCC Comments at 2325; Telco Comments at 3.(#e 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,  X_-including current customers of semipublic payphone service.HX_ yO -ԍXxAPCC Comments at 23. See also Letter from Michael S. Wroblewski, on behalf of Peoples Telephone Company, Inc., to William Caton, Acting Secretary, Federal Communications Commission (March 5,  yO -1997) (Peoples's March 5 Ex Parte).(#H APCC also argues that, since the existing tariffed semipublic service is being terminated pursuant to section 276, Bell Atlantic's payphone operation has no more right to access and use the CPNI of semipublic  X -service customers than any other PSP.M  yO-ԍXxAPCC Comments at 24.(#M Further, APCC contends that the deregulation of semipublic service presents PSPs with a potential marketing opportunity to replace Bell Atlantic as the payphone service provider for these customers. APCC argues that semipublic 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  Xy-without preference to Bell Atlantic's payphone operations.Ly yO-ԍXxId. at 2425.(#L  XK-x453. ` ` Bell Atlantic confirms that usage on semipublic payphone lines will be available to the PSP purchasing the underlying access line on the same basis such information  X-is available for the NCL service and SCL service generally.S(  yO-ԍXxBell Atlantic Reply at 12.(#S 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 semipublic customers  X-is mandated.B  yOA#-ԍXxId.(#B Bell Atlantic further claims that information concerning Bell Atlantic's semipublic payphones customers will remain proprietary customer account information and that no"H ,-(-(ZZ" statutory provision or Commission rule prohibits Bell Atlantic from using its own CPNI to  X-market and supply an existing service just because the service has been deregulated.I yOb-ԍXxId. at 13.(#I  X-x554. ` ` In providing payphone services, Bell Atlantic must comply with the  X-Commission's preexisting 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 semipublic 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  X -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 semipublic payphone service, because no  X-such requirement was adopted in the Payphone Order or in the Reconsideration Order, or is otherwise required by our CEI rules.  XK- x2.` ` Network Information Disclosure (#`  X-x655.` ` The Payphone Order requires Bell Atlantic to disclose to the payphone services industry information about network changes and new network services that affect the  X-interconnection of payphone services with the network.[X yO-ԍXxPayphone Order, at para. 206(#[ 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  X-interface through which a PSP interconnects with Bell Atlantic's public switched network.l yOC-ԍXxPhase II Order, 2 FCC Rcd at 3086, para. 102.(#l 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  Xe-agreement.`ex yO!-ԍXxId. at 30913093, paras. 134140.(#` Bell Atlantic also must publicly disclose technical information about a new or  XN-modified network service twelve months prior to the introduction of that service.t N yO$-ԍXxId. at 3092, para. 136. We note that, under the Commission's rules, if a BOC is able to introduce the service within twelve months of the make/buy point, however, it may make public disclosure at the make/buy point. It may not, however, introduce the service earlier than six months after public disclosure.(#t "7 ,-(-(ZZ"Ԍ X-x756.` ` 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  X-requirements of that order.[ yO4-ԍXxPayphone Order at para. 146.(#[ 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,  X-1997.LX yO-ԍXxSee id.(#L  X_-x857.` ` Bell Atlantic represents that all PSPs may connect their payphone CPE to Bell  XH-Atlantic's basic network through standard, publicly disclosed network interfaces.UH yO -ԍXxBell Atlantic CEI Plan at 6.(#U Bell Atlantic commits to disclosing any new services or network changes that affect the  X -interoperability of payphone services with the network.V x yOC-ԍXxBell Atlantic CEI Plan at 10.(#V As described above, consistent with  X -the requirements of the Payphone Order, Bell Atlantic made the necessary network disclosure  X -for its new network interface in August 1996.a  yO-ԍXxBell Atlantic March 31st Ex Parte.(#a We therefore find that Bell Atlantic's CEI plan comports with the Commission's network information disclosure requirements.  X -x 3.` ` Nondiscrimination Reporting  Xy-x958.` ` In the Payphone Order, the Commission directed the BOCs to comply with the  Xb-Computer III and ONA requirements regarding nondiscrimination in the quality of service,  XK-installation, and maintenance.SK yO-ԍxPayphone Order at para. 207.S Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semiannual 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  X-covered service offerings, installation and maintenance.*(  yO -ԍxSee Payphone Order at para. 207; BOC ONA Reconsideration Order, 5 FCC Rcd 3084, 3096, Appendix  yO!-B (1990), BOC ONA Amendment Order, 5 FCC Rcd 3103 (1990), Erratum, 5 FCC Rcd 4045, pets. for review  yOX"-denied, California II, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 7646 (1991), BOC ONA Second Further  yO #-Amendment Order, 8 FCC Rcd 2606 (1993), pet. for review denied, California II, 4 F.3d 1505 (9th Cir. 1993);  yO#-Phase II Order, 2 FCC Rcd at 3082, para.73; and Filing and Review of Open Network Architecture Plans, CC Docket No. 882, Memorandum Opinion and Order, Phase I, 6 FCC Rcd 7646, 764950 (1991).* ",-(-(ZZ"Ԍ X-x:59.` ` Bell Atlantic represents that it will continue to comply with all existing Commission orders and any future Commission orders related to nondiscrimination  X-reporting.V yOK-ԍXxBell Atlantic CEI Plan at 10.(#V Bell Atlantic commits to modifying its quarterly Installation and Maintenance  X-Nondiscrmination Reports filed pursuant to ONA requirements to include performance data for the basic network services provided to unaffiliated and affiliated payphone service  X-providers.`X yO-ԍXxBell Atlantic Apr. 11th Ex Parte.(#` Bell Atlantic also commits to include payphone related information in its annual  Xv-filing of the ONA Nondiscrimination Maintenance Report.Bv yO -ԍXxId.(#B We find that Bell Atlantic's CEI plan comports with the Commission's nondiscrimination reporting requirements.  X1- C.xAccounting Safeguards  X -x;60.` ` In the Payphone Order and the Accounting Safeguards Order, the Commission  X -concluded that it should apply accounting safeguards identical to those adopted in Computer  X -III to BOCs providing payphone service on an integrated basis. x yO-ԍXxPayphone Order at paras. 157, 199, 201; Accounting Safeguards Order, at para. 100.(#Ɨ 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  X-analyze the data; and 5) the performance of onsite audits by Commission staff.q yO-ԍXxBOC Safeguards Order, 6 FCC Rcd at 7591, para. 46.(#q Bell  X-Atlantic must comply with these accounting safeguards.X yO! -ԍXxWe note that Bell Atlantic represents that joint and common costs will be allocated pursuant to Bell Atlantic's Cost Allocation Manual (CAM) and that it will file CAM changes to cover the accounting of  yO!-unregulated payphone service costs, pursuant to the Payphone Order. Bell Atlantic CEI Plan at 89.(#ƀ 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.  X|- D.xOther Issues  XN-x 1.` ` Sufficiency "N ,-(-(ZZ"Ԍ X-ԙx<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  X-its plan. yO4-ԍXxAPCC Comments at 12, Telco Comments at 23, Payphone Associations Comments at 48.(#ƌ As discussed above, we find that Bell Atlantic adequately complies with each of the CEI requirements.  Xv-Xx 2.X` ` Tariffing Issues (#`  XH-x=62. ` ` APCC and the Payphone Associations raise various objections to the content of  X1-Bell Atlantic's state tariffs.1X yO: -ԍXxSee APCC Comments at 811; Payphone Associations Comments at 1323.(#Ƃ 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  X -subsidized by regulated services.  yOn-ԍXxAPCC Comments at 711; Payphone Associations Comments at 1523 (The Payphone Associations focus their comments on the payphone tariffs that Bell Atlantic filed in Pennsylvania and New Jersey).(# 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  Xy-same features must be purchased separately from the COCOT service.ty@ yOj-ԍXxAPCC Comments at 79; Payphone Associations Comments 1620.(#t Similarly, the Payphone Associations claim that the COCOT rates tariffed by Bell Atlantic in New Jersey  XK-are exorbitant and cannot be reasonably claimed to be costbased.^K yO-ԍXxPayphone Associations Comments at 21.(#^ Bell Atlantic responds that complaints about the adequacy of the rates or other aspects of its state tariffs should be  X-raised in state tariff proceedings, not in this CEI proceeding.[`  yO.-ԍxBell Atlantic Reply at 7.` (#[ It argues that the Commission  X-has delegated to the states the responsibility for reviewing Bell Atlantic's coin line tariffs.B  yO -ԍXxId.(#B  X-x>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  X-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" ,-(-(ZZ"  X-the requirements of section 276."c yOy-ԍXxReconsideration Order, at para. 163.(#c 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)  X-nondiscriminatory.X yO-ԍXxReconsideration Order, at para. 163; see also id. at n.492 (noting that the "new services test required in  yO-the Report and Order is described at 47 C.F.R. Section 61.49(g)(2)").(# In addition, the order established that "[s]tates must apply these  X-requirements and the Computer III guidelines for tariffing such intrastate services."B yO -ԍXxId.(#B The order further stated that "[w]here LECs have already filed intrastate tariffs for these services,  Xv-states may, after considering the requirements of this order, the Report and Order, and section  X_-276 conclude: 1) that existing tariffs are consistent with the requirements of the Report and  XH-Order as revised herein; and 2) that in such case no further filings are required."BH@ yO9-ԍXxId.(#B Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs  X -operating in their state to file these tariffs with the Commission."B  yO-ԍXxId.(#B  X - x3.` ` Screening Codes  X -x?64.` ` APCC, AT&T and MCI contend that Bell Atlantic is required, pursuant to the  X -Reconsideration Order, to provide PSPs using COCOT lines (SCL service) screening code  X-digits that uniquely identify their lines as payphone lines.`  yO-ԍXxAPCC Comments at 1921; AT&T Comments at 2; MCI Comments at 12. Screening code digits allow interexchange carriers (IXCs) to track payphone calls for the purpose of paying percall compensation to LECs. As APCC states, "with a unique screening code, the IXC knows immediately that a call is compensable, and should not have to take any further steps in order to calculate the compensation due for each particular ANI invoiced by an [independent PSP]." APCC Comments at 20.(# 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 percall compensation  X-from IXCs.P yO"-ԍXxAPCC Comments at 2021.(#P In addition, MCI maintains that Bell Atlantic's plan does not provide screening  X-codes digits that can be "transmitted by PSPs for all access methods and from all locations."X yOW%-ԍXxMCI Comments at 2. MCI maintains that, for example, LECs "do not provide automatic number identification or information digits with feature group B access and from nonequal access areas." Accordingly, argues MCI, "PSPs would not be able to transmit specific payphone coding digits from"&,-(-( '"  yO-payphones in these circumstances and, therefore, they would not be eligible for compensation." Id.(#"X,-(-(ZZ("Ԍ X-ԙx@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  X-unaffiliated.SX yO-ԍXxBell Atlantic Reply at 10.(#S Bell Atlantic also asserts that, pursuant to the Commission's latest OLS order,  X-it has made FLEX ANI available to interexchange carriers by tariff.I yO= -ԍXxId. at 11.(#I Using FLEX ANI, Bell Atlantic represents that it will transmit a "70" code that uniquely identifies SCLs as  Xv-payphone lines.Bvx yO -ԍXxId.(#B 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  X1-the 07 code.B1 yO-ԍXxId.(#B  X -xA66.` ` 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  X -in a formal complaint or other proceedings.@  yO-ԍxSee, e.g., Policy and Rules Concerning Operator Service Access and Pay Telephone Compensation, CC Docket No. 9135, CCB/CPD File Nos. 9618, 9625, and 9632, Memorandum Opinion and Order, DA 962169, at 2 n.7 (rel. Dec. 20, 1996) (citing MCI petition for clarification of LECs' obligation to provide screening code digits, and stating that MCI's petition would be addressed in a subsequent order). We note that in its  yO'-Reconsideration Order, the Commission stated that, once percall compensation becomes effective, "[e]ach payphone must transmit coding digits that specifically identify it as a payphone, and not merely as a restricted  yO-line." Reconsideration Order at para. 64. That order further required that "all LECs must make available to  yO-PSPs, on a tariffed basis, such coding digits as part of the ANI for each payphone." Id. We note that this issue is currently under review.  Xy-x 4.` ` Numbering Assignments  XK-xB67.` ` According to APCC, the Payphone Order requires LECs to assign line numbers  X4-to payphones on a nondiscriminatory basis.x4 yO#-ԍXxAPCC Comments at 18 (citing Payphone Order at para. 149).(#x 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  X-applied to Bell Atlantic's payphone division and other PSPs.L0 yO&-ԍXxId. at 1819.(#L APCC maintains that Bell",-(-(ZZ " 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  X-assigned 8000 and 9000 series numbers. X yOK-ԍXxId. at 1819. APCC argues that assignment of numbers in the 8000 to 9000 range provides a distinct advantage in the prevention of fraud by alerting overseas operators to refrain from completing collect calls to such numbers.(#  In reply, Bell Atlantic asserts that it presently assigns new payphone numbers, including 8000 and 9000 blocking numbers, on a nondiscriminatory, firstcome, firstserved basis regardless of whether the requesting PSP is  X-affiliated or unaffiliated with Bell Atlantic.K yO& -ԍxBell Atlantic Reply at 10.K  X_-xC68.` ` 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  X1-reallocate existing number assignments.[1x yOZ-ԍXxPayphone Order at para. 149.(#[ 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.  X -x 5.` ` Dialing Parity  X -xD69.` ` MCI asserts that Bell Atlantic does not explain how it will comply with the  X-dialing parity requirement in the Payphone Order, including access to operator services,  Xy-directory assistance, and directory listings.My yO2-ԍXxMCI Comments at 23.(#M In reply, Bell Atlantic represents that, in the  Xb-Payphone rulemaking proceeding, the Commission ruled that the duty to provide intraLATA  XK-dialing parity applies to payphones when the duty is generally required.SK yO-ԍXxBell Atlantic Reply at 13.(#S  X-xE70.` ` 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  X-providers.[(  yO -ԍXxPayphone Order at para. 292.(#[ The Commission stated that such dialing parity for payphones should be  X-implemented at the same time as dialing parity for other telephones.B  yOC#-ԍXxId.(#B 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  X-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"~ H ,-(-(ZZn"  X-services it intends to offer and how it will unbundle those basic payphone services.^ yOy-ԍXxPayphone Order at para. 20304.(#^ 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.  X-x 6.` ` Uncollectibles  Xv-xF71.` ` AT&T asserts that Bell Atlantic must explain its treatment of uncollectibles due  X_-to fraud.L_X yOh -ԍXxAT&T Comments at 3.(#L 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  X1-accorded to nonaffiliates.B1 yO -ԍXxId.(#B 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  X -with the operator service provider.S x yO-ԍXxBell Atlantic Reply at 14.(#S 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.  XK- x7.` ` Operator Services  X-xG72.` ` APCC contends that Bell Atlantic's CEI plan fails to specify whether Bell  X-Atlantic's operator services are part of its deregulated payphone services.M yO-ԍXxAPCC Comments at 22.(#M 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  X-other PSPs in the provision of these services.B yO !-ԍXxId.(#B 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  X|-terms and conditions.B|(  yOU%-ԍXxId.(#B Bell Atlantic responds that its operator services are regulated services"|! ,-(-(ZZP"  X-and will be offered to affiliated and nonaffiliated PSPs on a nondiscriminatory basis.V yOy-ԍXxBell Atlantic Reply at 1415.(#V Bell Atlantic does not plan to "resell" operator services as a deregulated service for either inmate  X-services or payphone services in general.IX yO-ԍXxId. at 14.(#I 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  X-payphones.I yO& -ԍXxId. at 15.(#I  X_-xH73.` ` 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  X -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  X -service calls was beyond the scope of section 276 and the Payphone proceeding.b x yO-ԍXxReconsideration Order, at para. 52.(#b We conclude that Bell Atlantic has sufficiently addressed the concerns raised by APCC.  Xb- x8.` ` Inmate Calling Services Issues  X4-xI74.` ` 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  X-will provide to its ICS operations.S yO-ԍXxICSPC Comments at 23, 11.(#S 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  X-numbers.L yO!-ԍXxId. at 1018.(#L 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  Xe-Atlantic has complied with the requirements of section 276.He(  yO>&-ԍXxId. at 3.(#H In addition, ICSPC asserts that"e" ,-(-(ZZ1" Bell Atlantic should be required to disclose whether its payphone operations will be  X-responsible for the cost of ICS calls for which they are unable to collect.J yOb-ԍXxId. at 89.(#J  X-xJ75.` ` 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  X-whether that system is located at a central office or at a customer premises.KX yO-ԍXxId. at 910.(#K 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  XH-collocation to other providers.IH yO -ԍXxId. at 18.(#I 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  X -they wish.I x yO,-ԍXxId. at 19.(#I  X -xK76.` ` In a subsequent ex parte filing,  yO-ԍXxSee Letter from Albert H. Kramer to William Caton (Mar. 19, 1997) (ICSPC Ex Parte Response). (#Ƣ ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations  X -because collect calling is fundamental to ICS.J  yO-ԍXxId. at 12.(#J According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its networkbased 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  XK-is still subsidizing that service contrary to the prohibition in section 276.HK(  yO$-ԍXxId. at 2.(#H  X-xL77.` ` 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  X-institutions.S  yOA#-ԍXxBell Atlantic Reply at 12.(#S Bell Atlantic disputes ICSPC's characterization of inmate services as more  X-complex and complicated than other payphone services.BH  yO%-ԍXxId.(#B Bell Atlantic describes its inmate payphones as payphones that permit only automated collect calls through an operator service"#,-(-(ZZ"  X-provider and, in some cases, limited coin calls.B yOy-ԍXxId.(#B Bell Atlantic claims that the equipment used for inmate call restriction, PIN identification, and related security controls are dedicated  X-to specific correctional facilities and has been classified as deregulated CPE.BX yO-ԍXxId.(#B  X-xM78.` ` 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  XH-accorded to all calls that use Bell Atlantic's operator services.IH yO -ԍXxId. at 14.(#I Bell Atlantic does not intend  X1-to "resell" operator services as a deregulated service.B1x yOZ-ԍXxId.(#B Bell Atlantic represents, however, that its operator services will continue to serve independent payphone providers and Bell Atlantic  X -payphones on a nondiscriminatory basis.I  yO-ԍXxId. at 15.(#I 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  X -operator services.I  yO-ԍXxId. at 14.(#I Bell Atlantic represents that, in most of its inmate facilities, it uses a  X -store and forward technologyH( (  yO-ԍXxBell Atlantic explains the store and forward technology as follows:(# XxX` ` When an inmate dials a 0+ automated call, the PSP, either in the set or through ancillary equipment, stores the number and redials the call as a direct dialed or 1+ call with a recording requesting that the called party signal acceptance of a collect call. The call is billed to the PSP by the carrier transporting the call at direct dialed rates. The PSP, in turn, bills the party that accepted the collect call at rates set by the PSP. The store and forward method is transparent to the inmate placing the call as well as the recipient of the call who agrees to accept charges. These calls from the perspective of the consumer are indistinguishable from other collect calls placed by dialing 0 plus the called number.(#` XxLetter from Marie Breslin, Director FCC Relations, to William Caton, Acting Secretary, Federal  yO"-Communications Commission (Mar. 24, 1997) (Bell Atlantic Mar. 24th Ex Parte).(#H 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"$,-(-(ZZ"  X-owned by the vendor.zX yOy-ԍXxId. Bell Atlantic represents that call processing equipment owned by a third party vendor is utilized in over 80 percent of its inmate accounts. Bell Atlantic notes that, in a few instances, the equipment is  yO -either owned by Bell Atlantic or no call processing equipment is utilized. Id.(#z 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  X-purposes.B yOk-ԍXxId.(#B Bell Atlantic notes that these calls are then billed in the same manner and at the  X-same rates as collect calls generally.Bx yO -ԍXxId.(#B Bell Atlantic represents that the call processing in  X-these instances is viewed as adjunct to Bell Atlantic's operator services.B yO] -ԍXxId.(#B  Xv-xN79.` ` ICSPC argues that this approach not only conflicts with section 276 and the  X_-Payphone Order, but also violates the Commission's Declaratory Ruling on ICS equipment,  XH-issued a year ago.}XH yO-ԍXxLetter from Albert H. Kramer to William Caton (Apr. 10, 1997) (ICSPC Apr. 10th Ex Parte) citing  yOY-Petition for Declaratory Ruling by the Inmate Calling Services Providers Task Force, Declaratory  yO!-Ruling, 11 FCC Rcd 7362, 7373 (rel. Feb. 20, 1996) (Inmate Service Order)(#} 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  X -resale by Bell Atlantic's own ICS operation.W  yO>-ԍXxICSPC Apr. 10th Ex Parte(#W x  X -xO80.` ` Section 276 specifically defines payphone service to include the provision of  X-inmate telephone service in correctional institutions.OH  yO-ԍXx47 U.S.C.  276(d).(#O In the Reconsideration Order, we  Xy-clarified that the requirements of the Payphone Order apply to inmate payphones that were  Xb-deregulated in an earlier order. b yO -ԍXxReconsideration Order, at para. 131 (citing Petition for Declaratory Ruling by the Inmate Calling  yO!-Services Providers Task Force, Declaratory Ruling, 11 FCC Rcd 7362, 7373 (rel. Feb. 20, 1996)  yO{"-(Inmate Service Order); Petitions for Waiver and Partial Reconsideration or Stay of InmateOnly  yOC#-Payphones Declaratory Ruling, Order, 11 FCC Rcd 8013 (Com. Car. Bur. 1996)).(# 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"4%,-(-(ZZ"  X-provide the ICS, and the operator service facilities used to support the ICS.l yOy-ԍXxSee Payphone Order, at paras. 157, 159.(#l In addition, Bell Atlantic is required to offer on a tariffed basis any basic payphone service or network  X-feature used by its payphone operations to provide ICS.X yO-ԍXxSee Payphone Order, at paras. 14649; Reconsideration Order, at paras. 16263.(#ƙ  X-xP81.` ` 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  Xv-its payphone equipment, including that used for ICS,Sv yO -ԍXxBell Atlantic Reply at 12.(#S and that the underlying network services used to interconnect Bell Atlantic's ICS are available on a tariffed basis to all PSPs  XH-under the same terms, prices, and conditions.UHx yOq-ԍXxBell Atlantic CEI Plan at 5.(#U Additionally, Bell Atlantic will purchase the newlytariffed 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  X -located at a customer premises or a Bell Atlantic central office,  yO-ԍXxPayphone Order, at paras. 157, 159. See also Inmate Service Order, 11 FCC Rcd at 7373.(#ƨ it appears that Bell Atlantic  X -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.  Xy-xQ82.` ` 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.  X-Xx 9.X` ` Primary Interexchange Carrier (PIC) Selection (#`  Xe-xR83.` ` 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"N&,-(-(ZZ"  X-concerning the payphone PIC selection process. yOy-ԍXxOncor Comments at 5. According to Oncor, Bell Atlantic should have described: (1) how it will manage the payphone PIC selection and order implementation process; (2) how it will ensure that all PIC orders obtained pursuant to Bell Atlantic agreements with location owners will be handled on a nondiscriminatory basis, and that all valid PIC orders and location provider agreements will be honored and will not be subject to interference by Bell Atlantic or anyone else; (3) how its marketing personnel will be trained and supervised to ensure that they do not misrepresent Bell Atlantic's role in the payphone PIC selection process; and (4) how its personnel involved in the PIC ordering and implementation processes will be trained and supervised to ensure that they do not "interfere" with the  yO-sales and marketing of interexchange services from payphones. Id.(#ƴ AT&T also asserts that Bell Atlantic's CEI plan should describe how Bell Atlantic will ensure that the PIC selection process for  X-payphones will be performed on a nondiscriminatory basis.L yO -ԍXxAT&T Comments at 3.(#L Bell Atlantic responds that both independent payphone providers and Bell Atlantic will be able to select and control, in the  X-same manner, their "PIC" of a presubscribed interexchange carrier for their payphone lines.S(  yO}-ԍXxBell Atlantic Reply at 14.(#S  Xv-xS84.` ` We conclude that Bell Atlantic is not required, as part of the CEI process, to  X_-demonstrate how it will administer the PIC selection process for payphones. In the Payphone  XH-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  X -it will unbundle those basic payphone services.`  yO-ԍXxPayphone Order, at paras. 20304.(#` 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.  X- Xx10.` ` SubscriberSelected CallRating (#  Xb-xT85.` ` 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  X-establish the length of initial and overtime periods.vH  yO"-ԍXxAPCC Comments at 13; Payphone Associations Comments at 1315.(#v 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  X-minute period after the first five minutes.S yOx%-ԍXxAPCC Comments at 13, n. 9.(#S APCC and the Payphone Associations therefore request the Commission to require Bell Atlantic to develop a more flexible rating feature for"'h,-(-(ZZ"  X-its coin line service.v yOy-ԍXxAPCC Comments at 1213; Payphone Associations Comments at 15.(#v Likewise, APCC continues, Bell Atlantic should specify how directory  X-assistance (DA) rates are set.IX yO-ԍXxId. at 14.(#I In reply, Bell Atlantic maintains that it is not required, under  X-the terms of the Reconsideration Order, to disassemble the NCL line and provide separate  X-calling rating functionalities under state tariff.R yOT-ԍXxBell Atlantic Reply at 4.(#R Further, Bell Atlantic represents that the switch capability to apply different rates for directory assistance and toll calls on a lineby X-line basis is not available today.Hx yO -ԍXxId. at 5.(#H Bell Atlantic notes that the Commission's 120day process for new BSEs is available and should be used by independent payphone providers that seek to  X_-disassemble the basic lines or create new functionalities associated with the NCL line.H_ yO-ԍXxId. at 6.(#H  X1-xU86.` ` We find that the Payphone Order did not require the BOCs to provide to  X -independent PSPs an unbundled call rating feature for coin line services.  yOc-ԍXxPayphone Order, at paras. 14648. See also Reconsideration Order, at para. 165.(#ƛ In addition, in its  X -Reconsideration Order, in response to a request that it require access to, inter alia, call rating  X -capabilities,sX (  yO-ԍXxOn reconsideration, the New Jersey Payphone Association requested that the Commission require access to call rating capabilities, answer supervision, call tracking, joint marketing, installation and  yOU-maintenance, and billing and collection. See Reconsideration Order, at para. 155. (#s the Commission specifically declined to require this type of unbundling.c H  yO-ԍXxReconsideration Order, at para. 165.(#c As previously noted, independent PSPs may seek additional unbundling through the 120day  X -ONA process. State regulatory commissions also may impose further unbundling requirements.  Xy- Xx11.` ` Operator Service Provider (OSP) Selection (#  XK-xV87.` ` 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  X-for intraLATA calls.F yO#-ԍXxAPCC at 14. (#F APCC asserts that, under section 276, PSPs are entitled to select their OSP of choice for intraLATA, including local, operatorassisted calls, and therefore that, to the extent Bell Atlantic does not permit OSP selection for its coin line service, its CEI plan is"(h,-(-(ZZ'"  X-inconsistent with section 276.B yOy-ԍXxId.(#B 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  X-selection process to choose a presubscribed carrier for intraLATA calls.SX yO-ԍXxBell Atlantic Reply at 14.(#S We find that APCC's request goes beyond the scope of this proceeding, which is limited to determining  X-whether Bell Atlantic's CEI plan complies with the Commission's Computer III CEI requirements.  XJ- Xx12.` ` Interim Compensation Scheme (#  X -xW88.` ` 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  X -to participate in the interim compensation scheme outlined in the Payphone Order.F   yO-ԍXxTelco at 47.(#F We find this argument is beyond the scope of this CEI proceeding. Moreover, the interim  X -compensation rules were addressed at length in the payphone rulemaking proceeding.  x yO-ԍXxSee e.g., Reconsideration Order, at para. 11415 (describing the interim compensation mechanism  yO-adopted in the Payphone Order).(#  X-Xx 13.X` ` Payphone Subsidy (#`  Xd-xX89.` ` 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  X-required to make such a demonstration as part of its CEI plan.  yOr-ԍXxUnder the terms of the Payphone proceeding, 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, a BOC must, in addition to having an approved CEI plan, be able to certify the following: 1) it has an effective cost accounting manual filing; 2) it has an effective interstate CCL tariff reflecting a reduction in revenue; 3) it has effective interstate tariffs reflecting the removal of charges that recover the costs of payphones any intrastate subsidies; 4) it has deregulated and reclassified or transferred the value of payphone customer premises equipment and related costs as required in the Report and Order; 5) it has in effect intrastate tariffs for basic payphone services (for "dumb" and "smart" payphones); and 6) it has in effect intrastate and interstate tariffs for unbundled  yOz%-functionalities associated with those lines. Reconsideration Order, at para. 131, 132. See also  yOB&-Clarification Order, at para. 29.(#Ɲ ")0 ,-(-(ZZ"Ԍ X-Xx 14.X` ` SemiPublic Service Issues (#`  X-xY90.` ` 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  Xv-treated on the subscriber's bill.P v yO-ԍXxAPCC Comments at 2526.(#P We find these semi-public service issues to be beyond the scope of the CEI review process.  X1- V. CONCLUSION ă  X -xZ91.` ` 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." *X ,-(-(ZZl "  X-H VI. ORDERING CLAUSE ă  X- x[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. x` `  hh@Federal Communications Commission x` `  hh@A. Richard Metzger, Jr. x` `  hh@Deputy Chief, Common Carrier Bureau