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A. 1. a.(1)(a) i) a) 1 .1 .1 .1 .1 .1 .1 .1 Technical2^$!")##a1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . a6TechnicalTechnical Document Style)D (a) . a2TechnicalTechnical Document Style<6  ?  A.   2%'$7%%&a3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   a1TechnicalTechnical Document StyleF!<  ?  I.   a7TechnicalTechnical Document Style(@D i) . 2y-W'3')e-a8TechnicalTechnical Document Style(D a) . Doc InitInitialize Document Stylez   0*0*0*  I. A. 1. a.(1)(a) i) a) I. 1. A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:"(#v 1 XUII. BACKGROUND p>"(#v 3 XUIII. SERVICE DESCRIPTION p>"(#v 6 XUIV. COMPLIANCE ISSUES p!(#p 11  X"-XX` ` A.` ` CEI Plan Requirements ` p!(#p 11  X#-XX` ` B.` ` Other Nonstructural Safeguards ` p"(#s 47  Xh$-XX` ` C.` ` Accounting Safeguards ` p"(#s 55  XQ%-XX` ` D.` ` Other Issues ` p"(#s 56 XUV. CONCLUSION p"(#s 89 XUVI. ORDERING CLAUSE p"(#s 90"(,))ZZ'"Ԍ  X-M- I. INTRODUCTION ă  X-1. ` ` On November 22, 1996, pursuant to the requirements of the Commission's  X-orders in the payphone rulemaking proceeding,- yO- ԍXImplementation of the Pay Telephone Reclassification and Compensation Provisions of the  yO- zTelecommunications 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 and  yOu- United States, Case No. 961394 (D.C. Cir., filed Oct. 17, 1996), Erratum (rel. Sept. 27, 1996), recon.,  yO= - FCC 96439 (rel. Nov. 8, 1996) (Reconsideration Order); Order, DA 97678 (Common Carrier Bur. rel.  yO -Apr. 4, 1997) (Clarification Order).(#- BellSouth Corporation (BellSouth) filed a  X-comparably efficient interconnection (CEI) plan for payphone service.@ yO~ - ԍXBellSouth Comparably Efficient Interconnection Plan for Payphone Services (filed Nov. 22, 1996) (BellSouth CEI Plan).(#ƺ In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan  X_-describing how it will comply with the Commission's Computer III4 _ yO- =ԍXAmendment of Section 64.702 of the Commission's Rules and Regulations, CC Docket No. 85229, PhaseI,  yOp- 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987) (Phase I Reconsideration Order),  yO8- kfurther recon., 3 FCC Rcd 1135 (1988) (Phase I Further Reconsideration Order), second further recon., 4  yO- .FCC Rcd 5927 (1989) (Phase I Second Further Reconsideration), Phase I Order and Phase I Reconsideration  yO- Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir. 1990) (California I); Phase II, 2 FCC Rcd 3072  yO- (1987) (Phase II Order), recon., 3 FCC Rcd 1150 (1988) (Phase II Reconsideration Order), further recon.,  yOX- 4 FCC Rcd 5927 (1989) (Phase II Further Reconsideration Order), PhaseII Order vacated, California I, 905  yO - F.2d 1217 (9th Cir. 1990); Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA Remand  yO- Order), recon., 7 FCC Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir.  yO- z1993) (California II); Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier1  yOx- /Local Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order), recon. dismissed  yO@- in part, 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. denied,  yO-115 S.Ct. 1427 (1995) (referred to collectively as the ComputerIII proceeding).(#4 CEI equal access  XH-parameters and nonstructural safeguards for the provision of payphone services.[HP yOI-ԍXPayphone 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 BOCs' own payphone operations to  X -provide payphone services.d  yO!-ԍXSee id. at paras. 146, 200204.(#d  X -2. ` ` The Commission issued a public notice of BellSouth's CEI plan on November  X -27, 1996.( p yO%- >ԍXPleading Cycle Established for Comments on BellSouth's Comparably Efficient Interconnection Plan for  yO&-Payphone Service Providers, Public Notice, CC Docket No. 96128, DA 962005, released Nov. 27, 1996.(#( On December 30, 1996, six parties filed comments opposing the plan. x  yO- ԍXComments of the American Public Communications Council (APCC Comments); AT&T's Comments On  LBellSouth's Comparably Efficient Interconnection Plan (AT&T Comments); Comments of the Competitive  yTelecommunications Association (CompTel Comments); Comments of the Inmate Calling Service Providers  Coalition (ICSPC Comments); Comments of Oncor Communications, Inc. (Oncor Comments); and  Comments of the Southeastern Public Communications Coalition to BellSouth's Proposed CEI Plan (SPCC  Comments). APCC filed an errata to its comments on December 31, 1996. ICSPC filed an errata to its comments on December 31, 1996.(#  BellSouth" ,-(-(ZZ " submitted reply comments on January 15, 1997. For the reasons discussed below, we approve BellSouth's CEI plan.  X- 1II. BACKGROUND ׃  X-3. ` ` The payphone rulemaking proceeding implemented section 276 of the  Xv-Communications Act of 1934, as amended.# v yO/- ?ԍX47 U.S.C.  276. Telecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56 (1996 Act),  yO-  codified at 47 U.S.C.  151 et seq. Hereinafter, all citations to the 1996 Act will be to the 1996 Act as  it is codified in the United States Code. The 1996 Act amended the Communications Act of 1934. We will refer to the Communications Act of 1934, as amended, as "the Communications Act" or "the Act."(## Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC that provides payphone service: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access  X -service operations; and (2) shall not prefer or discriminate in favor of its payphone service.U   yO-ԍX47 U.S.C.  276(b)(1)(C).(#U The 1996 Act provided that such safeguards must, at a minimum, include the nonstructural  X -safeguards adopted in the Computer III proceeding.U  yO-ԍX47 U.S.C.  276(b)(1)(C).(#U  X -4. ` ` In the Payphone Order, the Commission determined that the Computer III and  X -Open Network Architecture (ONA) x  yOh- !ԍXSee Filing and Review of Open Network Architecture Plans, 4 FCC Rcd 1 (1988) (BOC ONA Order),  yO0- krecon., 5 FCC Rcd 3084 (1990) (BOC ONA Reconsideration Order); 5 FCC Rcd 3103 (1990) (BOC ONA  yO- Amendment Order), erratum, 5 FCC Rcd 4045, pets. for review denied, California v. FCC, 4 F.3d 1505 (9th  yO- Cir. 1993), recon., 8 FCC Rcd 97 (1993) (BOC ONA Amendment Reconsideration Order); 6 FCC Rcd 7646  yO - !(1991) (BOC ONA Further Amendment Order); 8 FCC Rcd 2606 (1993) (BOC ONA Second Further  yOP!-  Amendment Order), pet. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (collectively  yO"-referred to as the ONA Proceeding).(# nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or crosssubsidize in their  Xy-provision of payphone service." XyP yOz%- ԍXPayphone Order at para. 199. In addition, the Commission subsequently adopted accounting safeguards  yOB&- /for BOC and incumbent LEC provision of payphone service on an integrated basis. See Implementation  >of the Telecommunications Act of 1996: Accounting Safeguards Under the Telecommunications Act of" ' ,-(-(-'"  yO- 1996, CC Docket No. 96150, Report and Order, FCC 96490, para. 100 (rel. Dec. 24, 1996) (Accounting  yOX-Safeguards Order).(#ƒ Accordingly, the Commission required the BOCs to file"y  ,-(-(ZZi"  X-"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  X-nondiscrimination requirements."#   yO- ԍXPayphone 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  krequirements would remain in effect, pending the outcome of that rulemaking, to extent that they do not  yO - conflict with the CPNI provisions of the 1996 Act. See Implementation of the Telecommunications Act  {of 1996: Telecommunication Carriers' Use of Customer Proprietary Network Information and Other  yOt -Customer Information, CC Docket No. 96115, 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  Xv-in the payphone proceeding.v yO- yԍXReconsideration Order, at para. 132. In addition to an approved CEI plan, in order to receive compensation,  yO- the Reconsideration Order requires that "a LEC must be able to certify the following: (1) it has an effective  zcost accounting manual ("CAM") filing; (2) it has an effective interstate CCL tariff reflecting a reduction  zfor 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  yOo- kcustomer premises equipment ("CPE") and related costs as required in the [Payphone Order]; (5) it has in  effect intrastate tariffs for basic payphone services (for "dumb" and "smart" payphones); and (6) it has in  yO- effect intrastate and interstate tariffs for unbundled functionalities associated with those lines." Id. at para. 131.(#  XH-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 instrumentimplemented 'smart payphones' or 'dumb'  X -payphones that utilize central office coin services,X 0 yO- ԍXA "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.(#ƃ or some combination of the two in a  X -manner similar to the LECs."b P yO -ԍXReconsideration Order at para. 162.(#b Those tariffs must be filed with the applicable state regulatory  X -commission.C  yOf#-ԍXId. (#C 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. p yO&-ԍXPayphone Order at paras.146148; Reconsideration Order at paras. 162163; Clarification Order at para. 8. (#Ƶ " ,-(-(ZZ "Ԍ X-ԙ III. SERVICE DESCRIPTION  X- 6.` ` BellSouth will conduct its payphone operations through a corporate entity that  X-is distinct from its basic service operations.I yO4-ԍBellSouth CEI Plan at 3.I 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  Xv-basic services and the entity to whom the CEI obligations attach.:vX yO -ԍId.:  XH-7.` ` BellSouth states that it offers two payphone services 1) Public Telephone Access Service for customer premises equipment (CPE) (PTAS); and 2) SmartLine Service  X -for Public Telephone Access (SmartLine).@  yO-ԍId. at 5.@ 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.  X -8.` ` The PTAS service is a local exchange service provided for use with customer provided coinoperated or noncoinoperated public telephones that are frequently referred to as  X-"smart sets."@x yO-ԍId. at 5.@ According to BellSouth, the PTAS is a standard Dial Tone First (DTF)  Xy-exchange line service that is offered on a twoway or outwardonly basis.y yO2- MԍXSee Letter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth, to William F. Caton,  yO-Acting Secretary, FCC, filed March 7, 1997, at 3 (BellSouth March 7 Ex Parte).(# For PTAS, BellSouth provides the carriage and completion of all local dialed calls, including operator  XK-service functions. :K`  yO\-ԍId.: The service may be offered as a flat rate or measured local service,  X4-depending upon the jurisdiction.:4  yO-ԍId.: BellSouth states that billed number screening is a  X-mandatory feature associated with its PTAS service.X  yON!- ԍXId. Billed number screening prevents calls made from phones being billed to the payphone (e.g., collect  calls to the payphone, calls charged to third party numbers, etc.). Letter from Michael K. Kellogg to Mary  yO"-Beth Richards, Deputy Bureau Chief, Common Carrier Bureau, FCC filed March 25, 1997 at 2.(#ƭ Various central office blocking and  X-operator screening options are also available with PTAS.X yOW%- ԍXBellSouth March 7 Ex Parte at 3. These blocking options include blocking of 1+DDD, 10XXX 011+,  yO&- 101XXXX011+, and 7 digit local calls. Id. The screening option enables screening information to be sent  yO&-to the operator to prevent operator assisted sentpaid calls from being billed to the line. Id. (#Ƹ BellSouth states that it will also",-(-(ZZF"  X-provide central office blocking of 900, 976, and N11 calls placed from payphone sets.: yOy-ԍId.: PSPs  X-may also obtain international call blocking for PTAS from BellSouth's federal tariff.:X yO-ԍId.:  X- BellSouth offers answer supervision as an optional feature for PTAS service in Florida only.8 yOk- ԍXSee id. and Letter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth, to William  yO3-Caton, Acting Secretary, FCC, filed March 20, 1997, Attachment at 3 (BellSouth March 20 Ex Parte).(#8  X-BellSouth represents that an operator cannot perform coin control functions on a PTAS line.I@ yO -ԍBellSouth CEI Plan at 5.I According to BellSouth, tariffs for its PTAS service have been in effect in all of its states  X-since 1985.:  yO-ԍId.:  X_-9.` ` BellSouth states that its SmartLine service is a standard DTF coin line for  XH-customerprovided pay telephones that are commonly referred to as "dumb sets.":!H`  yOY-ԍId.: According  X1-to BellSouth, this service can be provided on a twoway or an outwardonly basis.:"1  yO-ԍId.: SmartLine service may be offered as a flat rate or measured local service, depending upon the  X -jurisdiction.W#  yO4-ԍBellSouth March 7 Ex Parte at 2.W The SmartLine service will be provided on a DTF basis to allow end users to  X -dial certain calls without requiring coin deposits e.g., 911, local directory assistance, and  X -nonsent paid calls.:$  yO-ԍId.: BellSouth will provide central office blocking of 900, 976, and N11  X -calls.:%  yO-ԍId.: 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  X-treatment; (2) billed number screening; and (3) coin signaling (coin collect and coin return). &0 yOq!- ԍXId. Coin collect is used when a call has been completed and coin return is used if a call is not completed  yO9"-because the called number is not answered or is busy. Id.(#  BellSouth's operator system will handle 0intraLATA toll calls and 0+ local calls from  Xb-SmartLine Service lines.:'b yO%-ԍId.: All 10XXX 0+ or 101XXXX 0+ dialed intraLATA toll calls will"b',-(-(ZZ"  X-be routed to the dialed carrier.:( yOy-ԍId.: As with the PTAS service, international call blocking is  X-available through the BellSouth federal tariff.:)X yO-ԍId.: According to BellSouth, state tariffs for its  X-SmartLine service are in effect in all of BellSouth's states.K* yOk-ԍBellSouth CEI Plan at 56.K  X- 10.` ` BellSouth also lists additional services that will be available to all PSPs. These  X-are local usage detail and coin refund and repair referral service.+x yO - /ԍXId. at 6. Local usage detail is provided for use with BellSouth's usage based local calling plans. BellSouth  yO~ - zMarch 20 Ex Parte, Attachment at 3. With coin refund and repair referral service, BellSouth will receive  \end user claims on behalf of the independent PSP of coins lost within a set or accept notifications of sets  yO- in need of repairs. Id. BellSouth will then issue customer credits or refunds, or inform the independent  yO-PSP of the repair need as appropriate. Id. (#Ƣ ` `  XH- IV. COMPLIANCE ISSUES ă  X - A. CEI Plan Requirements  X - 11. ` ` 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- ԍXSee 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  koffer 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 enhanced service  providers; and (3)how the BOCs would comply with the other nonstructural safeguards imposed by  yO-ComputerIII. See Phase I Order, 104 FCC 2d at 103459, paras. 142200.(#Ƒ As applied in the payphone context, the CEI requirements are designed to give independent PSPs equal and  X-efficient access to the regulated basic payphone services that the BOCs use to provide their  Xy-own payphone services.o-y yO"#-ԍXSee Payphone Order at paras. 146, 200204.(#o BOCs also must provide payphone services to independent PSPs on  Xb-a nondiscriminatory basis as required in the payphone rulemaking proceeding.q.b yO%-ԍXSee Reconsideration Order at paras. 163165.(#q The"b.,-(-(ZZ"  X-Commission, in its Computer III proceeding, established nine specific CEI requirements,v/ yOy-ԍXPhase I Order, 104 FCC 2d at 10391043, paras. 154166.(#v 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.  X- 1. Unbundling of Basic Services  Xv-  X_- 12.` ` The Payphone Order deregulated LEC payphones and classified those  XH-payphones as CPE.[0HX yOQ -ԍXPayphone 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 tariff unbundled payphone features  X -that the LEC uses or provides on an unbundled basis.1  yO-ԍXId. at paras. 146148; Reconsideration Order at paras. 162163; Clarification Order at para. 8. (#ƫ Moreover, BOCs, but not other LECs, must unbundle additional network elements when requested by payphone providers based on  X -the specific criteria established in the Computer III and ONA proceedings.2 x yO-ԍXPayphone Order at 148; Reconsideration Order at para. 165.(#  X - 13.` ` The Payphone Order requires BOCs to file CEI plans that explain how they  X-will unbundle basic payphone services.[3 yOI-ԍXPayphone 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  Xb-service functions that underlie its provision of payphone service.4b yP-ԍX#c P7 wP#Id. (citing Phase I Order, 104 FCC 2d at 1040). See also Reconsideration Order at para. 213 .(# Nonproprietary information used by the BOC in providing the unbundled basic services must be made  X4-available as part of CEI.54)  yP-ԍ#c P7 wP#Payphone Order, at para. 204 (citing Phase I Order, 104 FCC 2d at 1040). In addition, any options available to the BOC in the provision of  X-such basic services or functions must be included in the unbundled offerings.6  yO -ԍId. See also Reconsideration Order at para. 213 (citing Phase I Order at 1040, para. 158).   X- 14.` ` According to SPCC, BellSouth's description of its plan to unbundle its  X-payphone line access services is inadequate.E7J  yO$-ԍSPCC Comments at 10.E SPCC states that although BellSouth's plan describes the payphone line access it intends to provide to payphone providers, the plan fails  X-to offer any information concerning the constituent elements of payphone line access or the"7,-(-(ZZ"  X-service which is currently provided to its own payphone operations.E8 yOy-ԍSPCC Comments at 11.E SPCC asserts that if BellSouth does not disclose the services to which it currently subscribes or the constituent  X-elements of the service, the Commission cannot evaluate whether BellSouth has sufficiently  X-unbundled its service offerings.:9X yO-ԍId.: Both APCC and SPCC contend that the BOCs must  X-unbundle and tariff the features that they provide to their own payphone services.\: yO= -ԍAPCC Comments at 8 and SPCC Comments at 12.\ APCC further argues that BellSouth must tariff "the basic payphone line" separately from network  Xv-services and unbundled features.D;vx yO -ԍAPCC Comments at 8.D  XH-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  X -state tariff.F<  yO-ԍBellSouth Reply at 8.F According to BellSouth, "there are no payphonespecific, networkbased, unbundled features and functions provided to others or taken by BellSouth's payphone  X -operations that are tariffed by BellSouth at the intrastate level."&=   yO5- \ԍXLetter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth to William Caton, Acting  yO- Secretary, FCC, filed April 9, 1997 (BellSouth April 9 Ex Parte). BellSouth notes, however, that it will  yO- file a federal tariff for answer supervision for Florida, pursuant to the requirements of the Clarification  yO-Order. Id. See also infra at Section IV.A.7.(#&  X -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  Xy-payphone services using smart, dumb, or inmate payphones.S>y  yO-ԍPayphone Order at para. 146.S 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  X4-payphone operations.Z?4 yO!-ԍReconsideration Order at para. 146.Z BellSouth's plan, as supplemented, satisfies these requirements. We note, however, that BellSouth may choose to unbundle additional payphonespecific features  X-and functions, the states may require further unbundling, or independent PSPs may request" ?,-(-(ZZF" additional unbundled features and functions through the ONA 120day service request  X-process.\@ yOy-ԍClarification Order at para. 8. n.23.\ Any networkbased, payphonespecific features and functions offered on an unbundled basis must comply with the tariffing and CEI requirements of the payphone  X-proceeding, Computer III, and ONA. ` `  X-17. ` ` We reject APCC's contention that BellSouth must unbundle the "'basic  Xv-payphone line' separately from network services and unbundled features."JAvo yO-ԍAPCC Comments at 8. J As noted in the  X_-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  X1-unbundled basis."B1 yO -ԍXClarification Order at para. 16 (citing Payphone Order at para. 148; Reconsideration Order at para. 165).(#ƴ 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  X -state and federal jurisdictions.C  yO- ԍXClarification 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 an enhanced  yOV- service provider may require or find useful in configuring its enhanced service. Id. at para. 17 (citing Filing  yO- and Review of Open Network Architecture Plans, Phase I, Memorandum Opinion and Order, FCC 88381,  yO- 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  yO>- services that other LECs call features and functions. The 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  yO- {payphone line (state tariff), or separately on an unbundled basis (federal and state tariffs)." Id. (citing  yO^- MApplication of Open Network and Nondiscrimination Safeguards to GTE Corporation, 11 FCC Rcd 5558 (1995)). (# 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  X-unbundled basis to itself or to others.`DG yO -ԍXPayphone Order at paras. 146148.(#` Independent payphone providers may seek further  Xy-unbundling by making a request pursuant to the ONA process.PEy yO#-ԍXId. at para. 148.(#P  Xb-  XK-  "t   X4-  X-" gE,-(-(ZZ)"Ԍ X- "t 2.` ` Interface Functionality  X-18.` ` 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.F yP-Ѝ#c P7 wP#Id. at paras. 20203; Phase I Order, 104 FCC 2d at 1039, para. 157.  Xv-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  XH-payphone services.IGHY yOR -ԍBellSouth CEI Plan at 4.I We find that BellSouth's CEI plan comports with the interface functionality requirement established by the Commission.  X -   X - 3. Resale  X -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 costshifting to regulated  X-operations and anticompetitive pricing in unregulated markets."H yP*-Ѝ#c P7 wP#Phase I Order, 104 FCC 2d at 1040, para. 159. Based on the requirement in  Xy-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  XK-on a nondiscriminatory basis to other payphone providers.}IKz yOv-ԍPayphone Order at para. 200; Reconsideration Order at para. 211.}  X-21.` ` BellSouth represents that BSPC will "subscribe to the tariffed services at the  X-same tariffed rates as any other subscriber to these services."IJ  yO-ԍBellSouth CEI Plan at 6.I We find that BellSouth has met the resale requirement. "t   X- 4. Technical Characteristics  X-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  Xe-payphone services.Ke yP$- ЍXPayphone Order at paras. 199207; Reconsideration Order at paras. 218220; and #c P7 wP#Phase I Order, 104 FCC 2d at 1041, para. 160.(# "N K,-(-(ZZ"Ԍ X-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  X-characteristics of those services.KL yOK-ԍBellSouth CEI Plan at 67.K We find that BellSouth's CEI plan comports with the technical characteristics requirement established by the Commission.  X- 5. Installation, Maintenance, and Repair  X_-24.` ` The Payphone Order requires BOCs to describe in their CEI plans how they  XH-will comply with the nondiscrimination requirements in Computer III and ONA regarding the  X1-quality of service, installation, and maintenance.SM1X yO: -ԍPayphone Order at para. 207.S This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in  X -a CEI offering to unaffiliated PSPs are the same as those the carrier provides to its own or its  X -affiliated payphone service operations.N  yP-ЍId. at para. 203; #c P7 wP#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.O y yP- ЍX#c P7 wP#The Payphone Order does not impose any new continuing reporting requirement because BOCs are already  xP- subject to reporting requirements pursuant to Computer III and ONA. BOCs must report on payphone  xP- services as they do for basic services. Phase I Order, 104 FCC 2d at 1041, para.161. BellSouth must  xPX- provide quarterly reports on installation and maintenance of its basic services. Id. at 10551056, paras.  xP -192193. (#Ƴ  X -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  Xy-all service and maintenance requests will be processed through the same systems.JPy*  yOT-ԍBellSouth CEI Plan at 11.J According  Xb-to BellSouth, its payphone operations will be subject to the same scheduling procedures and  XK-time periods, as any other PSP.@QK  yO-ԍId. at 7.@ BellSouth notes that its Private Payphone Provider  X4-Handbook, which it provides to PSPs, contains a description of its service order procedures,  X-installation procedures and schedules, and repair procedures.ARJ  yO"-ԍId. at 11.A BellSouth represents that BSPC has its own field service personnel who install, repair, and maintain BSPC's payphone  X-sets and ancillary equipment, and, therefore, BellSouth will only provide tariffed access lines  X-and services to BSPC on the same terms and conditions as provided to other PSPs.AS yOc&-ԍId. at 11.A " jS,-(-(ZZ"Ԍ X-26.` ` APCC argues that BellSouth's CEI plan does not provide sufficient detail about  X-how it will provide installation, maintenance, and repair.ET yOb-ԍAPCC Comments at 17.E 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  X-procedures.:UX yO-ԍId.: With respect to service order processing, APCC asserts that in the past independent PSPs have experienced difficulties when a location provider changes from a  Xv-BellSouth payphone to an independent PSP's payphone.DVv yO -ԍId. at 1920.D 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  X1-checking to see if the BellSouth payphone was under a contract.AW1x yOZ-ԍId. at 19.A According to APCC, disputes between BellSouth's payphone division and the location provider over whether an  X -existing contract remains in force should not prevent the connection of a new payphone.:X  yO-ԍId.:  X -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  X -payphones are replaced by independent PSP payphones.AY  yO-ԍId. at 20.A  X-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  Xb-performing installation, repair, and maintenance functions.BZb(  yO;-ԍId. at 18.B According to APCC, BellSouth's plan also is deficient because it fails to make clear whether it will follow nondiscriminatory  X4-practices with respect to the location of the demarcation point.:[4  yO-ԍId.: 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  X-access service.!\H  yO$- ԍXId. at 1819. APCC attaches to its comments a letter which APCC alleges shows that BellSouth may be  yO%-following an inconsistent policy regarding its demarcation point. Id. at Attachment 1.(#! According to APCC, the BellSouth Private Payphone Provider Handbook states that BellSouth will provide inside wiring installation and repair on a time and materials" \,-(-(ZZ"  X-basis to independent PSPs.A] yOy-ԍId. at 18.A APCC argues that BellSouth's CEI plan should state that  X-BellSouth will also charge BSPC for such installation and repair on a time and materials  X-basis.:^X yO-ԍId.:  X-28.` ` In its reply, BellSouth further clarifies that as a separate entity, BSPC's  X-personnel will contact the same BellSouth service center through the same channels of  Xv-communication that are available to other PSPs (i.e., same phone number and same fax  X_-number).G__ yO -ԍBellSouth Reply at 25.G BellSouth states that it has attached a current copy of its Private Payphone  XH-Provider Handbook to its reply.`XHx yOq- {ԍXId. at 25 n.70. BellSouth notes, however, that because the handbook is updated on a regular basis, it is  zprovided as an example, but is not incorporated into the plan, since modifications to the handbook might  yO-require approval as amendments to the CEI plan. Id.(#ƀ BellSouth represents that it will follow the procedures  X1-described in the handbook on a nondiscriminatory basis.Aa1 yOz-ԍId. at 25.A Further, BellSouth represents that  X -it will handle all displacement situations identically.Ab (  yO-ԍId. at 26.A According to BellSouth, lines ordered by any PSP, whether BSPC or any other, will be installed as ordered on a nondiscriminatory  X -basis.:c  yOU-ԍId.: 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  X -[BSPC] or independent payphone providers, in accordance with" the Payphone Order and the  X -Reconsideration Order.d H  yO- ԍXLetter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth, to William Caton, Acting  yOh-Secretary, FCC (filed April 1, 1997) (BellSouth April 1 Ex Parte).(#  Xy-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  XK-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  X-personnel who perform installation, repair, and maintenance functions.Me yOn$-ԍXAPCC Comments at 18.(#M BellSouth represents  X-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"0e,-(-(ZZE"  X-BSPC on the same terms and conditions as provided to other PSPs.Rf yOy-ԍXBellSouth CEI Plan at 11.(#R 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.  X - 6.` ` EndUser Access  X -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  X-users equal opportunities to obtain access to basic network facilities.gX yO-ЍXSee Phase I Order, 104 FCC 2d at 1041, para. 162; Payphone Order at para. 199.(#ƣ  Xb-31.` ` BellSouth represents that its payphone operations will purchase and utilize the  XK-same tariffed services available to all other PSPs.IhK yO-ԍBellSouth CEI plan at 7.I 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  X-PSPs.:ix yO/-ԍId.: We find that BellSouth's CEI plan comports with the enduser access requirement established by the Commission.  X-  "t 7.` ` CEI Availability  X-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"Ni,-(-(ZZ"  X-testing their payphone service offerings.j yOy- ԍXPhase 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 . . . services particularly,  their interconnection with the basic underlying facilities while withholding those same basic facilities  yOa-from others." Id.(# Past decisions also have referred to this as the 90 X-day notice requirement.k @ yO- zԍXSee, 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  yOj -  Interconnection to Providers of Voice Mail Messaging Service, CCBPol 9623, Order, DA 961894 (rel.  yO2 -Nov. 14, 1996) (Ameritech Minor Amendments).(#  X- 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  X_-others.al_(  yO8-ԍSee Clarification Order, at para. 8.a LECs are not required to file tariffs for the basic payphone line for smart and dumb  XH-payphones with the Commission.gmH  yO-ԍXReconsideration Order at paras. 162163.(#g As stated in the Clarification Order, LECs are required to file federal tariffs for payphonespecific, networkbased features and functions "only if the LEC provides them separately and on an unbundled basis from the basic payphone line, either  X -to its own payphone operations or to others . . . ."_n H  yO-ԍXClarification Order at para. 18.(#_  X -!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  X-tariffs for unbundled features and functions within 45 days of the release date of the  Xy-Clarification Order, with a scheduled effective date of no later than 15 days after the date the  Xb-tariff is filed.Xob yO -ԍClarification Order at paras. 21.X In addition, each BOC was required to file, by April 10, 1997, a written ex  XK-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  X-tariffs for such features and functions within 45 days of the release date of the Order.Gph yO6%-ԍId. at para. 22.G "p,-(-(ZZ("Ԍ X-"35.` ` BellSouth represents that tariffs for both its PTAS and SmartLine services are  X-in effect in all of its states.q yOb- ԍXBellSouth CEI Plan at 8. BellSouth represents that its PTAS service has been fully operational and available  yO*- in all of its states pursuant to tariff that have been in effect since 1985. Id. With respect to its SmartLine  service, BellSouth represents that tariffs for this service became effective in Mississippi in 1993; in  >Alabama, Florida, Georgia, Kentucky, North Carolina, and South Carolina in 1994; and in Tennessee and  yO-Louisiana in October and November of 1996. Id. at 6 n.10.(#Ɠ 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  X-potential payphone competitors for, in most cases, anywhere from two to eleven years.Irx yO -ԍBellSouth CEI Plan at 8.I Therefore, BellSouth maintains that payphone competitors have already had ample opportunity  X-to engage in any necessary testing.:s yOF -ԍId.: According to BellSouth, no purpose would be served by  Xv-now specially designating an additional time period for testing.:tv yO-ԍId.: BellSouth notes that in this  X_-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  X1-the facilities and functionalities listed in the tariffs.:u1(  yO -ԍId.: Therefore, BellSouth asserts that the  X -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  X -period.@v  yOU-ԍId. at 9.@  X -   X -#36.` ` According to APCC, BellSouth's CEI plan is deficient because it has not filed  X -any federal tariffs with its plan.Fw H  yO-ԍAPCC Comments at 67.F APCC claims that the only service LECs are not required  X-to tariff at the federal level is the basic payphone line for smart and dumb payphones.@x yO-ԍId. at 7.@  Xy-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  XK-representative of the rates charged throughout BellSouth's region.]yKh yOd#-ԍSPCC Comments at 67 and APCC Comments at 7.] Moreover, APCC asserts  X4-that the state tariffs that BellSouth did attach to its plan are not complete or uptodate.Dz4 yO%-ԍAPCC Comments at 7.D According to APCC, the Florida PTAS service tariff, which BellSouth attached as an"z,-(-(ZZ" illustrative tariff with its CEI plan, is not the most recent version, and many of the relevant  X-rates are crossreferenced to tariff pages that were not included in the CEI filing.{ yOb- =ԍXId.; see also SPCC Comments at 6 (asserting that the Florida tariff BellSouth attached as an illustrative tariff was amended more than a year and a half ago). (# APCC also notes that BellSouth's Florida SmartLine service tariff provides that the service "will be  X-provided from central offices where facilities are available."l|  yO-ԍAPCC Comments at 13 (quoting BellSouth's coin line tariff).l APCC asserts that BellSouth must disclose the areas in which SmartLine service is unavailable, and how many payphones  X-it has installed in such areas.A} yO -ԍId. at 14.A 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  X_-PTAS service.:~_@ yOP-ԍId.: Otherwise, APCC asserts that BellSouth would be in the position of  XH-providing SmartLine service to BSPC while claiming that it is unavailable to independent  X1-PSPs.:1 yO-ԍId.: AT&T argues that BellSouth should be required to amend its CEI plan to clarify that SmartLine service will be available to nonBellSouth PSPs at every central office where such  X -service is provided to BSPC.Z `  yO-ԍAT&T Comments at 34 and AT&T Reply at 4.Z 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  X -still appropriate, "once BellSouth has properly unbundled its services."E  yOv-ԍSPCC Comments at 17.E  X -$37.` ` BellSouth responds that APCC misreads the Commission's tariffing and  X-unbundling requirements.F  yO-ԍBellSouth Reply at 8.F 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  Xb-the states.:b yO# -ԍId.: Therefore, BellSouth states that there are no additional features or functions to  XK-be unbundled, and, therefore, there are no applicable federal tariffs.:K yO"-ԍId.: In responding to concerns about the deficiencies in the illustrative state tariffs, BellSouth concedes that a  X-portion of one of the submitted sample tariffs has been superseded.G0 yO%-ԍId. at 15 n. 40.G BellSouth, however,  X-represents that it has attached to its reply a "copy of the current tariff for both of [its",-(-(ZZ"  X-payphone] services in all of [its] states.": yOy-ԍId.: BellSouth also responds to concerns about its SmartLine service tariff offering being limited to central offices where facilities are  X-available.AX yO-ԍId. at 23.A BellSouth states that "BSPC will buy tariffed services subject to the same tariff  X-limitations as any other provider."A yOT-ԍId. at 24.A Thus, BellSouth represents that "in the handful of instances whereby [BellSouth] is currently offering payphone service using dumb sets out of  X-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  X_-providers.":_x yO -ԍId.:  X1-%38. ` ` We find that BellSouth's plan complies with the CEI availability  X -requirement.   yO- zԍXWe note that, because we are also relying on the states to review LEC tariffs for basic payphone services,  our conclusion that BellSouth has satisfied the CEI availability requirement does not represent a  determination that BellSouth's basic payphone services are tariffed in accordance with the requirements of  yO+-section 276. See also infra at Section IV.D.2.(# 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  X -SmartLine 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  X -operations or to others.`  yOH-ԍXClarification Order, at para. 18.(#` BellSouth represents that it will file federal tariffs, in accordance  X-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  Xb-private branch exchange (PBX) trunks.Rb  yO-ԍBellSouth April 9 Ex Parte.R We reject as well APCC's and SPCC's contention  XK-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  X-sufficient.eX yO"- ԍXSee Phase I Order, at 1055, para. 190 ("The CEI Plan must also include sample state and federal tariffs for  ythe Basic Interconnection Charge and the distancesensitive transmission charges that satisfy our CEI pricing requirements") (emphasis added).(#e 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. "0,-(-(ZZ'"Ԍ X-&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  X-provided. BellSouth's illustrative state coin line tariff provides that coin line service will be  X-provided where facilities are available.Z yO-ԍBellSouth CEI plan, Appendix B at A7.8.1.Z 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.   X1- '40. ` ` Finally we grant Bellsouth's request not to enforce the 90day 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  X -line and COCOT services for some time.S X yO-ԍXId. at 8 and 6 n.10.(#S 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,  X-BellSouth must make testing capability available to unaffiliated PSPs at the same time that  X-such capability is available to BellSouth.B yO-ԍXId.(#B  X-  X-8.` ` Minimization of Transport Costs  X-(41.` ` This requirement obligates carriers to provide competitors with interconnection  X|-facilities that minimize transport costs.|x yO -ԍPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.164.   XN-)42.` ` BellSouth represents that its payphone operations subscribe to the same tariffed  X7-services as other PSPs and that they are not collocated with BellSouth's basic network"7,-(-(ZZ"  X-services.I yOy-ԍBellSouth CEI Plan at 9.I Consequently, BellSouth states that there are no differences in transmission  X-costs.:X yO-ԍId.:  X-*43.` ` As a corollary to its general argument that the Commission should require  X-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  Xv-transport costs requirement.Dv yO -ԍSPCC Comments at 9.D 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  XH-PTAS rates, which SPCC contends are BellSouth's single line business rates in that state.:Hx yOq-ԍId.:  X1-SPCC asserts that such a reduction is consistent with BellSouth's Computer III obligation to  X -reduce transport costs to its competitors.s  yO-ԍId. (citing Phase I Order, 104 FCC 2d at 1042).s SPCC argues that the "principle of Computer III  X -requires BOCs to reduce transmission costs [in this instance, PTAS rates] to its competitors  X -where the BOCs' own interconnection [SmartLine] gives it an unfair cost advantage."@  yO5-ԍId. at 9.@  X -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  X -interconnect to the local network through SmartLine.": (  yO-ԍId.: BellSouth responds that "[t]he  X-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  Xb-charges all other service providers."b  yO- =ԍXBellSouth Reply at 19 (citing BellSouth Plan for Comparably Efficient Interconnection for Voice Messaging  yO-Services, 3 FCC Rcd 7284, para. 42 (1988). (#  X4-+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  X-enhanced service operations while not giving others the same access.d yO$-ԍPhase I Order, 104 FCC 2d at 1042, para. 164.d 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",-(-(ZZ" costs. Consequently, BellSouth's compliance with the minimization of transport costs  X-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.  X-  X- 9.` ` Recipients of CEI  X_-,45. ` ` This requirement prohibits a BOC from restricting the availability of its CEI  XH-offering to any particular class of customer or PSP.H yO -ԍPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.165.  X --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  X -customer for any lawful purpose.J X yO-ԍBellSouth CEI Plan at 10.J We find that BellSouth has proposed to provide service to CEI recipients in compliance with the Commission's requirements.  X -  X -B.Other Nonstructural Safeguards  X-  Xy-.47. ` ` In addition to the CEI requirements established in Computer III, and applied to  Xb-BOC provision of payphone services in the Payphone Order,b yO-ԍPayphone Order at para. 202. See also, Reconsideration Order at para. 210. a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network  X4-information (CPNI), disclosure of network information, and nondiscrimination reporting.g4x yO]-ԍPhase II Order, 2 FCC Rcd at 3082, paras.7375.g  X- 1.` ` Customer Proprietary Network Information  X-/48. ` ` The Payphone Order requires BellSouth to explain how it will comply with the  X-ComputerIII CPNI safeguards,n yOz-ԍSee Phase II Order, 2 FCC Rcd at 3095, para.156.n to the extent they are not inconsistent with section 222 of  X-the Communications Act, as amended. yO!-ԍPayphone Order, at para. 205 (citing 47 U.S.C.  222 and CPNI NPRM). 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  Xe-obligations under this provision._e(  yO>&-ԍCPNI NPRM, 11 FCC Rcd at 12514, para. 2._ The Commission has concluded that its existing CPNI"e ,-(-(ZZ1" regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they  X-do not conflict with section 222. yOb- kԍXId., at para. 3 (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-  X-049.` ` In its CEI plan, BellSouth represents that it will not disclose the CPNI of any  X-PSP to any other PSP, including BSPC, without the PSP's authorization.    yOu- LԍXBellSouth CEI Plan at 12. BellSouth represents that "CPNI related to the basic telecommunications services  kto which any payphone service provider subscribes is treated as "presumptively restricted" and will not be  available to or accessible by any other payphone service provider, including BellSouth's own operation,  yO -absent affirmative direction otherwise by the subscribing payphone service provider." Id.(#  According to BellSouth, aggregate CPNI will be made available to BellSouth's payphone service operation,  Xv-if at all, only pursuant to the conditions of section 222(c)(3) of the Communications Act, as  X_-amended.:_ yO-ԍId.: We find that BellSouth's plan comports with the CPNI requirements.  X  XH-  X1-2.` ` Network Information Disclosure (#`  X -150.` ` The Payphone Order requires BellSouth to disclose to the payphone services industry information about network changes and new network services that affect the  X -interconnection of payphone services with BellSouth's network.[  yO-ԍXPayphone Order at para. 206.(#[ BellSouth must make that disclosure at the "make/buy" point, that is, when BellSouth decides whether to make or to  X -procure from an unaffiliated entity any product whose design affects or relies on the network  X-interface.(  yPi-ԍ#c P7 wP#Phase II Order, 2 FCC Rcd at 3086, para. 102. 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  Xb-nondisclosure agreement.b  yP-ԍ#c P7 wP#Id. at 30913093, paras. 134140. BellSouth also must publicly disclose technical information about  XK-a new or modified network service twelve months prior to the introduction of that service.!KJ  yPF - |ԍX#c P7 wP#Id. 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 the public disclosure.(#  X-251.` ` 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  X-that payphone services are provided on a timely basis consistent with the other deregulatory"3,-(-(ZZ "  X-requirements of that order.S yOy-ԍPayphone Order at para. 146.S 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.JX yO-ԍSee id.J` `  X-352.` ` BellSouth states that it has previously made appropriate disclosure of interface  X-information related to the tariffed services covered by its payphone CEI plan.J yO& -ԍBellSouth CEI Plan at 12.J BellSouth  Xv-represents that it began offering its SmartLine service in 1993, and that it published its  X_-network disclosure notice for that service in 1992._x yO - ԍXLetter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth, to William Caton, Acting  yOP-Secretary, FCC, filed March 21, 1997, at 56 (BellSouth March 21 Ex Parte).(# 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  X -services with the network.J  yO-ԍBellSouth CEI Plan at 12.J We find that Bellsouth's CEI plan comports with the Commission's network information disclosure requirements.  X -  X - 3.` ` Nondiscrimination Reporting  X -  X -453.` ` In the Payphone Order, the Commission directed the BOCs to comply with the  X-Computer III and ONA requirements regarding nondiscrimination in the quality of service,  Xy-installation, and maintenance.Sy`  yO-ԍPayphone 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  X4-the commitments made in their CEI plans with respect to the nondiscriminatory provision of  X-covered service offerings, installation and maintenance.x  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  yON!- lreview denied, California II, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 7646 (1991), BOC ONA  yO"- >Second Further Amendment Order, 8 FCC Rcd 2606 (1993), pet. for review denied, California II, 4 F.3d  yO"- 1505 (9th Cir. 1993); Phase II Order, 2 FCC Rcd at 3082, para.73; and Filing and Review of Open  yO#- kNetwork Architecture Plans, CC Docket No. 882, Memorandum Opinion and Order, Phase I, 6 FCC Rcd 7646, 764950 (1991).(#Ǝ  X-554.` ` 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"0,-(-(ZZ"  X-service operators in its periodic ONA nondiscrimination reports.J yOy-ԍBellSouth CEI Plan at 11.J We find that BellSouth's CEI plan comports with the Commission's nondiscrimination reporting requirements.  X-  X- C.Accounting Safeguards  X-  X-655.` ` In the Payphone Order and the Accounting Safeguards Order, the Commission  Xv-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 yOh -ԍXPayphone Order at paras. 157, 199, 201; Accounting Safeguards Order at para. 100.(#Ɩ 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  Xy-analyze the data; and 5) the performance of onsite audits by Commission staff.y yP-ԍ#c P7 wP#BOC Safeguards Order, 6 FCC Rcd at 7591, para. 46. BellSouth  Xb-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.  X- D.Other Issues  X- 1.` ` Sufficiency  X-756.` ` 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  Xe-plan.ey yO!- kԍXAPCC Comments at 23; CompTel Comments at 14; ICSPC Comments at 2; SPCC Comments at 4; and AT&T Reply at 12.(#Ƴ As discussed elsewhere in this order, however, we find that BellSouth adequately complies with each of the required parameters.  "t   "t ",-(-(ZZZ"Ԍ X- 2.` ` Tariffing Issues   X-857.` ` 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  Xv-these commenters, BellSouth's payphone operations are more likely to use.( v yO- ԍXSee APCC Comments at 4, 812; SPCC Comments at 68; APCC Reply at 2; AT&T Reply at 45; and  yO- \Letter from Albert H. Kramer, Counsel to APCC, to William Caton, Secretary, FCC, filed Feb. 26, 1997,  yO - at 6 (APCC Feb. 26 Ex Parte); see also Letter from Michael S. Wroblewski, to William Caton, Acting  yOG -Secretary, FCC, filed March 5, 1997, at 6 (Peoples March 5 Ex Parte).(#(  XH-958.` ` 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  X -proceeding.G  yO{-ԍBellSouth Reply at 16.G 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  X -PSPs.: @ yO-ԍId.:  X -: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  X-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  Xb-section 276."Zb yO-ԍReconsideration Order at para. 163.Z 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.`  yO.- ԍXReconsideration Order at para.163; see also id. at n.492 (noting that the "new services test required in the  yO-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.":  yOo!-ԍId.: The order further stated that "[w]here LECs have already filed intrastate tariffs for these services,  X-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  X-Order as revised herein; and 2) that in such case no further filings are required.":H  yO&-ԍId.: Finally,",-(-(ZZ" 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.": yOb-ԍId.: Thus, the state payphone tariff proceedings are the appropriate fora to address concerns about rates, terms, and conditions offered in state payphone tariffs.  X- 3.` ` Screening Codes  X_-;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  X1-lines.q1X yO: -ԍAPCC Comments at 2123; MCI Reply at 12; and AT&T Reply at 45.q 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  X -payphones.E  yO-ԍAPCC Comments at 21.E 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  X -that permits the assignment of a "70" code that uniquely identifies COCOT lines.A x yO-ԍId. at 22.A APCC claims that BellSouth now states that it will provide LIDBbased OLS, rather than Flex  X -ANI.:  yO`-ԍId.: APCC argues that LIDBbased OLS is inferior to the unique code provided to LEC payphones using coin lines, and that such inferior treatment is inconsistent with the  Xy-nondiscrimination requirement of section 276(a).Ay yO-ԍId. at 23.A Both AT&T and MCI support APCC's contention that the transmission of different digits on the SmartLine and PTAS lines  XK-constitutes discrimination.VK(  yO$-ԍAT&T Reply at 5 and MCI Reply at 12.V AT&T also asserts that whatever codes are used, "the  X4-Reconsideration Order (para. 64) precludes BellSouth from requiring an interexchange carrier  X-to perform an additional lookup in order to track payphone calls."D  yO -ԍAT&T Reply at n.11.D MCI also argues that  X-BellSouth is not in compliance with the Commission's payphone orders.@H  yO"-ԍMCI Reply at 2.@ According to  X-MCI, in the Reconsideration Order the Commission required LECs to make available to PSPs  X-coding digits as a part of ANI that specifically identify a phone as a payphone and "not  X-merely as a restricted line."l yOJ'-ԍId. (citing Reconsideration Order at para. 64).l "h,-(-(ZZ"Ԍ X-ԙ<61.` ` In its reply, BellSouth disputes APCC's argument that BellSouth's choice of the LIDB solution for its OLS service unlawfully discriminates against nonBellSouth  X-payphone providers.G yOK-ԍBellSouth Reply at 12.G According to BellSouth, the Commission determined that OLS could  X-be provided by means of either a FLEX ANI solution or by the use of LIDB technology.DX yO-ԍId. at 1011.D BellSouth states that consistent with the Commission's requirements, both the SmartLine  X-service, which delivers the "27" ANI digits, and the PTAS service, which delivers the "07"  Xv-digits, are equally available to all payphone providers, including BSPC.Av yO -ԍId. at 11.A  X_-  XH-=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  X -proceeding or in other proceedings.Q@ x 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 (rel. Dec. 20, 1996), p. 2 n. 7 (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  yOL- that in its 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  yO- a restricted line." Reconsideration Order at para. 64. That order further required that "all LECs must make  yO-available to PSPs, on a tariffed basis, such coding digits as part of the ANI for each payphone." Id.(#Q    X - 4.` ` Numbering Assignments  X ->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  Xy-LEC payphones and PSP payphones are assigned 8000 and 9000 series numbers.fXy  yO- /ԍXAPCC Comments at 21. APCC states that assignment of numbers in the 8000 to 9000 range provides a  distinct advantage in the prevention of fraud because they alert overseas operators to refrain from  yO:-completing calls to such numbers. Id. at 20.(#f In reply,  Xb-BellSouth states that line number assignments will be made to all payphone providers on a  XK-nondiscriminatory basis.GK yO"-ԍBellSouth Reply at 25.G BellSouth states that it will not reserve a pool of numbers for its  X4-own operations, but will assign numbers in the 80009000 range on request "'whenever"40,-(-(ZZH"  X-possible,' i.e., if the number is available.": yOy-ԍId.: Moreover, BellSouth states that it is not required  X-to reallocate numbers lawfully assigned under prior regulation.AX yO-ԍId. at 26.A  X-?64.` ` The Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to reallocate existing number  X-assignments.[ yO& -ԍXPayphone Order at para. 149.(#[ 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.  X1- 5.` ` Uncollectibles  X -@65.` ` AT&T asserts that BellSouth must explain its treatment of uncollectibles due to  X -fraud.D x yO-ԍAT&T Comments at 4.D 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  X -accorded to nonaffiliates, regardless of whether such practice appears in BellSouth's tariffs.:  yOw-ԍId.:  X - 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.  X4- 6.` ` Operator Services  X-A66.` ` 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  X-payphone service.E yO !-ԍAPCC Comments at 25.E APCC argues that if operator services are part of BSPC's deregulated  X-payphone service, BellSouth should explain whether BSPC is providing such services in the  X-payphone by reselling networkbased operator functions.D(  yOl$-ԍId. at 2526.D In addition, APCC states that BellSouth should be required to identify the network functions supporting such services and to"| ,-(-(ZZn"  X-indicate how those same functions will be offered to PSPs on a nondiscriminatory basis.A yOy-ԍId. at 26.A 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  X-between BSPC and other PSPs in the provision of such services.:X yO-ԍId.: For example, APCC states that if BellSouth is offering a commission to BSPC for presubscribing its payphones to  X-BellSouth's operator service, such commissions must also be available to independent PSPs on  Xv-the same terms and conditions.:v yO -ԍId.:  XH-B67.` ` 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  X -services to be part of its deregulated payphone service. We note that in the Reconsideration  X -Order, the Commission declined to require LECs to make available on a nondiscriminatory  X -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  X -the level of 0+ commissions paid pursuant to contract on operator service calls was beyond  X-the scope of section 276 and the Payphone proceeding.Yx yO-ԍReconsideration Order at para. 52.Y  Xy-  Xb-7.` ` Inmate Calling Services Issues  X4-C68.` ` 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  X-regulated operations will provide to its ICS operations.p yO-ԍICSPC Comments at 57; AT&T Comments at 23; AT&T Reply at 23.p ICSPC also argues that BellSouth must disclose whether its regulated operations will provide its ICS operations with inmate call  X-processing and call control functions and information for fraud protection, the validation of  X-called numbers.Q yO!-ԍId. at 712, 1315, 1517.Q ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. In addition, ICSPC asserts that BellSouth should  X|-be required to disclose whether its payphone operations will be responsible for the cost of ICS  Xe-calls for which they are unable to collect.Ie(  yO>&-ԍ Id. at 910.I "N ,-(-(ZZ0"Ԍ X-D69.` ` 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  X-whether that system is located at a central office or at a customer premises.B yOK-ԍId. at 89.B According to ICSPC, to the extent BellSouth's call processing and call control systems dedicated to ICS are  X-located in BellSouth's central offices, BellSouth must provide physical or virtual collocation  X-to other providers.AX yO-ԍId. at 13.A ICSPC also contends that BellSouth must disclose information on interfaces between BellSouth's equipment dedicated to ICS and its regulated network support  X_-services, so that other providers can utilize the same interface if they wish.A_ yO -ԍId. at 19.A  X1-E70.` ` 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'  X -as used in [the] Plan means . . . the provision of inmate service in correctional institutions."G x yO,-ԍBellSouth Reply at 21.G 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  X -processing, become immaterial.:  yOw-ԍId.:  X-F71.` ` In a subsequent ex parte filing, yO-ԍXSee Letter from Albert H. Kramer to William F. Caton (Mar. 19, 1997). (#ƅ ICSPC argues that section 276 requires the  Xy-BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations  Xb-because collect calling is fundamental to ICS.Jb(  yO;-ԍXId. 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  X-collecting for those calls, the BOC is essentially providing ICS as a regulated service and is  X-still subsidizing that service contrary to the prohibition in section 276.H  yOo!-ԍXId. at 2.(#H  X-G72.` ` In a subsequent ex parte, BellSouth provided additional information about how  X-BSPC will conduct its payphone operations after April 1, 1997.YH  yO%-ԍBellSouth March 21 Ex Parte at 3. Y According to BellSouth,  X-BSPC will purchase the same network services that are available to any other PSP from",-(-(ZZ"  X-BellSouth's General Subscriber Services Tariff.: yOy-ԍId.: BellSouth represents that the CPE located at the location provider's premises will be used to perform operator functions, call control,  X-validation, call rating and recording.:X yO-ԍId.: BellSouth states that billing and collection functions  X-will be performed through an industry clearinghouse.: yOT-ԍId.: In addition, BellSouth represents that BSPC will be at risk for fraud and uncollectibles as any other independent inmate service  X-provider.:x yO -ԍId.:   X_-H73.` ` Section 276 specifically defines payphone service to include the provision of  XH-inmate telephone service in correctional institutions.GH yO-ԍ47 U.S.C.  276(d).G In the Reconsideration Order, we  X1-clarified that the requirements of the Payphone Order apply to inmate payphones that were  X -deregulated in an earlier order.-   yOc- zԍXReconsideration Order at para. 131 (citing Petition for Declaratory Ruling by the Inmate Calling Services  yO+- Providers Task Force, Declaratory Ruling, 11 FCC Rcd 7362, 7373 (rel. Feb. 20, 1996) (Inmate Service  yO- zOrder); Petitions for Waiver and Partial Reconsideration or Stay of InmateOnly Payphones Declaratory  yO-Ruling, Order, 11 FCC Rcd 8013 (Common Carrier Bur. 1996)).(#- 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  X -telephones to the network, the central office "coin service" used to provide the ICS, and the  X -operator service facilities used to support the ICS.f  yO-ԍSee Payphone Order at paras. 157 and 159.f In addition, BellSouth is required to offer on a tariffed basis any basic payphone service or network feature used by its payphone  X -operations to provide ICS.  yOh-ԍSee Payphone Order at paras. 14649; Reconsideration Order at paras. 16263.  Xy-I74.` ` 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  X4-tariff.`4 yO#-ԍXBellSouth March 21 Ex Parte at 3.(#` 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  X-whether that equipment is located in a customer premises or a BellSouth central office,0 yO&-ԍ Payphone Order at paras. 157 and 159. See also Inmate Service Order, 11 FCC Rcd at 7373." ,-(-(ZZd"  X-BellSouth represents that it has done so. yOy- jԍXLetter from Ben G. Almond, Executive DirectorFederal Regulatory, BellSouth, to William Caton, Secretary,  yOA-FCC, filed April 7, 1997 (BellSouth April 7 Ex Parte).(# We find no support in the Payphone Order or  X-Reconsideration Order for ICSPC's contention that BellSouth must provide collect calling as a  X-nonregulated service when used with inmate payphones.  X-J75.` ` 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.  X - 8.` ` Primary Interexchange Carrier Selection  X-K76.` ` 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  Xb-payphone PIC selection process.;b  yO3- >ԍXOncor Comments at 5. According to Oncor, BellSouth 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 BellSouth 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 BellSouth or anyone else; (3) how its marketing personnel will be trained and supervised  =to ensure that they do not misrepresent BellSouth'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 sales and marketing of interexchange services from payphones.  yOs-Id.(#; AT&T also asserts that BellSouth's CEI plan should describe how BellSouth will ensure that the PIC selection process for payphones will be  X4-performed on a nondiscriminatory basis.A4  yO-ԍAT&T Reply at 6.A In addition, Oncor also alleges that BellSouth "has  X-been actively engaged in efforts" to contract with payphone location providers regarding the  X-selection of interexchange carriers from BellSouth payphones in violation of the Payphone  X-Order, which only allows a BOC to engage in such negotiations after receiving approval for  X-its CEI plan.[  yO $-ԍOncor Comments at 6 and Appendix B at 89.[  X-L77.` ` In its reply comments, BellSouth states that its CEI plan addresses how it will  X-provide interconnection to other payphone providers because that is to whom BellSouth's CEI"!,-(-(ZZ3"  X-obligations run, pursuant to the Commission's orders.G yOy-ԍBellSouth Reply at 26.G According to BellSouth, "Oncor's concerns and allegations regarding the 'integrity of the payphone PIC selection and ordering  X-process' are out of place in this proceeding and are not relevant to BellSouth's satisfaction of  X-its CEI obligations toward payphone providers.":X yO-ԍId.:  X-M78.` ` We conclude that BellSouth is not required as part of the CEI process to  Xv-demonstrate how it will administer the PIC selection process for payphones. In the Payphone  X_-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  X1-it will unbundle those basic payphone services.W1 yO -ԍPayphone Order at paras. 20304.W 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.  X -N79.` ` With respect to the issue of whether BellSouth has been engaging in negotiations with location providers regarding the selection of interexchange carriers prior to  Xy-receiving CEI approvals, we note that this appears to be the same issue that was addressed in  Xb-the Reconsideration Order regarding BellSouth's activities.gbx yO-ԍReconsideration Order at paras. 228 and 23637. g In responding to comments  XK-about BellSouth's activities, the Commission concluded in the Reconsideration Order that  X4-"contracts entered into pursuant to the grant of authority in section 276(b)(1)(D) and prior to a  X-BOC receiving approval of a CEI plan required by the Report and Order are in violation of  X-the Commission's rules adopted in this proceeding."H yO-ԍId. at para. 237.H The Commission noted, however, that it could not ascertain whether the agreements entered into prior to the completion of these  X-requirements were negotiated in a manner consistent with these policies.: yO! -ԍId.: 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  X-concerning such contracts in light of this policy.":(  yOl$-ԍId.: Based on the Commission's  X|-determination in the Reconsideration Order, we conclude that concerns about BellSouth's engaging in improper negotiations are beyond the scope of this CEI proceeding. "N" ,-(-(ZZ0"Ԍ X- 9.` ` Call Rating  X-O80. ` ` APCC contends that BellSouth must provide a coin line service that allows  X-independent PSPs to set their own end user rates for intraLATA calls.E yO4-ԍAPCC Comments at 14.E APCC asks the Commission to require BellSouth to refile its CEI plan with a more flexible rating feature for  X-its coin line service.AX yO-ԍId. at 15.A  X_-P81.` ` The Payphone Order did not require the BOCs to provide to independent PSPs  XH-an unbundled call rating feature for coin line services.H yO -ԍPayphone Order at paras. 14648. See also Reconsideration Order at para. 165. In addition, on reconsideration of  X1-the Payphone Order, in response to a request that the Commission require access to, inter alia,  X -call rating capabilities,X x yOC- ԍXOn reconsideration, the New Jersey Payphone Association requested that the Commission require access to  call rating capabilities, answer supervision, call tracking, joint marketing, installation and maintenance, and  yO-billing and collection. See Reconsideration Order at para. 155. (#ƒ the Commission specifically declined to require further unbundling  X -of payphone services beyond those established in the Payphone Order.`  yOL-ԍReconsideration Order at para. 165.` As previously noted, independent PSPs may seek additional unbundling through the 120day ONA process. The appropriate state regulatory authorities may also impose further unbundling requirements.  X - 10.` ` Selection of Operator Services Provider  Xy-Q82.` ` 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  XK-intraLATA toll calls and 0+ local calls for its coin line services.EK(  yO$-ԍAPCC Comments at 16.E APCC requests the Commission to require BellSouth to refile its CEI plan in conformance with the Commission's  X-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  X-complies with the Commission's Computer III CEI requirements.X  yOX"- ԍXBellSouth represents that its payphone operations will be provided the same coin line service, including the  yO #- same operator service, as is available to other PSPs. See BellSouth Reply at 67. If independent PSPs seek a different arrangement, they may request it through the 120 day ONA process. (#Ɣ  "t  "#,-(-(ZZ"Ԍ X- "t  11. ` ` Valuation  X-R83.` ` 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  X-Commission's affiliate transactions rules.] yO-ԍAPCC Comments at 56; ICSPC Comments at 34.] 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  XH-of the Commission's Rules."HX yOQ -ԍAPCC Comments at 5; ICSPC Comments at 3 (citing Payphone Order at para. 164). APCC and ICSPC contend that BellSouth's CEI plan, tariff  X1-filing, and CAM omit any discussion of asset valuation.Y1 yO -ԍAPCC Comments at 6; ICSPC Comments at 4.Y  X -S84.` ` In reply, BellSouth states that the claims of APCC and others are "irrelevant to  X -this CEI plan compliance review."G x yO-ԍBellSouth Reply at 22.G BellSouth represents that it will comply with the requirements for the valuation of transferred assets established by the Commission in the  X -payphone orders.:  yOw-ԍId.: In the Payphone Order, the Commission established the accounting requirements that the LECs must follow in transferring or reclassifying payphone assets from  X-regulated to nonregulated status.X yO-ԍPayphone Order, at para.161171. X 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. "t   X- 12.` ` Separate Affiliate  X-T85.` ` 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,  X-BSPC."E(  yO"-ԍSPCC Comments at 14.E SPCC raises questions about the corporate structures of BellSouth and BSPC and  X-the type of joint activities that the two will be engaged in.:  yO%-ԍId.: In reply, BellSouth states that under the Commission's nonstructural safeguards, BellSouth is not obligated to operate its"$H ,-(-(ZZ"  X-payphone business through a separate entity.G yOy-ԍBellSouth Reply at 23.G 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  X-accounting safeguards are met.:X yO-ԍId.: BellSouth represents that transactions between itself and  X-BSPC will be subject to the affiliate transaction rules and subject to audit.: yO= -ԍId.:  Xv-U86.` ` 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,  X -Bellsouth must follow the necessary accounting requirements.  X - 13.` ` Benchmarking  Xy-V87.` ` APCC asserts that because Ameritech offers an anticrime service Restricted  Xb-Coin Access BellSouth should offer this unbundled service also.E bx yO-ԍAPCC Comments at 13.E According to APCC, the "Commission should 'benchmark' the unbundled services offered by one LEC against  X4-those offered by another.": 4 yO-ԍId.: In response, BellSouth states that APCC's claim "is not  X-supported by the Commission's CEI requirements."G  yOf-ԍBellSouth Reply at 24.G According to BellSouth, the  X-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  X-providers.": (  yO!-ԍId.:  X-W88.` ` 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  X|-payphone rulemaking proceeding required the BOCs to provide basic payphone services to  Xe-support smart, dumb, and inmate payphone operations, including unbundled network features"e% ,-(-(ZZO"  X-they provide to others and that are taken by their payphone operations.  yOy-ԍXPayphone Order at 146148; Reconsideration Order at paras. 162163; Clarification Order at 8.(#ƨ 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.  X-2 V. CONCLUSION ă  X_-X89.` ` 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. " &X ,-(-(ZZ "  X-H VI. ORDERING CLAUSE ă  X- Y90.` ` 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. ` `  hh,VFederal Communications Commission ` `  hh,VA. Richard Metzger, Jr. ` `  hh,VDeputy Chief, Common Carrier Bureau  X7-