WPCb 2 BJZCourier3|j>Fx6X@`7X@HP LaserJet 5SiiHPLAS5SI.PRSx  @\"]X@ Y-#c P7 P#X01Í ÍX01Í Í#Xw P7|XP#2<MXf i CourierCG Times"i~'K2^18MSS888S8888SSSSSSSSSS88Jxir{icx{8Aui{x`xoYi{xxxl888SS8JSJSJ8SS..S.SSSS>A.SSxSSJJSJS+SSSSS8SSSSSSSSS.xJxJxJxJxJorJiJiJiJiJ8.8.8.8.{SxSxSxSxS{S{S{S{SxSxJ{SxSxSxS{S`SxIxSxIqIqIrSrS{dgIiSiSgIxSxSxSxSxS{S{S8.SSSS8Sz]SSuSg/gFx6X@`7X@8x/c81, c PE37P8wC;,|Xw PE37XP?@'?'?'",tB^ f ^;C]ddCCCdCCCCddddddddddCCY~~vCN~sk~CCCddCYdYdYCdd88d8ddddJN8ddddYYdYd4dddddCddddddddd8YYYYYY~Y~Y~Y~YC8C8C8C8ddddddddddYdddddsdXdXXXddx|X~d~d|XdddddddC8ddddCdoddd|8|H~d|8|8dtddddHHdlLlLlLkd|H|8~ddddddddXXXd~ddkd~ddxCddCCCWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNdddCYQQddddddFddddFCChhd44ddxxdddvooChdF"dhd9dCCxCddoddCdYds]xUvdYYCCCCx~oxoY~NYdYC8YooYdYxsdxdd~YYxoxxx~CdxYxxxxCCdddddddxCsdYC\   pxtll\tll@\@\`L2cKt\3|jCG TimesCG Times BoldTimes New RomanTimes New Roman BoldCG Times ItalicTimes New Roman Italic"i~'^:DTddDDDd4D48ddddddddddDDd||||DXp||dp||ppL8LTdDddXdX8dd88X8ddddLL8dXXXLP8PlD4lTDDD4DDDDDDdDd8|d|d|d|d|dX|X|X|X|XD8D8D8D8dddddddddpX|ddddpXd|d|d|d|dXXlXx|X|X|X|XdddldldD8DdDDDddllXp8pHpDp@p8dtdddd|L|L|LdLdLdLllpHp8pTddddddplpLpLpLdpDddLpDpdx4ddC,CWddddddddddddddddddddddddddddddddddddddddNHxxHhdLdddddd8@d<@d<DDppdDDxddxHxxHkddDpd<"dxtldxxd8wC;,|Xw PE37XPx/c81, c PE37P D7zC;, EXz_ pi7X7jC:,ynXj\  P6G;XP7nC:,'A.SSxSSJJSJS+SSSSS8SSSSSSSSS.xJxJxJxJxJorJiJiJiJiJ8.8.8.8.{SxSxSxSxS{S{S{S{SxSxJ{SxSxSxS{S`SxIxSxIqIqIrSrS{dgIiSiSgIxSxSxSxSxS{S{S8.SSSS8Sz]SSuSg/g??a7Right ParRight-Aligned Paragraph NumberspfJ` `  hh#(@*i) (h-(# a8Right ParRight-Aligned Paragraph NumbersyW"3!` `  hh#(-@p/a) -pp2(#p a1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . 2C@AAmBa6TechnicalTechnical Document Style)D (a) . a2TechnicalTechnical Document Style<6  ?  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Default Paragraph Fo V Z2cbf EQV \",tB^ f ^;C]ddCCCdCCCCddddddddddCCdxN`xoCCCddCdoYoYFdo8Co8odooYNCodddYdddd4dddddCddddddddo8dddddYYYYYN8N8N8N8oddddooooddpddddxodddXXddXddXdddddooL8doddNopddo8PdN8ppoddXXdpLoNpLodPDdopoopodXYXodoodddCddCCCWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNdddCdUUddddddFddddFCCssd44ddxxddd~ooCsdF"dsd9dCCxCddoddCdYds`xUvdddCCCCxoxoYNYYYN8YooYdYxxdxddYYxoxxxNdxYxxxxCCdddddddxCxdYC\   pxtll\tll@\@\`L"i~'K2^!.22YN!!!2Y!!!!2222222222!!dYd,YH?EJ?;HJ!'F?[JH9HC6?JH^HHA!!!22!,2,2,!222N2222%'22H22,,2,d222222!222222222H,H,H,H,H,YCE,?,?,?,?,!!!!J2H2H2H2H2J2J2J2J2H2H,J2H2H2H2J292H,H2H,D,D,E2E2J<>,?2?2>,H2H2H2H2H2J2J2!2222!2I822F2>>$?2>>J2:J2J2H2H2YHB$B$C26&6&6&62>$>?2J2J2J2J2J2J2^HH2@,@,@,J2?2J262?2H2<!22!!!WddddddddddddddddddddddddddddddddddddddddddddddddxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHHH222!,))22X222YY2#2222Y#!!442Ydd22<"(#L 1 XxPII. BACKGROUND p>"(#L 3 XxPIII. SERVICE DESCRIPTION p>"(#L 6 XxPIV. COMPLIANCE ISSUES p!(#F 10  X -XxX` ` xA.` ` CEI Plan Requirements ` p!(#F 10  X!-XxX` ` xB.` ` Other Nonstructural Safeguards ` p"(#I 51  X"-XxX` ` xC.` ` Accounting Safeguards ` p"(#I 62  X#-XxX` ` xD.` ` Other Issues ` p"(#I 63 XxPV. CONCLUSION p"(#I 91 XxPVI. ORDERING CLAUSE p"(#I 92 " (,))[[&"Ԍ  X-  I. INTRODUCTION ă  X-x1. ` ` On January 3, 1997, pursuant to the requirements of the Commission's orders  X-in the Payphone proceeding, xP-ԍXxImplementation of the Pay Telephone Reclassification and Compensation Provisions of the  xP-Telecommunications Act of 1996, CC Docket No. 96128, Report and Order, FCC 96388 (rel. Sept.  xP-20, 1996) (Payphone Order), appeal docketed sub nom., Illinois Public Telecommunications Assn. v.  xP^ -FCC, Case No. 961394 (D.C. Cir., filed Oct. 17, 1996), recon., FCC 96439 (rel. Nov. 8, 1996)  xP& -(Reconsideration Order); Order, DA 97678 (Common Carrier Bur. April 4, 1997) (Clarification  xP -Order).(#Ʃ the NYNEX Telephone Companies (NYNEX) filed a  Xv-comparably efficient interconnection (CEI) plan for payphone service.v@ xPg -ԍXxNYNEX Comparably Efficient Interconnection Plan for Payphone Services (filed Jan. 3, 1997) (NYNEX CEI Plan).(#ƥ In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan  XH-describing how it will comply with the Commission's Computer III H xP-ԍXxAmendment of Section 64.702 of the Commission's Rules and Regulations, CC Docket No. 85229,  xPY-PhaseI, 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987) (Phase I  xP!-Reconsideration Order), further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Reconsideration  xP-Order), second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further Reconsideration),  xP-Phase I Order and Phase I Reconsideration Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir.  xPy-1990) (California I); Phase II, 2 FCC Rcd 3072 (1987) (Phase II Order), recon., 3 FCC Rcd 1150  xPA-(1988) (Phase II Reconsideration Order), further recon., 4 FCC Rcd 5927 (1989) (Phase II Further  xP -Reconsideration Order), PhaseII Order vacated, California I, 905 F.2d 1217 (9th Cir. 1990);  xP-Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA Remand Order), recon., 7 FCC  xP-Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (California  xPa-II); Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier1 Local  xP)-Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order), recon. dismissed in  xP-part, Order, CC Docket Nos.90623 & 92256, FCC 96222 (rel. May17, 1996); BOC Safeguards  xP-Order vacated in part and remanded, California v. FCC, 39 F.3d 919 (9th Cir. 1994) (California III),  xP-cert. denied, 115 S.Ct. 1427 (1995) (referred to collectively as the ComputerIII proceeding).(#ƫ CEI equal access  X1-parameters and nonstructural safeguards for the provision of payphone services.[1 xP-ԍXxPayphone Order at para. 202.(#[ BOCs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations to  X -provide payphone services.e  xPE#-ԍXxPayphone Order at paras. 146, 200204.(#e " 8,,(,([[ "Ԍ X-x2. ` ` The Commission gave public notice of NYNEX's CEI plan on January 8,  X-1997.  xPy-ԍXxPleading Cycle Established for Comments on Comparably Efficient Interconnection Plan for Payphone  xPA-Service Providers, Public Notice, CC Docket No. 96128, DA 9731 (rel. Jan. 8, 1997).(#  On February 7, 1997, eight parties filed comments opposing the plan.7 xP-ԍXxComments of the American Public Communications Council on NYNEX Telephone Companies' CEI Plan (APCC Comments); AT&T's Comments on NYNEX's Comparably Efficient Interconnection Plan (AT&T Comments); Comments of the Independent Payphone Association of New York, Inc. on the NYNEX Comparably Efficient Interconnection Plan for Payphone Services (IPANY Comments); Comments of the Inmate Calling Service Providers Coalition on NYNEX Telephone Companies CEI Plan (ICSPC Comments); MCI Telecommunications Corporation Comments (MCI Comments); Initial Comments of the New England Public Communications Council, Inc. (NEPCC Comments); Comments of Oncor Communications, Inc. (Oncor Comments); Comments of Telco Communications Group, Inc., on NYNEX's Comparably Efficient Interconnection Plan (Telco Comments). APCC filed an erratum to its comments on February 12, 1997.(#Ɠ NYNEX submitted reply comments on February 24, 1997. For the reasons discussed below, we approve NYNEX's CEI plan.  X-F II. BACKGROUND ă  X_-x3. ` ` The payphone rulemaking proceeding implemented Section 276 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (1996  X1-Act).1  xP-ԍXxTelecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56, to be codified at 47 U.S.C.   xPy-151 et seq.(# Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone  X -service.L '  xP-ԍXx47 U.S.C.  276.(#L The 1996 Act provided that such safeguards must, at a minimum, include the  X -nonstructural safeguards adopted in the Computer III proceeding.U  xP&-ԍXxId.  276(b)(1)(C).(#U  X-x4. ` ` In the Payphone Order, the Commission determined that the Computer III and  Xy-ONA nonstructural safeguards would "provide an appropriate regulatory framework to ensure  Xb-that BOCs do not discriminate or crosssubsidize in their provision of payphone service." bG xPZ"-ԍXxPayphone Order at para. 199. In addition, the Commission adopted accounting safeguards for BOC  xP"#-and incumbent LEC provision of payphone service on an integrated basis. See Implementation of the  xP#-Telecommunications Act of 1996: Accounting Safeguards Under the Telecommunications Act of 1996, CC Docket No. 96150, Report and Order, FCC 96490, para. 100 (rel. Dec. 24, 1996).(# Accordingly, the Commission required the BOCs to file "CEI plans describing how they will  X4-comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI"4/ ,,(,([[*" requirements as modified by section 222 of the 1996 Act, network disclosure requirements,  X-and installation, maintenance, and quality nondiscrimination requirements." x xPb-ԍXxPayphone Order at para. 199. In its notice of proposed rulemaking regarding the CPNI and other customer information provisions of the 1996 Act, the Commission concluded that its previously established CPNI requirements would remain in effect, pending the outcome of that rulemaking, to the  xP-extent that they do not conflict with the CPNI provisions of the 1996 Act. See Implementation of the Telecommunications Act of 1996: Telecommunication Carriers' Use of Customer Proprietary Network  xPJ-Information and Other Customer Information, CC Docket No. 96115, Notice of Proposed Rulemaking,  xP-11 FCC Rcd 12513, 12529, para. 38 (rel. May 17, 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  X-payphone under the new compensation plan established in the payphone proceeding.e  xP] -ԍXxReconsideration Order at para. 132. In addition to an approved CEI plan, in order to receive  xP% -compensation, the Reconsideration Order requires that "a LEC must be able to certify the following: (1) it has an effective cost accounting manual ('CAM') filing; (2) it has an effective interstate CCL tariff reflecting a reduction for deregulated payphone costs and reflecting additional multiline subscriber line charge ('SLC') revenue; (3) it has effective intrastate tariffs reflecting the removal of charges that recover the costs of payphones and any intrastate subsidies; (4) it has deregulated and reclassified or transferred the value of payphone customer premises equipment ('CPE') and related costs as required in  xP-the [Payphone Order]; (5) it has in effect intrastate tariffs for basic payphone services (for 'dumb' and 'smart' payphones); and (6) it has in effect intrastate and interstate tariffs for unbundled functionalities  xPe-associated with those lines." Id. at para. 131.(#e  Xv-x5. ` `  FEATURES 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' payphones that utilize central office coin services, or some combination of the two in a  X -manner similar to the LECs."p   xPk-ԍXxReconsideration Order at para. 162. A "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 perform such functions.(#p Those tariffs must be filed with the applicable state regulatory  X -commission.T  xP<-ԍXxId. at paras. 16263.(#T Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone affiliate to provide payphone service or offered by the BOC to unaffiliated payphone service providers (PSPs) on an  X -unbundled basis.  xP#-ԍXxPayphone Order at paras. 146148; Reconsideration Order at paras. 162163; Clarification Order at para. 8.(#Ƶ " p,,(,([[ "Ԍ X-&  III. SERVICE DESCRIPTION ă  X-x6.` `  BASICPAL NYNEX currently offers a variety of tariffed Basic Public Access Line (Basic  X-PAL) services in all of its state jurisdictions.O xP4-ԍXxNYNEX CEI Plan at 3. (#O According to NYNEX, these tariffed services,  X-which vary by state jurisdiction,X xP-ԍXxSee Letter from Alan S. Cort, NYNEX, to William F. Caton, Acting Secretary, Federal Communications Commission, Attachment B (March 20, 1997) (March 20th Letter).(# are currently used by unaffiliated PSPs to offer competitive  X-pa& yphone services using "smart" payphones and, on a limited basis, "dumb" payphones.O xP -ԍXxNYNEX CEI Plan at 3. (#O Generally, these Basic PAL lines provide twoway or oneway originating only measured  X_-service with optional features including line side answer supervision (LSAS), _@ xPP-ԍXxLSAS sends an "offhook" supervisory signal to the payphone line when the called party answers the call. March 20th Letter, Attachment B, at 4. When the called party disconnects, an "onhook" signal is detected and the reverse battery signal is returned to normal. According to NYNEX, LSAS  xP-improves the accuracy of a PSP's timing of sent paid (i.e., coin) calls. Id.(# billed number  XH-screening (BNS),H(  xP!-ԍXxBNS blocks incoming collect and third party calls from being billed to a payphone line when  xP-originating within the continental United States. Id.(# and certain call blocking features.  X -x7.` `  SMARTPAL NYNEX has supplemented its existing Basic PAL services with four additional tariffed service offerings, which hereinafter are referred to as Smart Public Access Line (Smart PAL) services:  X -x(1)` ` OneWay Basic Coin Access Line, which provides outgoingonly message  X -service with central officebased coin functionality,  xP-ԍXxCoin functionality includes dial tone first (DTF), call rating, automated local coin overtime, coin collect/coin return, return of initial coin deposit on calls beyond local calling area, operator system control to process 0+ and 0 calls, and standard recorded announcements. March 20th Letter, Attachment A, at 1. DTF enables customers to dial certain calls, such as 911 calls, without depositing coins.(# answer supervision, and certain call blocking and screening features;(#`  Xb-x(2)` ` TwoWay Basic Coin Access Line, which allows both incoming and outgoing calls and provides coin functionality, answer supervision, and certain call blocking and screening features;(#`  X-x(3)` ` Inmate Public Access Line, which provides outgoingonly coinless service, limited to collect calls only;(#` "0,,(,([["Ԍ X-x(4)` ` ChargeACall Public Access Line, which allows outgoingonly coinless calls to  X-0+ for calling card billing.G xPb-ԍxNYNEX CEI Plan at 34.G(#` x  X-x8.` ` NYNEX represents that it will treat affiliated and nonaffiliated PSPs on a nondiscriminatory basis in regard to any fraud protection and special numbering arrangements  X-and in the installation and maintenance of basic payphone services.HX xP-ԍXxId. at 4.(#H NYNEX also asserts that its PAL services will provide the necessary functionality for PSPs to provide their own billing and collections processes for calls completed from "smart" payphones and "dumb"  XH-payphones that utilize NYNEX's central office technology.@H xP -ԍxId. at 5.@ According to NYNEX, its OneWay Basic Coin Access Line and TwoWay Basic Access Line will provide the appropriate coin signaling and supervision capability to monitor coin deposits for calls placed from  X -"dumb" payphones.D x xP,-ԍxId. at 5 n.15D  X -x9.` ` NYNEX operates its payphone business on a structurally unseparated basis  X -from its telephone operating companies, as permitted by the Payphone Order.c  xPw-ԍXxSee Payphone Order at  145(#c NYNEX states that it currently provides public payphone services to endusers utilizing a combination  X-of "smart" and "dumb" payphones that utilize certain central office coin related capabilities.E xP-ԍxNYNEX CEI Plan at 2.E  Xy-NYNEX intends to use its Inmate Public Access Line to provide inmate calling services.Hy(  xPR-ԍxMarch 20th Letter at 2.H  XK- IV. COMPLIANCE ISSUES ă  X- A.xCEI Plan Requirements  X-x 10.` ` 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.0   xP*$-ԍXxSee Phase I Order, 104 FCC 2d at 1026, para. 128. Requiring BOCs to file CEI plans was one of the nonstructural safeguards adopted by the Commission, in lieu of structural separation, to prevent cross xP%-subsidization and discrimination. As a first step in implementing the Computer III framework, the Commission permitted the BOCs, which remained subject to various structural separation requirements, to offer individual enhanced services on an integrated basis following approval of servicespecific CEI"J',,(,(c'" 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 (ESPs); and (3)how the BOCs would comply with the other nonstructural safeguards  xP-imposed by ComputerIII. See Phase I Order, 104 FCC 2d at 103459, paras. 142200.(#0 As applied in the",,(,([[" payphone context, the CEI requirements are designed to give independent PSPs equal and efficient access to the regulated basic payphone services provided by the BOCs as well as  X-those basic services that the BOCs use to provide their own payphone services.o xP3-ԍXxSee Payphone Order at paras. 146, 200204.(#o The  X-Commission, in its Computer III proceeding, established nine specific CEI requirements,n @ xP -ԍxPhase I Order, 104 FCC 2d at 10391043, paras. 154166.n which are discussed below. NYNEX has described in its submissions how it will satisfy each of these nine requirements. We review below NYNEX's CEI plan with respect to each of these requirements.  XH-x 1.` ` Unbundling of Basic Services  X -x 11.` ` The Payphone Order deregulated LEC payphones and classified those  X -payphones as customer premises equipment (CPE).[!  xP-ԍXxPayphone Order at para. 142.(#[ In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either "smart" payphones or "dumb" payphones that utilize central office coin services, a LEC must also  X -tariff unbundled payphone features that the LEC uses or provides on an unbundled basis." `  xP-ԍXxId. at paras. 146148; Reconsideration Order at paras. 162163; Clarification Order at para. 8.(#ƪ Moreover, BOCs, but not other LECs, must unbundle additional network elements when  X-requested by payphone providers based on the specific criteria established in the Computer III  Xy-and ONA proceedings.#y  xP-ԍXxPayphone Order at para. 148; Reconsideration Order at para. 165.(#ƅ  XK-x 12.` ` The Payphone Order requires BOCs to file CEI plans that explain how they  X4-will unbundle basic payphone services.[$4  xPe -ԍXxPayphone Order at para. 204.(#[ Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic  X-service functions that underlie its provision of payphone service.% xP#-ԍXx#c P P#Id. at para. 204 (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"h%,,(,([[ "  X-available as part of CEI.& xPy-ԍx#c P P#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.'X xP-ԍx#c P P#Id.; see also Recon Order at para. 213 (citing Phase I Order, 104 FCC 2d at 1040).  X-x 13.` ` The basic services underlying NYNEX's payphone services consist of the  X-Smart PAL services described above,h( xP= -ԍXxSee supra  SMARTPAL7.(#h which NYNEX uses predominately with "dumb"  X-payphones. As previously noted, NYNEX also offers a variety of Basic PAL services that are  Xv-used by unaffiliated PSPs with "smart" payphones.h)vx xP -ԍXxSee supra  BASICPAL6.(#h For purposes of this order, Basic PAL service will also be referred to as "customer owned, coin operated telephone" or "COCOT" service, and Smart PAL service will also be referred to as "coin line" service.  X -x 14.` ` NYNEX represents that it has unbundled all basic services and functions used  X -by its payphone operations.M*  xP-ԍXxNYNEX CEI Plan at 6.(#M According to NYNEX, these services and functions constitute  X -the minimum set of network functions required for connectivity to the network.:+  xP5-ԍxId.: NYNEX also represents that all basic services that it uses to provide payphone services have been tariffed, and any network functions it uses are available to all PSPs under the same rates,  X -terms, and conditions.B, (  xP-ԍXxId.(#B  X-  Xy-x15. ` ` APCC and NEPCC argue that NYNEX's CEI plan must be rejected because NYNEX has not sufficiently unbundled payphone features and functionalities from the  XK-payphone access line.c-K  xP-ԍXxAPCC Comments at 56; NEPCC Comments at 3.(#c APCC contends that NYNEX is required to offer the basic payphone lines for its Basic PAL and Smart PAL services, and to offer separately the features and  X-functionalities that NYNEX proposes to offer as part of those basic payphone offerings.N.H  xP"-ԍXxAPCC Comments at 56.(#N APCC argues that such unbundling and separate tariffing are necessary to ensure that  X-NYNEX's payphone offerings are nondiscriminatory and free from cross subsidization.H/ xPx%-ԍXxId. at 6.(#H NEPCC asserts that NYNEX's bundling of certain features in its coin line service that are"h/,,(,([[D"  X-unbundled for its Basic PAL service is discriminatory and in violation of section 276.M0 xPy-ԍXxNEPCC Comments at 4.(#M NEPCC also contends that, if NYNEX offers an unbundled service in one state, then it should  X-be required to offer the unbundled service in the other states it serves as well.@1X xP-ԍxId. at 5.@  X-x16. ` ` NYNEX responds that its Basic PAL and Smart PAL offerings comply with the  X-CEI unbundling requirement. NYNEX contends that the Commission did not require carriers to unbundle coin line features from the basic payphone line, and that such requests should be  X_-handled through the ONA request process.D2_ xP -ԍxNYNEX Reply at 34.D  X1-x17. ` ` We find that NYNEX's plan satisfies the CEI unbundling requirement  X -contained in the payphone rulemaking proceeding. The payphone rulemaking proceeding requires BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone  X -services using either "smart" or "dumb" payphones or to offer inmate calling services.[3 x xP-ԍXxPayphone Order at para. 146.(#[ In addition, consistent with the payphone rulemaking proceeding requirements, BOCs must provide on a tariffed basis the unbundled features and functions they provide to others or to  X -their payphone operations.b4  xP`-ԍXxReconsideration Order at para. 146.(#b NYNEX's plan satisfies those requirements. We note, however, that NYNEX may choose to unbundle additional functions and features, states may request further unbundling, and payphone providers may request additional unbundled features and  Xb-functions through the ONA 120day service request process.d5b xP-ԍXxClarification Order at para. 8, n.23.(#d Any other unbundled features and functions provided by NYNEX must comply with the tariffing and CEI requirements of  X4-the payphone rulemaking proceeding, Computer III and ONA.  X-  X-x18.` ` We reject the contentions of APCC and NEPCC that NYNEX must unbundle the coin supervision and other features of its Smart PAL service offerings. As noted in the  X-Clarification Order, the payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled  X-basis."6(  xP#-ԍXxId. at para. 16 (citing Payphone Order at para. 148; Reconsideration Order at para. 165).(#Ƥ 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, on an unbundled basis, either to  XN-affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal"N 6,,(,([[0"  X-jurisdictions.7  xPy-ԍXxClarification Order at para. 16. That Order clarified that the unbundled features and functions addressed in the payphone rulemaking proceeding are network services similar to basic service elements ("BSEs") under the ONA framework. BSEs are defined as optional unbundled features that an  xP-enhanced service provider may require or find useful in configuring its enhanced service. Id. at para.  xP-17 (citing Filing and Review of Open Network Architecture Plans, Phase I, Memorandum Opinion and Order, FCC 88381, 4 FCC Rcd 1 (1988)). In this case, the unbundled features are payphone specific, networkbased features and functions used in configuring unregulated payphone operations provided by LECs or nonLEC PSPs. Some of the LECs use terms such as tariffed "options" and "elective  xP-features" to refer to network services that other LECs call features and functions. The Clarification  xP -Order concluded that "[o]ptions and elective features must be federally tariffed in the same circumstances as features and functions must be federally tariffed, depending on whether they are provided on a bundled basis with the basic network payphone line (state tariff), or separately on an  xP -unbundled basis (federal and state tariffs). Id. (citing Application of Open Network and  xP -Nondiscrimination Safeguards to GTE Corporation, 11 FCC Rcd 5558 (1995)).(# Because NYNEX offers, and will use, the Smart PAL services on a bundled  X-basis,J8  xP-ԍXxNYNEX Reply at 3.(#J it is not required to unbundle the individual features that comprise those services in its  X-CEI plan. No further unbundling is required at this time.[9 xP-ԍXxPayphone Order at para. 148.(#[ Independent payphone providers  X-may seek further unbundling by making a request pursuant to the ONA process.B: xP -ԍXxId.(#B  X-  X-x19.` ` We also reject NEPCC's contention that, if NYNEX offers an unbundled service in one state, it is required to offer that unbundled service in all of the states it serves. As noted, any payphone feature that a BOC uses on an unbundled basis in a state must be offered to independent PSPs in that state. Except as required pursuant to the ONA request process, a BOC is not obligated to unbundle additional services in a state unless the state  X -requires it to do so.B; 0 xP-ԍXxId.(#B  X -  X -x2.` ` Interface Functionality  X -x20.` ` 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 operations.< xP#-ԍxId. at paras. 20203; Phase I Order, 104 FCC 2d at 1039, para. 157. " P<,,(,([["Ԍ X- "A ^  "A ԙx21.` ` DISCLOSURENYNEX claims that its payphone operations will utilize the same standard interfaces and tariffed transmission offerings that are available on the same terms and  X-conditions to all PSPs.M= xPK-ԍXxNYNEX CEI Plan at 5.(#M According to NYNEX, all PSPs therefore can interconnect to the telephone network through identical standard hardware and software interfaces and access  X-arrangements associated with tariffed basic services.:>X xP-ԍxId.: NYNEX represents that the details of  "A ^  "A the interfaces for its four newlytariffed Smart PAL services were disclosed in a network  Xv-information disclosure in the December 1996 issue of the Bellcore Digest.?v xP -ԍXxId. at 5 n.17. See also March 20th Letter, Attachment C (copy of NYNEX' network disclosure).(#ƨ NYNEX also asserts that its payphone operations will utilize basic services only when they are made  XH-generally available to others.E@Hx xPq-ԍxNYNEX CEI Plan at 6.E  X -x22.` ` Telco asserts that NYNEX's statement that PSPs will obtain access to the network through existing interfaces available through NYNEX's standard network interfaces is insufficient. Telco argues that NYNEX must provide "further explanation or meaningful detail regarding the technical requirements [a PSP] must meet to connect to the network  X -interfaces . . . ."OA  xPw-ԍXxTelco Comments at 23.(#O  X-x23.` ` We find that NYNEX complies with the interface functionality requirement. As stated above, this requirement only obligates the BOC to make available standardized hardware and software interfaces that will be able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone operations. NYNEX avers that it has met this requirement. Beyond the filing of network disclosures, which NYNEX states that it has filed, and Telco does not dispute NYNEX's claims, this parameter does not require NYNEX to provide technical details in the CEI plan explaining how PSPs will connect to NYNEX's network.  X-x 3. Resale  X-x24.` ` 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  XN-operations and anticompetitive pricing in unregulated markets."dBN xP%-ԍxPhase I Order, 104 FCC 2d at 1040, para. 159.d Based on the requirement in  X7-the Payphone Order and the Reconsideration Order, any basic services provided by a BOC to"7 ( B,,(,([[" its payphone affiliate, as well as any payphone service provided by others, must be available  X-on a nondiscriminatory basis to other payphone providers.}C xPb-ԍxPayphone Order at para. 200; Reconsideration Order at para. 211.}  X-x25.` ` NYNEX represents that its payphone operations will procure CEI elements at the same tariffed rates, terms and conditions as it will make the elements available to other  X-PSPs.EDX xP-ԍxNYNEX CEI Plan at 6.E We find that NYNEX has met the resale requirement. We are not persuaded by  Xv-Telco's argument that NYNEX's plan is insufficient, because it "fails to address how it will provide resale or specify what combinations will be offered for resale, whether resale will be offered on a nondiscriminatory basis, or what mechanisms will exist to enable competitors to  X3-ensure that resale obligations are being met."ME3 xP -ԍXxTelco Comments at 2.(#M We find that NYNEX's representation is sufficient to meet this CEI requirement. To the extent that Telco's objections are based on concerns that NYNEX's tariffed payphone offerings unlawfully discriminate against unaffiliated PSPs, contrary to NYNEX's express representation to the contrary, such specific, factbased claims should be addressed in federal or state tariff proceedings or formal complaints against NYNEX.  X-x 4. Technical Characteristics  X{-  Xd-x26.` ` 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  X6-payphone services.F6x xP_-ԍXxPayphone Order at paras. 199207; Reconsideration Order at paras. 218220; #c P P#Phase I Order, 104 FCC 2d at 1041, para. 160.(#  X-x27.` ` According to its CEI plan, NYNEX will provide interconnection to the payphone offerings of NYNEX and its competitors through the same standard network interfaces and these interconnections are provided under tariff and support all the  X-transmission, switching, and signaling functions used by NYNEX's payphone operations.MG xPD -ԍXxNYNEX CEI Plan at 6.(#M We find that NYNEX's CEI plan comports with the technical characteristics requirement established by the Commission. To the extent that Telco obtains credible evidence that NYNEX has unlawfully discriminated against unaffiliated PSPs in the assignment of access lines, Telco may initiate a formal complaint against NYNEX. "P ` G,,(,([["Ԍ X-x 5. Installation, Maintenance, and Repair  X-  X-x28.` ` The Payphone Order requires BOCs to describe in their CEI plans how they  X-will comply with the nondiscrimination requirements in Computer III and ONA regarding the  X-quality of service, installation, and maintenance.SH xP-ԍxPayphone 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  Xv-a CEI offering to unaffiliated PSPs are the same as those the carrier provides to its own or its  X_-affiliated payphone service operations.|I_X xPh -ԍxId. at para. 203; Phase I Order, 104 FCC 2d at 1041, para. 161.| BOCs also must satisfy reporting and other  XH-requirements showing that they have met this requirement.JH xP -ԍXxPhase I Order, 104 FCC 2d at 1041, para. 16. NYNEX must provide quarterly reports on installation  xP -and maintenance of its basic services. Id. at 10551056, paras. 192193. The Payphone Order does not impose any new continuing reporting requirement because BOCs are already subject to reporting  xP9-requirements pursuant to Computer III and ONA. BOCs must report on payphone services as they do for basic services.(#  X -x29.` ` In its CEI plan, NYNEX represents that its installation, design, maintenance,  X -and repair methods and procedures are highly automated and are designed to treat all  X -customers, including PSPs, in an impartial, efficient, nondiscriminatory manner.GK  xP5-ԍXxCEI Plan at 7.(#G NYNEX also represents that it will establish procedures and processes that insure that affiliated and nonaffiliated PSPs are treated the same with regard to the quality and time period associated  X -with installation, maintenance and repair of basic services.BL (  xP-ԍXxId.(#B NYNEX asserts that mechanized  X-access capabilities associated with the installation, maintenance, and repair of basic services used in the provision of NYNEX's payphone services will be made available on a comparably efficient basis to all PSPs to insure that the quality and time period associated with the installation, maintenance, and repair of basic services will be the same. NYNEX also notes that the Commission has previously found NYNEX's procedures for ordering, installing,  X-maintaining, and repairing underlying basic services to be nondiscriminatory.M  xP -ԍXxId. at 7 n.20 (citing Filing and Review of Open Network Architecture Plans, Memorandum Opinion and Order, 4 FCC Rcd. 1, paras. 46773 (1988)).(#  X-x30.` ` Several commenters argue that NYNEX must provide further detail regarding how it will provide installation and repair on a nondiscriminatory basis to unaffiliated PSPs, in order for the Commission to be able to evaluate whether nondiscriminatory procedures will" M,,(,([["  X-in fact be in place.N xPy-ԍxAPCC Comments at 12; NEPCC Comments at 8; IPANY Comments at 3; Telco Comments at 3. For instance, APCC contends that NYNEX's plan must describe NYNEX's installation and repair procedures and disclose whether its payphone operations  X-personnel will have direct access to automated service order processing systems.POX xP-ԍXxAPCC Comments at 1213.(#P  X-x31.` ` APCC also asserts that NYNEX should explain whether it intends to share  X-personnel between its operating company and payphone operations and, if so, the measures it will implement to ensure that the use of shared personnel will not lead to discrimination in the  X_-provision of installation, maintenance, and repair.DP_ xP -ԍxId. at 1314.D NEPCC contends that NYNEX should be required to commit to avoid such sharing of personnel, particularly for installation, repair, and  X1-maintenance functions.MQ1x xPZ-ԍXxNEPCC Comments at 8.(#M In addition, APCC argues that NYNEX should identify for its  X -payphone offerings the demarcation point between the switched network and a payphone  X -provider's inside wire.pR  xP-ԍxAPCC Comments at 13. See also NEPCC Comments at 8.p IPANY contends that recent examples of alleged discriminatory and anticompetitive treatment of unaffiliated PSPs by New York Telephone cast doubt on  X -NYNEX's pledge to treat competing PSPs in a nondiscriminatory manner.S  xP-ԍXxIPANY Comments at 39. New York Telephone is a subsidiary of NYNEX that provides local exchange and exchange access telephone service in New York. (# For example, IPANY alleges that NYNEX requires independent PSPs that own curbside payphones in New  X -York to pay the expense of installing conduit to the payphone from the manhole even though  X-NYNEX has never charged its own payphone operations for similar installation.HTX  xP1-ԍXxIPANY Comment at 67. IPANY also alleges that New York Telephone has unreasonably refused to provide connections to payphones owned by independent PSPs through a terminal box on a privately xP-owned building adjacent to the payphones. Id. at 45.(#H  Xb-x32.` ` In reply, NYNEX states that it will update existing procedures and processes and will train personnel to ensure that NYNEX's payphone operations will be treated in the  X4-same way as nonaffiliated PSPs by the same customer service organizations that deal with  X-nonaffiliated PSPs for the provision, maintenance, and repair of network services.LU xP"-ԍXxNYNEX Reply at 11. (#L According to NYNEX, this will include the use of the same means of communication (e.g., paper, facsimile, and systems) and information requirements to initiate, manage, and monitor  X-the status of network service requests and trouble reports.IV xP)'-ԍXxId. at 11.(#I NYNEX also represents that costs"0V,,(,([["  X-associated with the use of telephone company network service technicians and installation and repair organizations by NYNEX's payphone operations will be appropriately allocated under  X-Parts 32 and 64 of the Commission's rules.NW xPK-ԍXxId. at 12 n.30.(#N NYNEX asserts that the concerns of discriminatory installation and maintenance service raised by IPANY are outside the scope of  X-this proceeding and are being addressed in the state regulatory arena.IXX xP-ԍXxId. at 12.(#I NYNEX also contends  X-that New York Telephone's conduct in the examples cited by IPANY was consistent with  Xv-New York state law.LYv xP -ԍXxId. at 1214.(#L Finally, NYNEX states that, in the deregulated payphone environment, New York Telephone's payphone operations will be subject to the same special construction,  XH-installation and other charges as nonaffiliated PSPs.IZHx xPq-ԍXxId. at 14.(#I  X -x 33. ` ` We find that NYNEX has met the installation, maintenance, and repair requirement. We conclude that NYNEX's description of the procedures that it will employ to ensure nondiscriminatory treatment of its own payphone operations and those of unaffiliated PSPs is sufficient for us to conclude that its CEI plan satisfies this parameter. We also reject APCC's argument that NYNEX must provide further explanation about personnel sharing in  X -order to ensure that there will be no discrimination against unaffiliated PSPs and NEPCC's  X-argument that NYNEX should commit to refrain from sharing personnel. In the Payphone  Xy-Order, we specifically declined to require BOCs to provide payphone CPE through a  Xb-structurally separated affiliate.Z[b xP-ԍXxPayphone Order at  145.(#Z More importantly, we find that NYNEX sufficiently describes the procedures it has adopted to address concerns about discrimination, even with  X4-shared personnel. NYNEX represents that its installation, design, maintenance, and repair methods and procedures are highly automated and are designed to treat all customers,  X-including PSPS, in an impartial, efficient, nondiscriminatory manner.M\ xPO-ԍXxNYNEX CEI Plan at 7.(#M NYNEX also represents that the customer service organizations that NYNEX will use to provide these functions will be the same for the nonaffiliated PSPs as well as the affiliated PSPs, and that it  X-will train personnel responsible for network services to treat affiliated and nonaffiliated PSPs  X-in a nondiscriminatory manner.K](  xP#-ԍXxNYNEX Reply at 11.(#K Moreover, NYNEX asserts that the time intervals for providing installation, maintenance and repair will be the same for all PSPs. Finally, we note that the Commission's rules require BOCs to allocate properly the costs, including costs"| ],,(,([[n"  X-associated with the use of personnel, between regulated and nonregulated operations.e^ xPy-ԍXxSee 47 C.F.R.  64.901, 64.903.(#e We  X-also note that, pursuant to section 64.904 of the Commission's rules, LECs that file CAMs are  X-required to have an independent audit performed annually.Y_X xP-ԍXxSee 47 C.F.R.  64.904.(#Y  X-x!34.` ` With respect to IPANY's complaints of past alleged nondiscriminatory conduct by New York Telephone, we do not believe that the pendency of these issues before the New York Commission requires us to find that NYNEX's plan does not satisfy our CEI requirements. Rather, in our view, these matters are better addressed in the state regulatory context. The record in this proceeding shows, according to both NYNEX and IPANY, that discussions are currently underway among New York Telephone, IPANY, and the New York  X -Public Service Commission on the issues raised in IPANY's comments.l`  xP-ԍXxSee IPANY Comments at 23; NYNEX Reply at 12.(#l  X -x"35.` ` Finally, we conclude that NYNEX has sufficiently identified the demarcation point to determine when maintenance becomes the payphone provider's responsibility and is  X -not part of the access network service.a x xP-ԍXxSee Reconsideration OrderĠat  150, 151, 167. Phase I Order, 104 FCC 2d at 1041, para. 162.(#Ʈ NYNEX states that the demarcation point will be "located within 12 inches of the terminal equipment side of the protector, or if there is no  X-protector within twelve inches of the point where the telephone wiring enters the premises."Kb xPI-ԍXxNYNEX Reply at 17.(#K PSP payphones located on pedestals or other types of freestanding locations will have the  Xb-demarcation point in the pedestal.Bcb xP-ԍXxId.(#B NYNEX further represents that the demarcation point for  XK-affiliated and nonaffiliated PSPs will be established consistent with state and federal rules.BdK(  xP$-ԍXxId.(#B  X-x 6.` ` End User Access  X-x#36.` ` 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.e  xP%-ԍxSee Phase I Order, 104 FCC 2d at 1041, para. 162; Payphone Order at para. 199. "H e,,(,([["Ԍ X-x$37.` ` NYNEX represents that affiliated and nonaffiliated PSPs' end users (i.e., the transient public and inmates at correctional facilities) will have access to the same underlying  X-tariffed services through the use of the payphone services provided by the individual PSP.Ef xPK-ԍxNYNEX CEI Plan at 7.E  X-NYNEX maintains that the same networkbased dialing and signaling capabilities will  X-therefore be available to affiliated and nonaffiliated PSP end users.BgX xP-ԍxId. at 78.B Telco argues that NYNEX's description of how it will provide end user access is too vague and that NYNEX  Xv-must specify how end users will obtain access.Mhv xP -ԍXxTelco Comments at 2.(#M We find that NYNEX is not required to provide the information requested by Telco in order to satisfy this CEI parameter. We find that NYNEX's CEI plan comports with the end user access requirement established by the Commission.  X - x 7.` ` CEI Availability  X -x%38.` ` 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 obligates 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  Xy-testing their payphone service offerings.iyx xP-ԍXxPhase I Order, 104 FCC 2d at 1041, para. 163. The testing period is necessary "to balance the conflicting interests of the carrier, which should have a reasonable period to develop, test, and 'debug' its CEI offerings before making them publicly available, and other CEI users, such as competitors, that might suffer an unfair competitive disadvantage if carriers were able to test and perfect their . . . services particularly, their interconnection with the basic underlying facilities while withholding  xP-those same basic facilities from others." Id.(#Ɗ Past decisions also have referred to this as the 90 Xb-day notice requirement.j b  xP-ԍXxSee e.g., Bell Operating Companies' Joint Petition for Waiver of Computer II Rules, Ameritech's Request for Waiver Related to Minor Amendment to Ameritech's Plan to Provide Comparable Efficient  xP-Interconnection to Providers of Voice Mail Messaging Service, CCBPol 9623, DA 961894 (rel. Nov. 14, 1996).(#ƍ  X4-x&39. ` ` 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.hk xPa&-ԍXxSee Clarification Order at para. 8.(#h LECs are not required to file tariffs for the basic payphone line for smart and dumb"hk,,(,([["  X-payphones with the Commission.gl xPy-ԍXxReconsideration 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 their own operations or to others . . . ."_mX xP-ԍXxClarification Order at para. 18.(#_  X-x'40.` ` The Clarification Order also granted all LECs a limited waiver of the federal tariffing requirements for unbundled features and functions that a LEC must meet before it is eligible to receive payphone compensation. Pursuant to this waiver, LECs must file interstate tariffs for unbundled features and functions within 45 days of the release date of the  X1-Clarification Order.On1 xP -ԍXxId. at para. 21.(#O In addition, each individual BOC was required to file by April 10,  X -1997, a written ex parte document advising 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 that Order.Oo x xP-ԍXxId. at para. 22.(#O  X -x(41.` ` NYNEX represents that its payphone service operations will offer payphone services on a regionwide basis and it will use a combination of its Smart PAL and Basic PAL services, which are available to other carriers under the same rates, terms, and conditions  Xy-and at the same time to all PSPs.Mpy xP2-ԍXxNYNEX CEI Plan at 8.(#M NYNEX further represents that, in the event that it plans to introduce a new underlying basic service or unbundled feature, it will provide notice and a testing capability to PSPs at least ninety days before using such services in the provision of its  X4-own payphone services.Bq4 xP}-ԍXxId.(#B NYNEX filed with its CEI plan state tariffs for the Smart PAL  X-services that it will offer in each of the states in which it provides local telephone services.`r(  xP-ԍXxSee NYNEX CEI Plan, Attachment A.(#` Generally, these tariffs also include the Basic PAL services that NYNEX currently offers in those states.  X-x)42.` ` APCC and NEPCC contend that NYNEX's CEI plan must be rejected because  X-NYNEX did not file the required federal tariffs.as  xP%-ԍXxAPCC Comments at 5; NEPCC Comments at 3.(#a They contend that, pursuant to the  X-Reconsideration Order, NYNEX must file tariffs for unbundled features at both the state and  X|-federal level, and that the only service for which a federal tariff is not required is the basic"|H s,,(,([["  X-line for smart and dumb payphones.at xPy-ԍXxAPCC Comments at 5; NEPCC Comments at 3.(#a In response, NYNEX contends that it is in compliance with the payphone rulemaking proceeding's federal tariffing requirement, as implemented by  X-the Clarification Order.uX xP-ԍXxSee Letter from Alan S. Cort, NYNEX, to William F. Caton, Acting Secretary, Federal Communications Commission (Apr. 10, 1997).(#ƽ In an ex parte filing, NYNEX represents that it will file federal  X-tariffs, in accordance with the requirements of the Clarification Order, for the following  X-unbundled features: line side answer supervision, direct dial screening, operator number  X-screening, and terminating number screening.Bv xP -ԍXxId.(#B  X_-x*43.` ` APCC also contends that NYNEX must be required to disclose how many of its payphones in each jurisdiction are subscribed to Basic PAL service and how many are  X1-subscribed to coin line service.Lw1@ xP"-ԍXxAPCC Comments at 4.(#L APCC further argues that, because NYNEX's tariffs for coin line services offer such services subject to the availability of facilities, NYNEX must be required to disclose where coin line service is not available and whether it has any payphones  X -currently installed in those areas.Jx  xPm-ԍXxId. at 89.(#J NEPCC contends that, if NYNEX has any payphones in  X -those areas, it must convert them to Basic PAL service.My `  xP-ԍXxNEPCC Comments at 6.(#M AT&T argues that, at minimum,  X -NYNEX's CEI plan must be amended to clarify that Smart PAL service will be available to independent PSPs at every central office where such service is provided to NYNEX's  X-payphone operations, and to reflect such conditions of availability in its tariffs.Lz  xP1-ԍXxAT&T Comments at 2.(#L  Xb-x+44. ` ` NYNEX responds that, at present, its payphone operations will subscribe only  XK-to NYNEX's Smart PAL services, rather than its Basic PAL services.P{K  xP|-ԍXxMarch 20th Letter at 2.(#P NYNEX responds to AT&T's request for clarification by stating that its Smart PAL services will be available to nonaffiliated PSPs in all central offices where such services are provided to NYNEX's  X-payphone operations.J| xP#-ԍXxNYNEX Reply at 6.(#J"|,,(,([[F"Ԍ X- "A x,45. ` ` We find that NYNEX's plan complies with the CEI availability requirement.} xPy-ԍXxWe note that our conclusion that NYNEX's CEI plan complies with the CEI availability requirement, and therefore our approval of its CEI plan, is contingent on the effectiveness of NYNEX's state tariffs for payphone services. We note further that, because we are relying on the states to review LEC tariffs for basic payphone lines, our conclusion that NYNEX has satisfied the CEI availability requirement does not represent a determination that NYNEX's basic payphone lines are tariffed in  xPa-accordance with the requirements of section 276. See also infra  STATETAR64.(#ƥ We reject the arguments of APCC and NEPCC that NYNEX must file a federal tariff for all payphone service features and functions except for the basic access line for Basic PAL and  X-Smart PAL service. 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  Xv-operations or to others._~v@ xPg -ԍXxClarification Order at para. 18.(#_ Because NYNEX will use, and offer, the features and functions of its Smart PAL services on a bundled basis, NYNEX need not unbundle those features and thus need not file a separate federal tariff for them at this time. As noted, NYNEX has committed to file federal tariffs for the unbundled payphone features offered in conjunction with its Basic PAL services.  X -x-46. ` ` We also conclude that NYNEX is not required to identify in its CEI plan specific geographic areas where Smart PAL service is not available or to state whether NYNEX has any payphones in such areas or what type of service, Smart PAL or Basic PAL, is being provided. NYNEX's New York state tariff provides that Smart PAL services are  X-furnished from suitably equipped central offices, subject to the availability of facilities. xP-ԍXxNYNEX CEI Plan, Attachment A (New York Tariff Revisions, Section 3, Page 14).(#Ɔ NYNEX represents that its Smart PAL services will be available to nonaffiliated PSPs in all  Xb-central offices where such services are provided to NYNEX's payphone operations.Tb`  xPs-ԍXxSee NYNEX Reply at 6.(#T We find that the state tariffs together with representations made by NYNEX provide adequate information concerning the availability of its Smart PAL services for purposes of our CEI plan requirements. We also find no basis in our CEI requirements or the payphone orders for directing NYNEX to identify how many of its payphones are subscribed to Basic PAL and how many are subscribed to Smart PAL for purposes of satisfying our CEI requirements.  X-x.47.` ` Finally we waive on our motion the 90day notice requirement for NYNEX's provision of Smart PAL services. Therefore, NYNEX may continue to provide Smart PAL 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, NYNEX has been offering payphone services using its Smart PAL services for some time. To bar NYNEX from continuing to use its Smart PAL services to provide payphone service for a period of"7 ,,(,([["  X-ninety days could result in a suspension of service. NYNEX is not, however, relieved of its obligation to permit unaffiliated PSPs upon request to conduct testing of NYNEX's Smart PAL offerings. For purposes of approving NYNEX's CEI plan, we simply waive the requirement that NYNEX's payphone operations may not use NYNEX's Smart PAL services  X-before such testing is accomplished.(X xP-ԍXxThe waiver provided herein does not effect the six specific requirements established in the payphone  xP-proceeding that carriers must meet before receiving compensation. See Reconsideration Order at para. 131.(#( If and when other basic payphone services are deployed, NYNEX must make testing capability available to unaffiliated PSPs at the same time that such capability is available to NYNEX's payphone operations, which NYNEX has committed to do.  XH-  X1-x 8.` ` Minimization of Transport Costs  X -  X -x/48.` ` This requirement obligates carriers to provide competitors with interconnection  X -facilities that minimize transport costs.  xP-ԍxPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.164. NYNEX asserts that it will charge affiliated and  X -nonaffiliated PSPs the same tariffed rates for basic payphone services.E x xP-ԍxNYNEX CEI Plan at 9.E We find that  X -NYNEX's CEI plan comports with the minimization of transport costs requirement.  xPw-ԍxSee Payphone Order at para. 203; Phase II Reconsideration Order, 3 FCC Rcd. 1155, paras. 3234.  X -  X-x 9.` ` Recipients of CEI  Xb-x049. This requirement prohibits a BOC from restricting the availability of its CEI  XK-offering to any particular class of customer or PSP.K xP-ԍxPayphone Order at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.165.  X-x150.` ` NYNEX avers that all of the basic services that it will use to provide its  X-payphone services are offered under existing tariffs to all PSPs and customers.E(  xP-ԍxNYNEX CEI Plan at 8.E We find that NYNEX has proposed to provide service to CEI recipients in compliance with the Commission's requirements.  X-" ,,(,([["Ԍ X- B.xOther Nonstructural Safeguards  X-x251. In addition to the CEI requirements established in Computer III, and applied to  X-BOC provision of payphone services in the Payphone Order, xP4-ԍXxPayphone Order at para. 202. See also Reconsideration Order at para. 210.(#ƛ a BOC that provides payphone  X-services must comply with requirements regarding the use of customer proprietary network  X-information (CPNI), disclosure of network information, and nondiscrimination reporting.gX xP-ԍxPhase II Order, 2 FCC Rcd at 3082, paras.7375.g  X_-x1.` ` Customer Proprietary Network Information  X1-x352. ` ` The Payphone Order requires NYNEX to explain how it will comply with the  X -ComputerIII CPNI safeguards,c  xP-ԍxSee id., 2 FCC Rcd at 3095, para.156.c to the extent they are not inconsistent with section 222 of  X -the 1996 Act, as amended. x xP,-ԍxPayphone Order at para. 205 (citing 47 U.S.C.  222 and the 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  X -obligations under this provision._  xPw-ԍxCPNI NPRM, 11 FCC Rcd at 12514, para. 2._ The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they  X-do not conflict with section 222. xP-ԍXxId. at 12515, 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).(#  Xb-x453. ` ` In its CEI plan, NYNEX represents that, until such time as the Commission issues regulations in the CPNI rulemaking, it will comply with the requirements of section  X4-222 and with any existing Commission CPNI requirements that are not inconsistent with  X-section 222.S  xP-ԍXxNYNEX CEI Plan at 10 n.25.(#S NYNEX also states that, absent customer consent, the marketing and sales personnel in its payphone operations will be restricted from access to the CPNI associated  X-with other customers or PSPs.I  xP #-ԍXxId. at 10.(#I In addition, any aggregate customer information derived  X-from such data provided to NYNEX's payphone operations will be made available to other",,(,([[" carriers or persons on reasonable and nondiscriminatory terms and conditions upon reasonable  X-request.B xPb-ԍXxId.(#B  X-x554. ` ` APCC and Telco claim that NYNEX's CEI plan does not offer sufficient  X-information concerning how NYNEX will comply with CPNI requirements, but rather merely states that NYNEX will follow existing procedures, except where inconsistent with Section  Xv-222.\vX xP -ԍxAPCC Comments at 19; Telco Comments at 4. \ APCC contends that NYNEX should explain how it will protect, under nondiscriminatory conditions, the CPNI of PSPs, as well as the CPNI of NYNEX's existing  XH-customers, including current customers of semipublic payphone service.VXH xP -ԍXxAPCC comments at 1920. See also Letter from Michael S. Wroblewski, on behalf of Peoples Telephone Company, Inc., to William S. Caton, Acting Secretary, Federal Communications  xPq-Commission (March 5, 1997) (Peoples's March 5 Ex Parte). (#V APCC argues  X1-that, since the existing tariffed semipublic service is being terminated, NYNEX's payphone personnel have no more right to access and use the CPNI of semipublic service end users that  X -any other PSP.M  xP-ԍXxAPCC Comments at 20.(#M APCC also contends that the deregulation of semipublic service presents PSPs with a potential marketing opportunity to replace NYNEX as the payphone service provider for these customers. APCC argues that semipublic customers should be provided  X -notice and a meaningful opportunity to replace NYNEX with another payphone service provider. It contends that NYNEX must disclose how it will provide such notice in a neutral fashion, including giving such customers an opportunity to authorize disclosure of CPNI on a nondiscriminatory basis to interested payphone providers without preference to NYNEX's  Xb-payphone operations.Nb xP-ԍXx Id. at 2021. (#N  XK-  X4- x655. ` ` NYNEX urges us to reject APCC's argument that the Commission apply special rules to semipublic payphone location providers on the ground that its claim  X-constitutes an untimely request for reconsideration of the payphone orders.K(  xP-ԍXxNYNEX Reply at 19.(#K  X-x756. ` ` In providing payphone services, NYNEX must comply with the Commission's  X-preexisting Computer III CPNI requirements, to the extent that they are consistent with section 222 of the Communications Act, as amended, and any regulations adopted by the Commission pursuant to section 222. NYNEX represents that it will comply with section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. Accordingly, we find that NYNEX's plan comports with CPNI requirements. In reaching this conclusion, we do not address issues raised by APCC relating to the CPNI associated with"N ,,(,([[" semipublic payphones. Issues relating to the interpretation of section 222, and how it relates  X-to the Computer III CPNI rules, are being addressed in the CPNI rulemaking, and therefore will not be considered here. We do, however, reject APCC's request that we require NYNEX to inform site owners about competitive options for semipublic payphone service, because no  X-such requirement was adopted in the Payphone Order or in the Reconsideration Order, or is otherwise required by our CEI rules.  X_-x 2.` ` Network Information Disclosure (#`  X1- x857.` ` The Payphone Order requires NYNEX to disclose to the payphone services industry information about network changes and new network services that affect the  X -interconnection of payphone services with the network.S  xP| -ԍxPayphone Order at para. 206.S NYNEX must make that disclosure at the "make/buy" point, that is, when NYNEX decides whether to make or to procure from  X -an unaffiliated entity any product whose design affects or relies on the network interface.r X xP-ԍXxPhase II Order, 2 FCC Rcd at 3086, para. 102.(#r  X -NYNEX must provide that information to members of the payphone services industry that sign a nondisclosure agreement, within 30 days after the execution of the nondisclosure  X-agreement.` xP)-ԍXxId. at 30913093, paras. 134140.(#` NYNEX also must publicly disclose technical information about a new or  Xy-modified network service twelve months prior to the introduction of that service.nXyx xP-ԍXxId. at 3092, para. 136. We note that under the Commissions rules, if a BOC is able to introduce the service within twelve months of the make/buy point, 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. (#n  XK-x958.` ` In the Payphone Order, the Commission waived the notice period for disclosure of network information relating to the "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory  X-requirements of that order.[ xPO-ԍXxPayphone Order at para. 146.(#[ Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15,  X-1997.L(  xP!-ԍXxSee id.(#L  X-x:59.` ` As described above, NYNEX asserts that it made the necessary network  X-disclosure for its new network interface in December 1996.c  xP%-ԍxSee supra  DISCLOSURE21.c NYNEX represents that all  X|-other underlying network services or features that its payphone operations may use are"|H ,,(,([[n"  X-available under existing tariffs.N xPy-ԍXxNYNEX CEI Plan at 11.(#N It also represents that it will continue to comply with the  X-existing, and any revised, network information disclosure requirements.BX xP-ԍXxId.(#B We find therefore that NYNEX's CEI plan comports with the Commission's network information disclosure requirements.  X-x 3.` ` Nondiscrimination Reporting  X_-x;60.` ` In the Payphone Order, we directed the BOCs to comply with the Computer III  XH-and ONA requirements regarding nondiscrimination in the quality of service, installation, and  X1-maintenance.S1 xP -ԍxPayphone Order at para. 215.S Specifically, BOCs are required to file the same quarterly nondiscrimination  X -reports, and annual and semiannual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of covered service  X -offerings, installation and maintenance.;x x xP-ԍXxSee id. at para. 207; BOC ONA Reconsideration Order, 5 FCC Rcd 3084, 3096, Appendix B (1990),  xP-BOC ONA Amendment Order, 5 FCC Rcd 3103 (1990), Erratum, 5 FCC Rcd 4045, pets. for review  xP-denied, California II, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 7646 (1991), BOC ONA  xPV-Second Further Amendment Order, 8 FCC Rcd 2606 (1993), pet. for review denied, California II, 4  xP-F.3d 1505 (9th Cir. 1993); Phase II Order, 2 FCC Rcd at 3082, para.73; and Filing and Review of  xP-Open Network Architecture Plans, CC Docket No. 882, Memorandum Opinion and Order, Phase I, 6 FCC Rcd 7646, 764950 (1991).(#;  X -x<61.` ` NYNEX represents that it will establish procedures and processes that will ensure that the time periods and quality of service associated with the installation, maintenance, and repair of basic services that are used in the provision of NYNEX's  Xb-payphone services are the same as those experienced by nonaffiliated PSPs.Eb  xP-ԍxNYNEX CEI Plan at 9.E It also commits to modify its quarterly Enhanced Services ONA Nondiscrimination Parity Report to  X4-provide installation and maintenance performance data on basic network services provided to  X-affiliated PSPs.AH  xP"-ԍxId. at 10.A Finally, NYNEX commits to address its provision of payphone services in its annual affidavit attesting that NYNEX has followed the appropriate and approved nondiscrimination procedures outlined in its ONA Plan relative to the provision of enhanced services. We find that NYNEX's CEI plan comports with the Commission's nondiscrimination reporting requirements. ",,(,([["Ԍ X- C.xAccounting Safeguards  X-x=62.` ` In the Payphone Order and the Accounting Safeguards Order, the Commission  X-concluded that it should apply accounting safeguards identical to those adopted in Computer  X-III to BOCs providing payphone service on an integrated basis. xP-ԍXxPayphone Order at paras.157, 199, 201; Accounting Safeguards Order at para. 100.(#ƕ 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  X -of detailed reporting requirements and the development of an automated system to store and  X -analyze the data; and (5) the performance of onsite audits by Commission staff. X xP-ԍx#c P P#BOC Safeguards Order, 6 FCC Rcd at 7591, para. 46. NYNEX must comply with these accounting safeguards. We note that the approval granted to NYNEX in this order is contingent upon the CAM amendments associated with NYNEX's provision of payphone service going into effect.  XK- D.xOther Issues  X-x 1.` ` Sufficiency  X-x>63.` ` APCC, NEPCC and Telco generally assert that NYNEX's CEI plan  X-insufficiently describes how NYNEX intends to comply with the CEI parameters; therefore,  X-these parties request that the Commission require NYNEX to either amend or refile its plan.T xPZ-ԍxAPCC Comments at 12; Telco at 24.T As discussed above, however, we find that NYNEX adequately complies with each of the  X-required parameters.  Xe- x2.` ` Tariffing Issues  X7-x?64.` ` APCC, NEPCC, and IPANY raise various objections to the content of  X -NYNEX's state tariffs.{ x xPI$-ԍXxAPCC Comments at 56; NEPCC Comments at 4; IPANY Comments at 911.(#{ For instance, IPANY asserts that NYNEX's prices for its Smart PAL and Basic PAL services in its New York state tariffs are discriminatory and that  X-NYNEX should be prohibited from offering its payphone operations any special rates not",,(,([[Z"  X-effectively available (because of volume or term conditions) to unaffiliated PSPs.Y xPy-ԍXxIPANY Comments at 911, 1517. (#Y NYNEX responds that these state tariff issues fall outside the scope of this proceeding, because the Commission has delegated to the states the responsibility of ensuring that the BOCs' state  X-tariffs are in compliance with section 276.JX xP-ԍXxNYNEX Reply at 5.(#J NYNEX also claims that any discount or individual contract basis offerings will be statetariffed offerings, subject to state commission  X-review and available to all PSPs on a nondiscriminatory basis.J xP& -ԍXxId. at 67.(#J  X_-x@65. ` `  STATETAR We agree with NYNEX that the state payphone tariff proceedings are the appropriate fora to address complaints concerning rates or terms and conditions in NYNEX's  X1-state tariffs. The Commission stated in the Reconsideration Order that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with the  X -requirements of section 276."Z x xP,-ԍxReconsideration 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.  xPw-ԍXxReconsideration Order at para. 163; see also id. at n.492 (noting that the "new services test required in  xP?-the Report and Order is described at 47 C.F.R. Section 61.49(g)(2)").(# In addition, the order established that "[s]tates must apply these  X -requirements and the Computer III guidelines for tariffing such intrastate services."H `  xP-ԍxId. at para. 163.H The order further stated that "[w]here LECs have already filed intrastate tariffs for these services,  Xy-states may, after considering the requirements of this order, the Report and Order, and section  Xb-276 conclude: (1) that existing tariffs are consistent with the requirements of the Report and  XK-Order as revised herein; and (2) that in such case no further filings are required.":K  xP-ԍxId.: Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs  X-operating in their state to file these tariffs with the Commission.":  xPN!-ԍxId.:  X-x 3.` ` Screening Codes  X-xA66.` ` Several parties contend that NYNEX is required, pursuant to the  X-Reconsideration Order, to provide PSPs using COCOT lines with screening code digits that",,(,([["  X-uniquely identify their lines as payphone lines. xPy-ԍxAPCC Comments at 1517; MCI Comments at 12; AT&T Comments at 3; NEPCC Comments at 9. APCC asserts that if NYNEX transmits a unique code only on its coin lines, which are primarily used only by NYNEX's own  X-payphone operations, and not on its COCOT lines, which are primarily used by unaffiliated PSPs, NYNEX is discriminating in favor its payphone division by providing it a great  X-advantage in the collection of percall compensation from interexchange carriers.MX xP-ԍXxAPCC Comments at 17.(#M In addition, MCI maintains that NYNEX does not provide screening code digits that can be  Xv-"transmitted by PSPs for all access methods and from all locations."v xP -ԍXxMCI Comments at 2. MCI maintains that, for example, LECs "do not provide [automatic number identification] (ANI) or information digits with Feature Group B access and from nonequal access areas." Accordingly, argues MCI, "PSPs would be able to transmit specific payphone coding digits from payphones in these circumstances and, therefore, they would not be eligible for compensation."  xP/-Id.(#  XH-xB67.` ` NYNEX responds that it will not discriminate in the provision of screening code digits. Regardless of the identity of the PSP, all traffic originated on Basic PAL and  X -Smart PAL lines will transmit ANI coding digits "27" and "07," respectively.J  xPc-ԍXxNYNEX Reply at 9.(#J NYNEX explains that a screening code discretely identifying the COCOT line as a payphone will be  X -provided to interexchange carriers through the use of a Line Information Database.B (  xP-ԍXxId.(#B NYNEX contends that this approach satisfies the screening code requirements established by  X -the Commission.  xP'-ԍXxId. NYNEX also contends that it is not required to provide ANI or information digits with Feature  xP-Group B services. Id. at 10 n.28.(#  X-xC68.` ` We find that the issue of whether NYNEX 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  XK-proceeding or in other proceedings.K xP !-ԍXxSee, e.g., Policy and Rules Concerning Operator Service Access and Pay Telephone Compensation, CC Docket No. 9135, CCB/CPD File Nos. 9618, 9625, and 9632, Memorandum Opinion and Order, DA 962169 at 2 n.7 (rel. Dec. 20, 1996) (citing MCI petition for clarification of LECs' obligation to provide screening code digits and stating that MCI's petition would be addressed in a  xP,$-subsequent order). We note that in its Reconsideration Order, the Commission stated that, once percall compensation becomes effective, "[e]ach payphone must transmit coding digits that specifically  xP%-identify it as a payphone, and not merely as a restricted line." Reconsideration Order at para. 64. That order further required that "all LECs must make available to PSPs, on a tariffed basis, such  xPL'-coding digits as part of the ANI for each payphone." Id.(#"K,,(,([[g"Ԍ X-ԙ x4 .` ` Numbering Assignments  X-  X-xD69.` ` According to APCC and NEPCC, the Payphone Order requires LECs to assign  X-line numbers to payphones on a nondiscriminatory basis.Q xP4-ԍxAPCC at 14; NEPCC Comments at 9.Q APCC contends that NYNEX should be required to reallocate the numbers assigned to the existing base of payphones, without charge, so that an equal percentage of LEC payphones and PSPs are assigned 8000  Xv-and 9000 series numbers.XXvX xP -ԍXxAPCC Comments at 14 n.12. APCC states that assignment of numbers in the 8000 to 9000 range provides LEC payphones with a distinct advantage in the prevention of fraud by alerting overseas  xP -operators to refrain from completing collect calls to such numbers. Id.(#X In reply, NYNEX asserts that it will apply the same number assignment process for NYNEX's payphone operations and nonaffiliated PSPs and will not  XH-reserve any special block of numbers for its payphone operations.CHx xPq-ԍxNYNEX Reply at 10.C  X -xE70.` ` We agree with APCC that the Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to  X -reallocate existing number assignments.S  xP-ԍxPayphone Order at para. 149.S NYNEX states that it will assign payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by NYNEX in the context of its CEI plan.  X-x 5.` ` Dialing Parity  Xy-  Xb-xF71.` ` MCI asserts that NYNEX does not explain how it will comply with the dialing  XK-parity requirements in the Payphone Order, including access to operator service, directory  X4-assistance, and directory listings.F4 xP}-ԍxMCI Comments at 23.F  X-xG72.` ` The Payphone Order concluded that the dialing parity requirements adopted pursuant to section 251(b)(3) of the Communications Act should extend to all payphone  X-location providers.S(  xP!-ԍxPayphone Order at para. 292.S NYNEX must, of course, comply with these requirements. We conclude, however, that NYNEX is not required as part of the CEI process to demonstrate  X-how it will comply with these dialing parity requirements. In the Payphone Order, the  X-Commission specified that a BOC's CEI plan must describe how it will conform to the CEI parameters with respect to the specific payphone services it intends to offer and how it will"| ,,(,([[P"  X-unbundle those basic payphone services.V xPy-ԍxPayphone Order at para. 20304.V Therefore, MCI's request that NYNEX detail how it will comply with the dialing parity requirement is outside the scope of this CEI review proceeding.  X-  X-x 6.` ` Uncollectibles  Xv-xH73. ` ` AT&T asserts that NYNEX must explain its treatment of uncollectibles due to fraud. AT&T contends that, to the extent NYNEX establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be  X1-accorded to nonaffiliates.N1X xP: -ԍXxAT&T Comments at 34.(#N NYNEX responds that it does not intend to establish any policy of foregoing uncollectibles due to fraud that would discriminate between its payphone  X -operations and nonaffiliated PSPs.K  xP-ԍXxNYNEX Reply at 10.(#K  X -xI74.` ` 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 NYNEX's CAM.  Xb-x 7.` ` Operator Services  X4-xJ75.` ` APCC and NEPCC contend that NYNEX's CEI plan fails to address whether  X-NYNEX's intraLATA operator services are part of its deregulated payphone services.[x xPF-ԍxAPCC Comments at 18; NEPCC Comments at 10.[ APCC argues that, if operator services are part of NYNEX's regulated operations, NYNEX must show that it is not subsidizing its payphone operations or discriminating between its  X-payphone operations and unaffiliated PSPs in the provision of operator services.M xP-ԍXxAPCC Comments at 18.(#M For example, if NYNEX is offering a commission to its payphone operations for presubscribing its payphones to NYNEX's operator services, then such commissions must also be available to unaffiliated PSPs on the same terms and conditions. IPANY contends that it is not clear from NYNEX's CEI plan whether certain services, such as repair referrals and coin refunds, will be  Xe-provided by NYNEX to PSPs subscribing to its Basic PAL services.Qe xP$-ԍXxIPANY Comments at 1112.(#Q NYNEX responds that"e( ,,(,([[" all of the regulated services provided by NYNEX to PSPs including any operator or switch X-based services will be provided on a nondiscriminatory basis.X xPb-ԍxNYNEX Reply at 7. NYNEX represents that, as of April 1, 1997, its operator services operations will  xP*-no longer provide repair referral or coin refund services to payphone providers. Id. at 8 n.20. See also March 20th Letter (describing the way in which NYNEX's payphone operations will provide coin refunds).   X-xK76.` ` Operator services are tariffed regulated services, which must be offered to affiliated and nonaffiliated PSPs on a nondiscriminatory basis. We note that, in the  X-Reconsideration Order, the Commission declined to require LECs to make available, on a nondiscriminatory basis, any commission payments provided to their own payphone divisions in return for the presubscription of operator service traffic to the LEC, because the  XH-Commission concluded that the level of 0+ commissions paid pursuant to contract on operator  X1-service calls was beyond the scope of section 276 and the Payphone proceeding.Y1 xP -ԍxReconsideration Order at para. 52.Y We conclude that NYNEX has sufficiently addressed the concerns raised by APCC, NEPCC, and IPANY.  X - x8.` ` Inmate Calling Services Issues  X -xL77.` ` The Inmate Calling Service Provider Coalition (ICSPC) raises a number of issues related to the provision of inmate calling services (ICS). ICSPC contends that NYNEX should be required to identify the network support and tariffed services its regulated  Xb-operations will provide to its ICS operations.Kbx xP-ԍxICSPC Comments at 23, 10.K ICSPC also argues that NYNEX must  XK-disclose whether its regulated operations will provide its ICS operations with inmate call processing and call control functions and information for fraud protection and the validation  X-of called numbers.O xP-ԍxId. at 1012, 1416, 18.O ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. In addition, ICSPC asserts that NYNEX should be required to disclose whether its payphone operations will be responsible for the costs of  X-ICS calls for which NYNEX's payphone operations do not receive compensation.L xP! -ԍXxId. at 1718.(#L According to ICSPC, NYNEX's failure to describe its provision of ICS in detail prevents the Commission from determining whether NYNEX has complied with the requirements of  X-section 276.@(  xPl$-ԍxId. at 3.@  Xe-xM78.` ` ICSPC also asserts that NYNEX must show that any call processing and call control system used for its ICS is being provided on a deregulated basis, regardless of"N ,,(,([["  X-whether that system is located at a central office or at a customer premises.@ xPy-ԍxId. at 9.@ According to ICSPC, to the extent NYNEX's call processing and call control systems dedicated to ICS are  X-located in NYNEX's central offices, NYNEX must provide physical or virtual collocation to  X-other providers.AX xP-ԍxId. at 18.A ICSPC also contends that NYNEX must disclose information on interfaces between NYNEX's equipment dedicated to ICS and its regulated network support services, so  X-that other providers can utilize the same interface if they wish.A xP& -ԍxId. at 19.A  X_-xN79.` ` In a subsequent ex parte filing,_x xP -ԍXxSee Letter from Albert H. Kramer, counsel for ICSPC, to William F. Caton, Acting Secretary, Federal Communications Commission (Mar. 19, 1997). (# ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations  X1-because collect calling is fundamental to ICS.J1 xP-ԍXxId. at 12.(#J According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its networkbased operator services division for processing and that division assumes the responsibility and risk associated with billing and  X -collecting for those calls, then the BOC is essentially providing ICS as a regulated service and  X -is still subsidizing that service, contrary to the prohibition in section 276.H `  xP-ԍXxId. at 2.(#H  X -xO80.` ` In response, NYNEX contends that its CEI plan shows that NYNEX will  X-provide ICS on a deregulated basis, as required by the Commission and by section 276.C  xP1-ԍxNYNEX Reply at 15.C NYNEX further contends that the underlying network services used to interconnect NYNEX's  Xb-ICS are available on a tariffed basis to all PSPs under the same prices, terms, and  XK-conditions.:K  xP|-ԍxId.: Although the equipment used to provide NYNEX's ICS is presently located on the customers' premises, NYNEX contends that it is permitted to locate such equipment within its switching centers without providing such collocation capability to nonaffiliated  X-carriers.F xP#-ԍxId. at 15 n.40.F NYNEX asserts that no network based functionalities used for fraud control and  X-validation in the context of ICS will be uniquely available to NYNEX's PSP operations.A xP@&-ԍxId. at 16.A " 0,,(,([[E" With respect to uncollectibles, NYNEX asserts that its treatment of uncollectibles will be the  X-same for calls that originate on NYNEX ICS payphones and other pay telephones.F xPb-ԍxId. at 16 n.42.F x  X-xP81.` ` Section 276 specifically defines payphone service to include the provision of  X-inmate telephone service in correctional institutions.GX xP-ԍx47 U.S.C.  276(d).G In the Reconsideration Order, we  X-clarified that the requirements of the Payphone Order apply to inmate payphones that were  Xv-deregulated in an earlier order. v xP -ԍXxReconsideration Order at para. 131 (citing Petition for Declaratory Ruling by the Inmate Calling  xP -Services Providers Task Force, Declaratory Ruling, 11 FCC Rcd 7362, 7373 (rel. Feb. 20, 1996)  xP -(Inmate Service Order); Petitions for Waiver and Partial Reconsideration or Stay of InmateOnly  xPg -Payphones Declaratory Ruling, Order, 11 FCC Rcd 8013 (Com. Car. Bur. 1996)).(# Thus, NYNEX is required to reclassify as unregulated assets all of its payphone assets related to its provision of ICS, with the exception of the loops  XH-connecting the inmate telephones to the network, the central office "coin service" used to  X1-provide the ICS, and the operator service facilities used to support the ICS.c1 xP-ԍxSee Payphone Order at paras. 157, 159.c In addition, NYNEX is required to offer on a tariffed basis any basic payphone service or network feature  X -used by its payphone operations to provide ICS. `  xP-ԍxSee id. at paras. 14649; Reconsideration Order at paras. 16263.  X -xQ82.` ` We conclude that NYNEX's CEI plan comports with our CEI requirements with respect to its provision of ICS. NYNEX avers that it will deregulate all of its payphone  X -equipment, including that used for ICS,E  xPH-ԍxNYNEX CEI Plan at 2.E and that the underlying network services used to interconnect NYNEX's ICS are available on a tariffed basis to all PSPs under the same terms,  Xy-prices, and conditions.Fy  xP-ԍxNYNEX Reply at 15. F As previously noted, NYNEX will use its newlytariffed Inmate  Xb-PAL service to provide inmate calling services.Qb xP# -ԍXxMarch 20th Letter at 2. (#Q Although we agree with ICSPC that any call processing and call control equipment related to NYNEX provision of ICS must be reclassified as deregulated CPE, regardless of whether that equipment is located in a customer  X-premises or a NYNEX central office, xPn$-ԍxPayphone Order at paras. 157, 159. See also Inmate Service Order, 11 FCC Rcd at 7373. NYNEX represents that it has done so. We also note  X-that NYNEX has committed to make any networkbased functionalities it uses for its"!0,,(,([[d"  X-provision of ICS available to all PSPs on a nondiscriminatory basis.M xPy-ԍxSee NYNEX Reply at 16.M More specifically, NYNEX states that PSPs can obtain the same fraud control and CLEC validation information available to NYNEX through NYNEX's LIDB database. In the alternative, a PSP can obtain such information via NYNEX's Operator Services, which NYNEX offers to all carriers on a  X-tariffed basis.:X xP-ԍxId.: We find no support in the Payphone Order or Reconsideration Order for ICSPC's contention that NYNEX is required to provide collect calling as a nonregulated service when used with inmate payphones.  XH-xR83.` ` 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 the ICSPC has cited no authority, that obligates NYNEX to allow collocation of nonaffiliated providers' call processing and call control equipment in a central office. As previously noted, the issue of NYNEX's treatment of uncollectibles will be addressed in the review of NYNEX's CAM. Finally, with regard to the disclosure of interface information, we have already concluded that NYNEX's CEI plan comports with the Commission's network information disclosure requirements.  Xb-x 9.` ` Primary Interexchange Carrier Selection  X4-xS84.` ` Oncor asserts that, in order for NYNEX's CEI plan to comply with the "spirit"  X-of the Commission's CEI requirements, the plan must address various issues concerning the  X-payphone primary interexchange carrier (PIC) selection process. xP-ԍXxOncor Comments at 5. According to Oncor, NYNEX 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 NYNEX 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 NYNEX or anyone else; (3) how its marketing personnel will be trained and supervised to ensure that they do not misrepresent NYNEX'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  xP-interexchange services from payphones. Id.(#Ɠ AT&T also asserts that NYNEX's CEI plan should describe how NYNEX will ensure that the PIC selection process  X-for payphones will be performed on a nondiscriminatory basis.D  xPA#-ԍxAT&T Comments at 4.D In reply, NYNEX contends that the PIC selection issue is outside the scope of this CEI proceeding. It also represents that  X-it will process all customers' PIC selections in a nondiscriminatory manner.KH  xP&-ԍXxNYNEX Reply at 17.(#K"",,(,([[R"Ԍ X-ԙxT85.` ` We conclude that NYNEX is not required as part of the CEI process to  X-demonstrate how it will administer the PIC selection process for payphones. In the Payphone  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  X-it will unbundle those basic payphone services.W xP-ԍxPayphone 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 requested by AT&T and Oncor. Therefore, arguments raised by parties regarding NYNEX's role as PIC administrator are beyond the scope of this proceeding.  X1-x 10.` ` Call Rating  X -xU86. ` ` APCC contends that, in order to meet the Commission's CEI requirements, NYNEX must provide a coin line service that allows unaffiliated PSPs to set their own end user rates for local and intraLATA calls, as well as to establish the length of initial and  X -overtime periods.bX X xP-ԍXxAPCC Comments at 911. See also NEPCC Comments at 67; IPANY Comments at 1213. An example of an initial rate is $0.25 for the first five minutes. An example of an overtime rate is $0.05 for each additional three minute period after the first five minutes. APCC Comments at 10 n.7.(#b APCC therefore requests the Commission to require NYNEX to develop  X -a more flexible rating feature for its coin line service.H x xP-ԍxAPCC Comments at 1011.H NYNEX responds that call rating is  X-not a CEI plan review issue.~X xPI-ԍXxNYNEX Reply at 56. According to NYNEX, it is technically infeasible for NYNEX to provide coin rating for multiple carriers. PSPs can establish their own initial rate for a local call, but the NYNEX  xP-switch is currently limited to one rating schedule, which is established by state regulation. Id.(#~ We agree. The Payphone Order did not require the BOCs to  Xy-provide to unaffiliated PSPs an unbundled call rating feature for coin line services.y(  xPR-ԍxPayphone Order at paras. 14648. See also Reconsideration Order at para. 165. In  Xb-addition, on reconsideration of the Payphone Order, in response to a request that the  XK-Commission require access to, inter alia, call rating capabilities,rXK  xP-ԍXxOn reconsideration, the New Jersey Payphone Association requested that the Commission require access to call rating capabilities, answer supervision, call tracking, joint marketing, installation and  xPD -maintenance, and billing and maintenance. See Reconsideration Order at para. 155 (#r the Commission specifically declined to require further unbundling of payphone services beyond those  X-established in the Payphone Order.` xP#-ԍxReconsideration Order at para. 165.` As previously noted, independent PSPs may seek  X-additional unbundling through the 120day ONA process. State regulatory commissions also may impose further unbundling requirements.  X-"#h,,(,([["Ԍ X- x11.` ` Selection of Operator Services Provider  X-xV87.` ` APCC requests that the Commission require NYNEX to amend its CEI plan to provide that all nonemergency operator assisted calls will be sent to the provider selected by  X-the PSP.w xP-ԍxAPCC Comments at 1112. See also NEPCC Comments at 78. w APCC argues that, under section 276, PSPs are entitled to select the operator service provider (OSP) for intraLATA calls, including local, operatorassisted calls, and therefore that, to the extent NYNEX does not permit OSP selection for its coin line service,  X_-its CEI plan is inconsistent with section 276.H_X xPh -ԍxAPCC Comments at 1112.H NYNEX responds that this issue is outside of the scope of this proceeding. NYNEX also represents that it will comply with the OSP  X1-selection requirements established in the Payphone Orders.J1 xP -ԍXxNYNEX Reply at 8.(#J We concur with NYNEX that APCC's request goes beyond the scope of this proceeding, which is limited to determining  X -whether NYNEX's CEI plan complies with the Commission's Computer III CEI requirements.  X - x12.` ` Interim Compensation Scheme  X -  X -xW88.` ` Telco argues that apart from the numerous deficiencies in NYNEX's CEI plan, the Commission should refrain from allowing NYNEX or any BOC to participate in the  Xy-interim compensation scheme outlined in the Payphone Order.>yx xP-ԍxTelco at 58.> We find that this argument is beyond the scope of this CEI proceeding. Moreover, the interim compensation rules were  XK-addressed at length in the payphone rulemaking proceeding.K xP-ԍXxSee, e.g., Reconsideration Order at paras. 114115 (describing the interim compensation mechanism  xP-adopted in the Payphone Order).(#  X-x 13.` ` SemiPublic Service Issues  X-xX89.` ` APCC maintains that, to the extent that NYNEX's payphone operations  X-continue to offer a "semipubliclike" payphone service that involves charging location providers for lines and usage on their payphones, NYNEX must disclose how such a service will be supported by its network operations and how charges for the service will be treated on  X-the subscriber's bill.M`  xP#-ԍXxAPCC Comments at 26.(#M We find these semipublic service issues to be beyond the scope of the CEI review process. "e$ ,,(,([[1"Ԍ X-vx 14.` ` Miscellaneous Other Issues  X-xY90.` ` IPANY raises other issues relating to NYNEX's payphone operations. IPANY claims that NYNEX's CEI plan must be amended to reflect that any commissions paid to  X-NYNEX's payphone operations must be made available on the same basis to nonaffiliated  X-vPSPs.Q xP-ԍXxIPANY Comments at 1315.(#Q IPANY also contends that NYNEX's CEI plan must address NYNEX's accounting treatment for the cost of a conduit connection between a manhole and a public payphone  X_-pedestal.Q_X xPh -ԍXxIPANY Comments at 1718.(#Q We find that these issues are beyond the scope of this proceeding.  X1- V. CONCLUSION ă xZ91. We conclude that NYNEX's CEI plan for its payphone services complies with the  X -Commission's Computer III requirements. Accordingly, in this Order, we approve NYNEX's CEI plan to offer payphone service, as described herein. We also grant NYNEX a waiver of the testing requirement for the provision of its Smart PAL service as described above. " %,,(,([[k "  X-H VI. ORDERING CLAUSE ă  X- x[92. IT IS HEREBY ORDERED that, pursuant to Sections 1, 4(i) and (j), 201, 202, 203, 205, 218, 222, 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, NYNEX's Comparably Efficient Interconnection Plan to Payphone Services Providers IS APPROVED, subject to the requirements and conditions provided herein. x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhA. Richard Metzger, Jr. x` `  hhDeputy Chief, Common Carrier Bureau