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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) BellSouth Corporation's Offer of ) Comparably Efficient ) Interconnection to ) Payphone Service ) Providers ) ) ) CC Docket No. 96-128 Implementation of the Pay Telephone ) Reclassification and Compensation ) Provisions of the Telecommunications ) Act of 1996 ) ORDER Adopted: April 15, 1997 Released: April 15, 1997 By the Deputy Chief, Common Carrier Bureau: TABLE OF CONTENTS Paragraph I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. SERVICE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . 6 IV. COMPLIANCE ISSUES . . . . . . . . . . . . . . . . . . . . . . . 11 A. CEI Plan Requirements . . . . . . . . . . . . . . . . . 11 B. Other Nonstructural Safeguards. . . . . . . . . . . . . . 47 C. Accounting Safeguards . . . . . . . . . . . . . . . . . . 55 D. Other Issues. . . . . . . . . . . . . . . . . . . . . . . 56 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 VI. ORDERING CLAUSE . . . . . . . . . . . . . . . . . . . . . . . . . 90 I. INTRODUCTION 1. On November 22, 1996, pursuant to the requirements of the Commission's orders in the payphone rulemaking proceeding, BellSouth Corporation (BellSouth) filed a comparably efficient interconnection (CEI) plan for payphone service. In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan describing how it will comply with the Commission's Computer III CEI equal access parameters and nonstructural safeguards for the provision of payphone services. BOCs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations to provide payphone services. 2. The Commission issued a public notice of BellSouth's CEI plan on November 27, 1996. On December 30, 1996, six parties filed comments opposing the plan. BellSouth submitted reply comments on January 15, 1997. For the reasons discussed below, we approve BellSouth's CEI plan. II. BACKGROUND 3. The payphone rulemaking proceeding implemented section 276 of the Communications Act of 1934, as amended. 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 that provides payphone service: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone service. The 1996 Act provided that such safeguards must, at a minimum, include the nonstructural safeguards adopted in the Computer III proceeding. 4. In the Payphone Order, the Commission determined that the Computer III and Open Network Architecture (ONA) nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or cross-subsidize in their provision of payphone service." Accordingly, the Commission required the BOCs to file "CEI plans describing how they will comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI requirements as modified by section 222 of the 1996 Act, network disclosure requirements, and installation, maintenance, and quality nondiscrimination requirements." Obtaining approval of its CEI plan is one of the criteria a BOC must meet before its payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established in the payphone proceeding. 5. The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrument-implemented 'smart payphones' or 'dumb' payphones that utilize central office coin services, or some combination of the two in a manner similar to the LECs." Those tariffs must be filed with the applicable state regulatory commission. Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone affiliate to provide payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis. III. SERVICE DESCRIPTION 6. BellSouth will conduct its payphone operations through a corporate entity that is distinct from its basic service operations. The new entity, BellSouth Public Communications, Inc. (BSPC), is a wholly owned subsidiary of BBS Holdings, Inc., which itself is a wholly owned subsidiary of BellSouth Telecommunications, Inc., the provider of basic services and the entity to whom the CEI obligations attach. 7. BellSouth states that it offers two payphone services -- 1) Public Telephone Access Service for customer premises equipment (CPE) (PTAS); and 2) SmartLine Service for Public Telephone Access (SmartLine). For purposes of this order, PTAS service will also be referred to as "customer owned, coin operated telephone" or "COCOT" service, and SmartLine service will be referred to as "coin line" service. 8. The PTAS service is a local exchange service provided for use with customer- provided coin-operated or noncoin-operated public telephones that are frequently referred to as "smart sets." According to BellSouth, the PTAS is a standard Dial Tone First (DTF) exchange line service that is offered on a two-way or outward-only basis. For PTAS, BellSouth provides the carriage and completion of all local dialed calls, including operator service functions. The service may be offered as a flat rate or measured local service, depending upon the jurisdiction. BellSouth states that billed number screening is a mandatory feature associated with its PTAS service. Various central office blocking and operator screening options are also available with PTAS. BellSouth states that it will also provide central office blocking of 900, 976, and N11 calls placed from payphone sets. PSPs may also obtain international call blocking for PTAS from BellSouth's federal tariff. BellSouth offers answer supervision as an optional feature for PTAS service in Florida only. BellSouth represents that an operator cannot perform coin control functions on a PTAS line. According to BellSouth, tariffs for its PTAS service have been in effect in all of its states since 1985. 9. BellSouth states that its SmartLine service is a standard DTF coin line for customer-provided pay telephones that are commonly referred to as "dumb sets." According to BellSouth, this service can be provided on a two-way or an outward-only basis. SmartLine service may be offered as a flat rate or measured local service, depending upon the jurisdiction. The SmartLine service will be provided on a DTF basis to allow end users to dial certain calls without requiring coin deposits -- e.g., 911, local directory assistance, and nonsent paid calls. BellSouth will provide central office blocking of 900, 976, and N11 calls. SmartLine service includes: (1) operator call screening to alert the operator that the call is originating from a SmartLine service line and may require special handling and billing treatment; (2) billed number screening; and (3) coin signaling (coin collect and coin return). BellSouth's operator system will handle 0-intraLATA toll calls and 0+ local calls from SmartLine Service lines. All 10XXX 0+ or 101XXXX 0+ dialed intraLATA toll calls will be routed to the dialed carrier. As with the PTAS service, international call blocking is available through the BellSouth federal tariff. According to BellSouth, state tariffs for its SmartLine service are in effect in all of BellSouth's states. 10. BellSouth also lists additional services that will be available to all PSPs. These are local usage detail and coin refund and repair referral service. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 11. The Commission's CEI requirements were originally established in the Computer III proceeding, in which the Commission adopted a regulatory framework to govern the provision of integrated enhanced and basic services by the BOCs. As applied in the payphone context, the CEI requirements are designed to give independent PSPs equal and efficient access to the regulated basic payphone services that the BOCs use to provide their own payphone services. BOCs also must provide payphone services to independent PSPs on a nondiscriminatory basis as required in the payphone rulemaking proceeding. The Commission, in its Computer III proceeding, established nine specific CEI requirements, which are discussed below. BellSouth has described in its submissions how it will satisfy each of these nine requirements. We review below BellSouth's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 12. The Payphone Order deregulated LEC payphones and classified those payphones as CPE. In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either 'smart payphones' or 'dumb' payphones that utilize central office coin services, a LEC must also tariff unbundled payphone features that the LEC uses or provides on an unbundled basis. Moreover, BOCs, but not other LECs, must unbundle additional network elements when requested by payphone providers based on the specific criteria established in the Computer III and ONA proceedings. 13. The Payphone Order requires BOCs to file CEI plans that explain how they will unbundle basic payphone services. Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic service functions that underlie its provision of payphone service. Nonproprietary information used by the BOC in providing the unbundled basic services must be made available as part of CEI. In addition, any options available to the BOC in the provision of such basic services or functions must be included in the unbundled offerings. 14. According to SPCC, BellSouth's description of its plan to unbundle its payphone line access services is inadequate. SPCC states that although BellSouth's plan describes the payphone line access it intends to provide to payphone providers, the plan fails to offer any information concerning the constituent elements of payphone line access or the service which is currently provided to its own payphone operations. SPCC asserts that if BellSouth does not disclose the services to which it currently subscribes or the constituent elements of the service, the Commission cannot evaluate whether BellSouth has sufficiently unbundled its service offerings. Both APCC and SPCC contend that the BOCs must unbundle and tariff the features that they provide to their own payphone services. APCC further argues that BellSouth must tariff "the basic payphone line" separately from network services and unbundled features. 15. BellSouth responds that the Commission did not require unbundling of existing services beyond the coin line service that the Commission permitted to be filed in the state tariff. According to BellSouth, "there are no payphone-specific, network-based, unbundled features and functions provided to others or taken by BellSouth's payphone operations that are tariffed by BellSouth at the intrastate level." 16. We find that BellSouth's plan satisfies the CEI unbundling requirement required in the payphone rulemaking proceeding. The payphone rulemaking proceeding requires the BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone services using smart, dumb, or inmate payphones. In addition, consistent with the requirements of the payphone rulemaking proceeding, BOCs must provide, on a tariffed basis, the unbundled features and functions that they provide to unaffiliated PSPs or to their own payphone operations. BellSouth's plan, as supplemented, satisfies these requirements. We note, however, that BellSouth may choose to unbundle additional payphone-specific features and functions, the states may require further unbundling, or independent PSPs may request additional unbundled features and functions through the ONA 120-day service request process. Any network-based, payphone-specific features and functions offered on an unbundled basis must comply with the tariffing and CEI requirements of the payphone proceeding, Computer III, and ONA. 17. We reject APCC's contention that BellSouth must unbundle the "'basic payphone line' separately from network services and unbundled features." As noted in the Clarification Order, the Commission's payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled basis." In the Clarification Order, we stated that, for example, if a BOC provides answer supervision bundled with the basic payphone line, the BOC is not required either to unbundle that service from its state tariff for payphone service, or to tariff that service at the federal level. If the LEC, however, provides answer supervision, separately, on an unbundled basis, either to affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal jurisdictions. Thus, BellSouth is not required at this time to unbundle from its basic payphone service offerings any features that BellSouth does not offer on an unbundled basis to itself or to others. Independent payphone providers may seek further unbundling by making a request pursuant to the ONA process. 2. Interface Functionality 18. The interface functionality requirement obligates the BOC to make available standardized hardware and software interfaces that are able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. 19. BellSouth represents that it will satisfy this requirement by having BSPC purchase and utilize the same tariffed services that are available to other providers of payphone services. We find that BellSouth's CEI plan comports with the interface functionality requirement established by the Commission. 3. Resale 20. The resale requirement established in Computer III obligates a "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anticompetitive pricing in unregulated markets." Based on the requirement in the Payphone Order and the Reconsideration Order, any basic services provided by a BOC to its payphone affiliate, as well as any payphone service provided to others, must be available on a nondiscriminatory basis to other payphone providers. 21. BellSouth represents that BSPC will "subscribe to the tariffed services at the same tariffed rates as any other subscriber to these services." We find that BellSouth has met the resale requirement. 4. Technical Characteristics 22. This requirement obligates a carrier to provide basic services with technical characteristics that are equal to the technical characteristics the carrier uses for its own payphone services. 23. BellSouth represents that its payphone operations will use the same basic services as its payphone competitors, and that there will be no difference in the technical characteristics of those services. We find that BellSouth's CEI plan comports with the technical characteristics requirement established by the Commission. 5. Installation, Maintenance, and Repair 24. The Payphone Order requires BOCs to describe in their CEI plans how they will comply with the nondiscrimination requirements in Computer III and ONA regarding the quality of service, installation, and maintenance. This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in a CEI offering to unaffiliated PSPs are the same as those the carrier provides to its own or its affiliated payphone service operations. BOCs also must satisfy reporting and other requirements showing that they have met this requirement. 25. In its CEI plan, BellSouth represents that its payphone operations will use the same ordering methods for service maintenance as other payphone service operators and that all service and maintenance requests will be processed through the same systems. According to BellSouth, its payphone operations will be subject to the same scheduling procedures and time periods, as any other PSP. BellSouth notes that its Private Payphone Provider Handbook, which it provides to PSPs, contains a description of its service order procedures, installation procedures and schedules, and repair procedures. BellSouth represents that BSPC has its own field service personnel who install, repair, and maintain BSPC's payphone sets and ancillary equipment, and, therefore, BellSouth will only provide tariffed access lines and services to BSPC on the same terms and conditions as provided to other PSPs. 26. APCC argues that BellSouth's CEI plan does not provide sufficient detail about how it will provide installation, maintenance, and repair. APCC contends that BellSouth's reference to its Private Payphone Provider Handbook is inadequate for CEI purposes, and that BellSouth should incorporate this handbook into its plan if it is going to rely on these procedures. With respect to service order processing, APCC asserts that in the past independent PSPs have experienced difficulties when a location provider changes from a BellSouth payphone to an independent PSP's payphone. APCC claims that in the past when an independent PSP ordered service for a location to install a payphone to replace an existing BellSouth payphone, BellSouth personnel would not connect the new payphone without first checking to see if the BellSouth payphone was under a contract. According to APCC, disputes between BellSouth's payphone division and the location provider over whether an existing contract remains in force should not prevent the connection of a new payphone. APCC argues that BellSouth should be required to refile its CEI plan specifying the procedures it will follow to ensure that there are no discriminatory practices when its payphones are replaced by independent PSP payphones. 27. Further, APCC contends that "any approval of BellSouth's CEI plan should be explicitly conditioned on its commitment not to share personnel" with BSPC when performing installation, repair, and maintenance functions. According to APCC, BellSouth's plan also is deficient because it fails to make clear whether it will follow nondiscriminatory practices with respect to the location of the demarcation point. APCC asserts that although no interface may have been installed yet, a demarcation point can and should be identified to determine at what point wire maintenance should be charged separately to BSPC as "inside wire" maintenance and at what point wire maintenance may be included as part of the tariffed access service. According to APCC, the BellSouth Private Payphone Provider Handbook states that BellSouth will provide inside wiring installation and repair on a time and materials basis to independent PSPs. APCC argues that BellSouth's CEI plan should state that BellSouth will also charge BSPC for such installation and repair on a time and materials basis. 28. In its reply, BellSouth further clarifies that as a separate entity, BSPC's personnel will contact the same BellSouth service center through the same channels of communication that are available to other PSPs (i.e., same phone number and same fax number). BellSouth states that it has attached a current copy of its Private Payphone Provider Handbook to its reply. BellSouth represents that it will follow the procedures described in the handbook on a nondiscriminatory basis. Further, BellSouth represents that it will handle all displacement situations identically. According to BellSouth, lines ordered by any PSP, whether BSPC or any other, will be installed as ordered on a nondiscriminatory basis. With respect to the demarcation point issue, BellSouth represents that it intends "to satisfy and comply with the demarcation point requirements for payphones provided by [BSPC] or independent payphone providers, in accordance with" the Payphone Order and the Reconsideration Order. 29. We conclude that BellSouth's CEI plan, together with the representations that BellSouth has made in this proceeding, provide sufficient detail on the procedures it will employ to ensure that the installation, maintenance, and repair functions will be performed on a nondiscriminatory basis. For example, APCC has raised concerns about the sharing of personnel who perform installation, repair, and maintenance functions. BellSouth represents that BSPC has its own field service personnel who install, repair, and maintain BSPC's payphone sets, and, therefore, BellSouth will only provide tariffed access lines and services to BSPC on the same terms and conditions as provided to other PSPs. According to BellSouth, the time intervals for providing installation, maintenance and repair will be the same for all PSPs. BellSouth represents that it will adhere to the Commission's demarcation point requirements. BellSouth further represents that it will provide installation, maintenance and repair on a nondiscriminatory basis. We note that while BellSouth's Payphone Provider Handbook is not part of its CEI plan, BellSouth has an affirmative, continuing obligation to ensure that its ordering, order processing, maintenance, and other services offered to PSPs are provided on a nondiscriminatory basis to affiliated and unaffiliated PSPs. We find that the record evidence with respect to BellSouth's installation, maintenance, and repair procedures for PSPs satisfies our CEI requirements. 6. End-User Access 30. With regard to payphone services, this parameter requires the BOC to provide to all end users the same network capabilities to activate or obtain access to payphone services that utilize the BOC's facilities. This parameter also requires the BOC to provide all end users equal opportunities to obtain access to basic network facilities. 31. BellSouth represents that its payphone operations will purchase and utilize the same tariffed services available to all other PSPs. BellSouth, therefore, maintains that end users of its payphone services will not have available to them any network features, including abbreviated dialing or special signaling, that are not also available to end users of other PSPs. We find that BellSouth's CEI plan comports with the end-user access requirement established by the Commission. 7. CEI Availability 32. This requirement obligates a carrier'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 requires the carrier to provide a reasonable time prior to that date when prospective users of the CEI offering can use the CEI facilities and services for purposes of testing their payphone service offerings. Past decisions also have referred to this as the 90-day notice requirement. 33. The payphone rulemaking proceeding established the following tariffing requirements for LECs. LECs must file tariffs in the states for basic payphone services that enable independent PSPs to offer payphone services using either smart or dumb payphones and for any unbundled features that the LECs provide to their payphone operations or to others. LECs are not required to file tariffs for the basic payphone line for smart and dumb payphones with the Commission. As stated in the Clarification Order, LECs are required to file federal tariffs for payphone-specific, network-based features and functions "only if the LEC provides them separately and on an unbundled basis from the basic payphone line, either to its own payphone operations or to others . . . ." 34. The Clarification Order also granted all LECs a limited waiver of the federal tariffing requirements for unbundled features and functions that a LEC must meet before it is eligible to receive payphone compensation. Pursuant to this waiver, LECs must file interstate tariffs for unbundled features and functions within 45 days of the release date of the Clarification Order, with a scheduled effective date of no later than 15 days after the date the tariff is filed. In addition, each BOC was required to file, by April 10, 1997, a written ex parte document that advises the Commission on the status of intrastate tariffs for the features and functions that it has not yet federally tariffed, and stating that it commits to filing federal tariffs for such features and functions within 45 days of the release date of the Order. 35. BellSouth represents that tariffs for both its PTAS and SmartLine services are in effect in all of its states. With respect to the testing period requirement, BellSouth states that the tariffed services to be used by its own payphone operations have been available to potential payphone competitors for, in most cases, anywhere from two to eleven years. Therefore, BellSouth maintains that payphone competitors have already had ample opportunity to engage in any necessary testing. According to BellSouth, no purpose would be served by now specially designating an additional time period for testing. BellSouth notes that in this context the establishment of a testing period prior to its offering of payphone service to the public is not practical, since BellSouth already offers payphone services to the public using the facilities and functionalities listed in the tariffs. Therefore, BellSouth asserts that the imposition of a service testing period before it could use the tariffed services in its payphone operations would require it to discontinue payphone service for the duration of the testing period. 36. According to APCC, BellSouth's CEI plan is deficient because it has not filed any federal tariffs with its plan. APCC claims that the only service LECs are not required to tariff at the federal level is the basic payphone line for smart and dumb payphones. Furthermore, both SPCC and APCC claim that the Commission should not rely on the illustrative state tariffs filed by BellSouth, because the rates listed in those tariffs are not representative of the rates charged throughout BellSouth's region. Moreover, APCC asserts that the state tariffs that BellSouth did attach to its plan are not complete or up-to- date. According to APCC, the Florida PTAS service tariff, which BellSouth attached as an illustrative tariff with its CEI plan, is not the most recent version, and many of the relevant rates are cross-referenced to tariff pages that were not included in the CEI filing. APCC also notes that BellSouth's Florida SmartLine service tariff provides that the service "will be provided from central offices where facilities are available." APCC asserts that BellSouth must disclose the areas in which SmartLine service is unavailable, and how many payphones it has installed in such areas. APCC contends that to the extent that BSPC has new or embedded payphones in such areas, it must be required to convert such payphones to the PTAS service. Otherwise, APCC asserts that BellSouth would be in the position of providing SmartLine service to BSPC while claiming that it is unavailable to independent PSPs. AT&T argues that BellSouth should be required to amend its CEI plan to clarify that SmartLine service will be available to non-BellSouth PSPs at every central office where such service is provided to BSPC. In response to BellSouth's statement that the testing period requirement does not apply in the payphone context, SPCC contends that a testing period is still appropriate, "once BellSouth has properly unbundled its services." 37. BellSouth responds that APCC misreads the Commission's tariffing and unbundling requirements. BellSouth states that the Commission did not require the unbundling of existing services beyond the coin line service that it permitted to be filed with the states. Therefore, BellSouth states that there are no additional features or functions to be unbundled, and, therefore, there are no applicable federal tariffs. In responding to concerns about the deficiencies in the illustrative state tariffs, BellSouth concedes that a portion of one of the submitted sample tariffs has been superseded. BellSouth, however, represents that it has attached to its reply a "copy of the current tariff for both of [its payphone] services in all of [its] states." BellSouth also responds to concerns about its SmartLine service tariff offering being limited to central offices where facilities are available. BellSouth states that "BSPC will buy tariffed services subject to the same tariff limitations as any other provider." Thus, BellSouth represents that "in the handful of instances whereby [BellSouth] is currently offering payphone service using dumb sets out of central offices where SmartLine is not available, such locations will be converted to smartset installations and BSPC will buy the same standard line that is available to all other providers." 38. We find that BellSouth's plan complies with the CEI availability requirement. We reject APCC's argument that BellSouth must file a federal tariff for all payphone service features and functions except for the basic access line for its PTAS and SmartLine services. As stated in the Clarification Order, BOCs need only submit federal tariffs for payphone-specific network-based features and functions if the BOC provides them separately and on an unbundled basis from the basic payphone line either to its payphone operations or to others. BellSouth represents that it will file federal tariffs, in accordance with the requirements of the Clarification Order, for answer supervision, which it tariffs as an unbundled feature in Florida for use with either independent PSP lines or line side terminated private branch exchange (PBX) trunks. We reject as well APCC's and SPCC's contention that BellSouth may not rely on illustrative or sample tariffs. We do not require carriers to file a complete set of tariffs with their CEI submissions. Sample or illustrative tariffs are sufficient. In any event, this argument is moot because BellSouth represents that it has supplemented its CEI plan with copies of all of its current tariffs for the states in its region. 39. We also conclude that BellSouth is not required to identify in its CEI plan specific geographic areas where coin line service is not available or to state whether BellSouth has any payphones in such areas or what type of service, coin line or COCOT, is being provided. BellSouth's illustrative state coin line tariff provides that coin line service will be provided where facilities are available. BellSouth represents that BSPC will buy the same tariffed services subject to the same tariff limitations as any other provider. We find that the illustrative state tariff together with BellSouth's representation provide adequate information concerning the availability of its coin line service for purposes of our CEI plan requirements. 40. Finally we grant Bellsouth's request not to enforce the 90-day notice requirement for BellSouth's provision of its coin line and COCOT services. Therefore, BellSouth may provide and continue to provide its coin line and COCOT services through the use of the CEI offering described herein for such services without first providing ninety days for unaffiliated carriers to test such services. This waiver is reasonable in this context because, unlike the provision of a new enhanced service, BellSouth has been offering its coin line and COCOT services for some time. To bar BellSouth from continuing to offer COCOT and coin line services for a period of ninety days would result in a suspension of service. BellSouth is not, however, relieved of its obligation under this parameter to permit unaffiliated PSPs to conduct testing, if deemed necessary, of the COCOT and coin line CEI offerings. For purposes of approving this CEI plan, we waive the prohibition that bars BellSouth's payphone operations from using BellSouth's COCOT and coin line services before such testing is accomplished. If and when other basic payphone services are deployed, BellSouth must make testing capability available to unaffiliated PSPs at the same time that such capability is available to BellSouth. 8. Minimization of Transport Costs 41. This requirement obligates carriers to provide competitors with interconnection facilities that minimize transport costs. 42. BellSouth represents that its payphone operations subscribe to the same tariffed services as other PSPs and that they are not collocated with BellSouth's basic network services. Consequently, BellSouth states that there are no differences in transmission costs. 43. As a corollary to its general argument that the Commission should require BellSouth to reduce the rates for its PTAS service, SPCC asserts that BellSouth must reduce its PTAS service rates in states other than Florida in order to comply with the minimization of transport costs requirement. SPCC argues that the Commission should require BellSouth to significantly lower its rates for PTAS service in its region so that they are equal to the Florida PTAS rates, which SPCC contends are BellSouth's single line business rates in that state. SPCC asserts that such a reduction is consistent with BellSouth's Computer III obligation to reduce transport costs to its competitors. SPCC argues that the "principle of Computer III requires BOCs to reduce transmission costs [in this instance, PTAS rates] to its competitors where the BOCs' own interconnection [SmartLine] gives it an unfair cost advantage." According to SPCC, BellSouth's statement that it will subscribe to the same tariffed services as other PSPs does not suffice in this instance because "independent PSPs cannot realistically interconnect to the local network through SmartLine." BellSouth responds that "[t]he Commission has repeatedly affirmed that its minimization of transport requirement is met when a carrier charges its own operations the same tariffed rate for its access facility as it charges all other service providers." 44. In the Computer III Phase I Order, where the Commission established the minimization of transport costs requirement, the Commission discussed this requirement in the context of advantages that a LEC might gain because it was collocating the equipment of its enhanced service operations while not giving others the same access. In this instance, SPCC has not indicated that BSPC's use of the SmartLine service involves any type of equipment collocation, which would provide BSPC with an advantage in terms of transport costs. Consequently, BellSouth's compliance with the minimization of transport costs requirement does not require a reduction in BellSouth's PTAS rates. We find that BellSouth's CEI plan comports with the minimization of transport costs requirement established by the Commission. 9. Recipients of CEI 45. This requirement prohibits a BOC from restricting the availability of its CEI offering to any particular class of customer or PSP. 46. BellSouth represents that the basic service tariffs to which BSPC and other PSPs will subscribe contain no class of customer restrictions and are available to any customer for any lawful purpose. We find that BellSouth has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 47. In addition to the CEI requirements established in Computer III, and applied to BOC provision of payphone services in the Payphone Order, a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination reporting. 1. Customer Proprietary Network Information 48. The Payphone Order requires BellSouth to explain how it will comply with the Computer III CPNI safeguards, to the extent they are not inconsistent with section 222 of the Communications Act, as amended. Although the requirements of section 222 became effective immediately upon enactment, the Commission has initiated a proceeding to consider regulations interpreting and specifying in more detail a telecommunications carrier's obligations under this provision. The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they do not conflict with section 222. 49. In its CEI plan, BellSouth represents that it will not disclose the CPNI of any PSP to any other PSP, including BSPC, without the PSP's authorization. According to BellSouth, aggregate CPNI will be made available to BellSouth's payphone service operation, if at all, only pursuant to the conditions of section 222(c)(3) of the Communications Act, as amended. We find that BellSouth's plan comports with the CPNI requirements. 2. Network Information Disclosure 50. The Payphone Order requires BellSouth to disclose to the payphone services industry information about network changes and new network services that affect the interconnection of payphone services with BellSouth's network. BellSouth must make that disclosure at the "make/buy" point, that is, when BellSouth decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface. BellSouth must provide that information to members of the payphone services industry that sign a nondisclosure agreement within 30 days after the execution of the nondisclosure agreement. BellSouth also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that service. 51. In the Payphone Order, the Commission waived the notice period for disclosure of network information relating to the "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory requirements of that order. Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15, 1997. 52. BellSouth states that it has previously made appropriate disclosure of interface information related to the tariffed services covered by its payphone CEI plan. BellSouth represents that it began offering its SmartLine service in 1993, and that it published its network disclosure notice for that service in 1992. BellSouth further represents that it will comply with the Commission's established network disclosure rules in its provision of new services or network changes that affect the interconnection or interoperability of payphone services with the network. We find that Bellsouth's CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 53. In the Payphone Order, the Commission directed the BOCs to comply with the Computer III and ONA requirements regarding nondiscrimination in the quality of service, installation, and maintenance. Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semi-annual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of covered service offerings, installation and maintenance. 54. In addition to the installation and maintenance procedures described above in Section IV.A., BellSouth states that it will begin including services provided to payphone service operators in its periodic ONA nondiscrimination reports. We find that BellSouth's CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 55. In the Payphone Order and the Accounting Safeguards Order, the Commission concluded that it should apply accounting safeguards identical to those adopted in Computer III to BOCs providing payphone service on an integrated basis. Pursuant to Computer III, the BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These safeguards consist of five principal elements: 1) the establishment of effective accounting procedures, in accordance with the Commission's Part 32 Uniform System of Accounts requirements and affiliate transactions rules, as well as the Commission's Part 64 cost allocation standards; 2) the filing of cost allocation manuals (CAMs) reflecting the accounting rules and cost allocation standards adopted by the BOC; 3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with their cost allocation manuals; 4) the establishment of detailed reporting requirements and the development of an automated system to store and analyze the data; and 5) the performance of on-site audits by Commission staff. BellSouth must comply with these accounting safeguards. We note that the approval granted to BellSouth in this order is contingent upon the CAM amendments associated with BellSouth's provision of payphone service going into effect. D. Other Issues 1. Sufficiency 56. APCC, CompTel, ICSPC, SPCC, and AT&T generally assert that BellSouth's CEI plan insufficiently describes how it intends to comply with the CEI parameters; therefore, these parties request that the Commission require BellSouth to either amend or refile its plan. As discussed elsewhere in this order, however, we find that BellSouth adequately complies with each of the required parameters. 2. Tariffing Issues 57. APCC and SPCC raise various objections to the contents of BellSouth's state tariffs. Various commenters urge the Commission to review the relative charges for BellSouth's COCOT line services and coin line services, claiming that the price differential may unreasonably discriminate in favor of its tariffed coin line services, which, according to these commenters, BellSouth's payphone operations are more likely to use. 58. BellSouth responds that complaints about the adequacy of the rates or other aspects of its state tariffs are not before the Commission in this CEI plan review proceeding. BellSouth asserts that in the CEI context it is only required to show that the underlying basic payphone services are available on the same terms and conditions to all PSPs. 59. We conclude that the state payphone tariff proceedings are the appropriate fora to address complaints concerning rates, terms, and conditions offered in state tariffs. The Commission stated in the Reconsideration Order that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with the requirements of section 276." That order required that the tariffs for these LEC services must be: (1) cost based; (2) consistent with the requirements of section 276 with regard, for example, to the removal of subsidies from exchange and exchange access services; and (3) nondiscriminatory. In addition, the order established that "[s]tates must apply these requirements and the Computer III guidelines for tariffing such intrastate services." The order further stated that "[w]here LECs have already filed intrastate tariffs for these services, states may, after considering the requirements of this order, the Report and Order, and section 276 conclude: 1) that existing tariffs are consistent with the requirements of the Report and Order as revised herein; and 2) that in such case no further filings are required." Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs operating in their state to file these tariffs with the Commission." Thus, the state payphone tariff proceedings are the appropriate fora to address concerns about rates, terms, and conditions offered in state payphone tariffs. 3. Screening Codes 60. APCC, MCI, and AT&T contend that BellSouth is required to provide PSPs using COCOT lines with a screening code that uniquely identifies their lines as payphone lines. According to APCC, BellSouth's plan does not provide sufficient detail about the types of screening services that BellSouth will offer to independent PSPs and BSPC's payphones. APCC asserts that BellSouth had initially indicated that it would implement the Commission's originating line screening (OLS) requirement by offering "Flex ANI," a service that permits the assignment of a "70" code that uniquely identifies COCOT lines. APCC claims that BellSouth now states that it will provide LIDB-based OLS, rather than Flex ANI. APCC argues that LIDB-based OLS is inferior to the unique code provided to LEC payphones using coin lines, and that such inferior treatment is inconsistent with the nondiscrimination requirement of section 276(a). Both AT&T and MCI support APCC's contention that the transmission of different digits on the SmartLine and PTAS lines constitutes discrimination. AT&T also asserts that whatever codes are used, "the Reconsideration Order (para. 64) precludes BellSouth from requiring an interexchange carrier to perform an additional look-up in order to track payphone calls." MCI also argues that BellSouth is not in compliance with the Commission's payphone orders. According to MCI, in the Reconsideration Order the Commission required LECs to make available to PSPs coding digits as a part of ANI that specifically identify a phone as a payphone and "not merely as a restricted line." 61. In its reply, BellSouth disputes APCC's argument that BellSouth's choice of the LIDB solution for its OLS service unlawfully discriminates against non-BellSouth payphone providers. According to BellSouth, the Commission determined that OLS could be provided by means of either a FLEX ANI solution or by the use of LIDB technology. BellSouth states that consistent with the Commission's requirements, both the SmartLine service, which delivers the "27" ANI digits, and the PTAS service, which delivers the "07" digits, are equally available to all payphone providers, including BSPC. 62. We find that the issue of whether BellSouth is providing screening information in compliance with the requirements established in the payphone rulemaking proceeding to be outside the scope of the CEI review process and is more appropriately raised in that proceeding or in other proceedings. 4. Numbering Assignments 63. APCC contends that BellSouth 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 PSP payphones are assigned 8000 and 9000 series numbers. In reply, BellSouth states that line number assignments will be made to all payphone providers on a nondiscriminatory basis. BellSouth states that it will not reserve a pool of numbers for its own operations, but will assign numbers in the 8000-9000 range on request "'whenever possible,' i.e., if the number is available." Moreover, BellSouth states that it is not required to reallocate numbers lawfully assigned under prior regulation. 64. The Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to reallocate existing number assignments. BellSouth represents that it will assign payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by BellSouth in the context of this CEI plan. 5. Uncollectibles 65. AT&T asserts that BellSouth must explain its treatment of uncollectibles due to fraud. AT&T contends that to the extent BellSouth establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be accorded to non-affiliates, regardless of whether such practice appears in BellSouth's tariffs. 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 the review of BellSouth's CAM. 6. Operator Services 66. APCC contends that BellSouth's CEI plan fails to address whether BellSouth's intraLATA operator services are part of its deregulated payphone services, or whether BellSouth considers such services to be severable services that are not "ancillary" to its payphone service. APCC argues that if operator services are part of BSPC's deregulated payphone service, BellSouth should explain whether BSPC is providing such services in the payphone by reselling network-based operator functions. In addition, APCC states that BellSouth should be required to identify the network functions supporting such services and to indicate how those same functions will be offered to PSPs on a nondiscriminatory basis. APCC argues that if operator services are separable regulated services that are not "ancillary" to BSPC's deregulated payphone service, BellSouth must ensure that it does not discriminate between BSPC and other PSPs in the provision of such services. For example, APCC states that if BellSouth is offering a commission to BSPC for presubscribing its payphones to BellSouth's operator service, such commissions must also be available to independent PSPs on the same terms and conditions. 67. Operator services are regulated services. Because BellSouth must offer such services to affiliated and unaffiliated PSPs on a nondiscriminatory, tariffed basis, BellSouth's CEI plan is not deficient because it does not address whether BellSouth considers operator services to be part of its deregulated payphone service. We note that in the Reconsideration Order, the Commission declined to require LECs to make available on a nondiscriminatory basis, any commission payments provided to their own payphone divisions in return for presubscription of operator service traffic to the LEC, because the Commission concluded that the level of 0+ commissions paid pursuant to contract on operator service calls was beyond the scope of section 276 and the Payphone proceeding. 7. Inmate Calling Services Issues 68. The Inmate Calling Service Provider Coalition (ICSPC) and AT&T raise a number of issues related to the provision of inmate calling services (ICS). Both ICSPC and AT&T contend that BellSouth should be required to identify the network support services its regulated operations will provide to its ICS operations. ICSPC also argues that BellSouth must disclose whether its regulated operations will provide its ICS operations with inmate call processing and call control functions and information for fraud protection, the validation of called numbers. ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. In addition, ICSPC asserts that BellSouth should be required to disclose whether its payphone operations will be responsible for the cost of ICS calls for which they are unable to collect. 69. ICSPC also asserts that BellSouth must show that any call processing and call control system used for its ICS is being provided on a deregulated basis, regardless of whether that system is located at a central office or at a customer premises. According to ICSPC, to the extent BellSouth's call processing and call control systems dedicated to ICS are located in BellSouth's central offices, BellSouth must provide physical or virtual collocation to other providers. ICSPC also contends that BellSouth must disclose information on interfaces between BellSouth's equipment dedicated to ICS and its regulated network support services, so that other providers can utilize the same interface if they wish. 70. In response to ICSPC's arguments, BellSouth notes that in its general description of the services covered by its CEI plan, BellSouth stated that "'payphone service' as used in [the] Plan means . . . the provision of inmate service in correctional institutions." Thus, BellSouth asserts that since "[t]he entire Plan speaks to inmate service," ICSPC's arguments about the unique characteristics of payphone services, such as call control and call processing, become immaterial. 71. In a subsequent ex parte filing, ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations because collect calling is fundamental to ICS. According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its network-based operator services division for processing and that division assumes the responsibility and risk associated with billing and collecting for those calls, the BOC is essentially providing ICS as a regulated service and is still subsidizing that service contrary to the prohibition in section 276. 72. In a subsequent ex parte, BellSouth provided additional information about how BSPC will conduct its payphone operations after April 1, 1997. According to BellSouth, BSPC will purchase the same network services that are available to any other PSP from BellSouth's General Subscriber Services Tariff. BellSouth represents that the CPE located at the location provider's premises will be used to perform operator functions, call control, validation, call rating and recording. BellSouth states that billing and collection functions will be performed through an industry clearinghouse. In addition, BellSouth represents that BSPC will be at risk for fraud and uncollectibles as any other independent inmate service provider. 73. Section 276 specifically defines payphone service to include the provision of inmate telephone service in correctional institutions. In the Reconsideration Order, we clarified that the requirements of the Payphone Order apply to inmate payphones that were deregulated in an earlier order. Thus, BellSouth is required to reclassify all of its payphone assets related to its provision of ICS, with the exception of the loops connecting the inmate telephones to the network, the central office "coin service" used to provide the ICS, and the operator service facilities used to support the ICS. In addition, BellSouth is required to offer on a tariffed basis any basic payphone service or network feature used by its payphone operations to provide ICS. 74. We conclude that BellSouth's CEI plan comports with our CEI requirements with respect to its provision of ICS. BellSouth represents that BSPC will purchase the same network elements that are available to any independent payphone service provider pursuant to tariff. Although we agree with ICSPC that any call processing and call control equipment related to BellSouth provision of ICS must be reclassified as nonregulated, regardless of whether that equipment is located in a customer premises or a BellSouth central office, BellSouth represents that it has done so. We find no support in the Payphone Order or Reconsideration Order for ICSPC's contention that BellSouth must provide collect calling as a nonregulated service when used with inmate payphones. 75. 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 BellSouth to allow for 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 BellSouth's CAM. Finally, with regard to the disclosure of interface information, we have already concluded that BellSouth's CEI plan comports with the Commission's network information disclosure requirements. 8. Primary Interexchange Carrier Selection 76. Oncor asserts that in order for BellSouth's CEI plan to comply with the "spirit" of the Commission's CEI requirements, the plan must address various issues concerning the payphone PIC selection process. AT&T also asserts that BellSouth's CEI plan should describe how BellSouth will ensure that the PIC selection process for payphones will be performed on a nondiscriminatory basis. In addition, Oncor also alleges that BellSouth "has been actively engaged in efforts" to contract with payphone location providers regarding the selection of interexchange carriers from BellSouth payphones in violation of the Payphone Order, which only allows a BOC to engage in such negotiations after receiving approval for its CEI plan. 77. In its reply comments, BellSouth states that its CEI plan addresses how it will provide interconnection to other payphone providers because that is to whom BellSouth's CEI obligations run, pursuant to the Commission's orders. According to BellSouth, "Oncor's concerns and allegations regarding the 'integrity of the payphone PIC selection and ordering process' are out of place in this proceeding and are not relevant to BellSouth's satisfaction of its CEI obligations toward payphone providers." 78. We conclude that BellSouth is not required as part of the CEI process to demonstrate how it will administer the PIC selection process for payphones. In the Payphone Order, the Commission specified that a BOC's CEI plan must describe how it will conform to the CEI parameters with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. The payphone rulemaking proceeding, however, did not require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as argued by AT&T and Oncor. Therefore, arguments raised by parties regarding BellSouth's role as PIC administrator are beyond the scope of this proceeding. 79. With respect to the issue of whether BellSouth has been engaging in negotiations with location providers regarding the selection of interexchange carriers prior to receiving CEI approvals, we note that this appears to be the same issue that was addressed in the Reconsideration Order regarding BellSouth's activities. In responding to comments about BellSouth's activities, the Commission concluded in the Reconsideration Order that "contracts entered into pursuant to the grant of authority in section 276(b)(1)(D) and prior to a BOC receiving approval of a CEI plan required by the Report and Order are in violation of the Commission's rules adopted in this proceeding." The Commission noted, however, that it could not ascertain whether the agreements entered into prior to the completion of these requirements were negotiated in a manner consistent with these policies. Consequently, the Commission stated that "[w]hile we are not in a position to declare null and void specific contracts that we have not determined to be unlawful, we will review any complaints concerning such contracts in light of this policy." Based on the Commission's determination in the Reconsideration Order, we conclude that concerns about BellSouth's engaging in improper negotiations are beyond the scope of this CEI proceeding. 9. Call Rating 80. APCC contends that BellSouth must provide a coin line service that allows independent PSPs to set their own end user rates for intraLATA calls. APCC asks the Commission to require BellSouth to refile its CEI plan with a more flexible rating feature for its coin line service. 81. The Payphone Order did not require the BOCs to provide to independent PSPs an unbundled call rating feature for coin line services. In addition, on reconsideration of the Payphone Order, in response to a request that the Commission require access to, inter alia, call rating capabilities, the Commission specifically declined to require further unbundling of payphone services beyond those established in the Payphone Order. As previously noted, independent PSPs may seek additional unbundling through the 120-day ONA process. The appropriate state regulatory authorities may also impose further unbundling requirements. 10. Selection of Operator Services Provider 82. APCC asserts that BellSouth's CEI plan is inconsistent with section 276, because BellSouth's illustrative tariff states that BellSouth's operator system will handle 0- intraLATA toll calls and 0+ local calls for its coin line services. APCC requests the Commission to require BellSouth to refile its CEI plan in conformance with the Commission's requirements on operator service providers. We conclude that APCC's request goes beyond the scope of this proceeding, which is limited to determining whether BellSouth's CEI plan complies with the Commission's Computer III CEI requirements. 11. Valuation 83. Both APCC and ICSPC assert that BellSouth has not provided any information about how it will perform the fair market valuation of its payphone assets as required by the Commission's affiliate transactions rules. According to APCC and ICSPC, "[t]he Commission has ruled that if a LEC chooses to provide its deregulated payphone services through a separate affiliate, then when the LEC transfers its ICS assets, the transfer must be recorded on the books at the higher of fair market value or net book cost, under Section 32.27 of the Commission's Rules." APCC and ICSPC contend that BellSouth's CEI plan, tariff filing, and CAM omit any discussion of asset valuation. 84. In reply, BellSouth states that the claims of APCC and others are "irrelevant to this CEI plan compliance review." BellSouth represents that it will comply with the requirements for the valuation of transferred assets established by the Commission in the payphone orders. In the Payphone Order, the Commission established the accounting requirements that the LECs must follow in transferring or reclassifying payphone assets from regulated to nonregulated status. We agree with BellSouth that a determination of whether such transfers adhere to the proper accounting requirements is beyond the scope of the CEI plan review. Such matters are better addressed in the context of reviewing BellSouth's CAM filings. 12. Separate Affiliate 85. SPCC contends that BellSouth's CEI plan fails to provide sufficient information about the "exact nature of [BellSouth's] proposed relationship with its new subsidiary, BSPC." SPCC raises questions about the corporate structures of BellSouth and BSPC and the type of joint activities that the two will be engaged in. In reply, BellSouth states that under the Commission's nonstructural safeguards, BellSouth is not obligated to operate its payphone business through a separate entity. According to BellSouth, the nonstructural safeguards presume that there may be extensive integration of operations between the regulated and nonregulated components of a company, as long as the nondiscrimination and accounting safeguards are met. BellSouth represents that transactions between itself and BSPC will be subject to the affiliate transaction rules and subject to audit. 86. We conclude that for purposes of the CEI review process, BellSouth is not required to provide further information about its dealings with BSPC. BellSouth is not relying on the existence of a separate affiliate as a means of showing compliance with any of the CEI requirements discussed above. As BellSouth has indicated, the nonstructural safeguards discussed in this order envision a certain amount of integration between the regulated and nonregulated arms of the same company. Thus, for CEI purposes we do not require further information about BSPC. We note, however, that in its dealings with BSPC, Bellsouth must follow the necessary accounting requirements. 13. Benchmarking 87. APCC asserts that because Ameritech offers an anticrime service -- Restricted Coin Access -- BellSouth should offer this unbundled service also. According to APCC, the "Commission should 'benchmark' the unbundled services offered by one LEC against those offered by another." In response, BellSouth states that APCC's claim "is not supported by the Commission's CEI requirements." According to BellSouth, the Commission's CEI requirements "establish only that the tariffed services provided by [BellSouth] to its own payphone operation or affiliates be available to other payphone providers." 88. We conclude that APCC's claims are not relevant to our determination of whether BellSouth's CEI plan for payphone services meets our CEI requirements. The payphone rulemaking proceeding required the BOCs to provide basic payphone services to support smart, dumb, and inmate payphone operations, including unbundled network features they provide to others and that are taken by their payphone operations. Neither the payphone rulemaking proceeding nor our CEI requirements mandate that one BOC provide certain unbundled services solely because they are offered by another LEC. V. CONCLUSION 89. We conclude that BellSouth's CEI plan complies with the Computer III requirements. We also grant BellSouth a waiver of the testing requirement for the provision of its PTAS and SmartLine services as described above. Accordingly, in this Order, we approve BellSouth's CEI plan to offer payphone service, as described herein. VI. ORDERING CLAUSE 90. IT IS HEREBY ORDERED that, pursuant to Sections 1, 4(i) and (j), 201, 202, 203, 205, 218, 222, and 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 BellSouth's Comparably Efficient Interconnection Plan for Payphone Service IS APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger, Jr. Deputy Chief, Common Carrier Bureau