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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Pacific Bell and Nevada Bell ) Comparably Efficient Interconnection ) Plan for the Provision of Basic Telephone) Service ) CC Docket No. 96-128 ) Implementation of the Pay Telephone ) Reclassification and Compensation Provisions) of the Telecommunications Act of 1996) ORDER Adopted: April 15, 1997 Released: April 15, 1997 By the Deputy Chief, Common Carrier Bureau: TABLE OF CONTENTS Paragraph I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. SERVICE DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . 6 IV. COMPLIANCE ISSUES . . . . . . . . . . . . . . . . . . . . . . . . 11 A. CEI Plan Requirements . . . . . . . . . . . . . . . . . . . 11 B. Other Nonstructural Safeguards. . . . . . . . . . . . . . . . 54 C. Accounting Safeguards . . . . . . . . . . . . . . . . . . . . 66 D. Other Issues. . . . . . . . . . . . . . . . . . . . . . . . . 67 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96 VI. ORDERING CLAUSES. . . . . . . . . . . . . . . . . . . . . . . . . . 97 I. INTRODUCTION 1. On December 26, 1996, pursuant to the requirements of the Commission's orders in the payphone rulemaking proceeding, Pacific Bell and Nevada Bell (jointly "PacTel") filed a comparably efficient interconnection (CEI) plan for the provision of payphone service. In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan describing how it will comply with the Commission's Computer III CEI equal access parameters and nonstructural safeguards for the provision of payphone services. BOCs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations to provide payphone services. 2. The Commission gave public notice of the filing of PacTel's CEI plan on January 13, 1997. On February 12, 1997, seven parties filed comments with the Commission opposing the plan. PacTel submitted reply comments on February 27, 1997. For the reasons discussed below, we approve PacTel's CEI plan. II. BACKGROUND 3. The payphone rulemaking proceeding implemented Section 276 of the Communications Act of 1934, as amended. Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC that provides payphone service: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone service. The 1996 Act provided that such safeguards must, at a minimum, include the nonstructural safeguards equal to those adopted in the Computer III proceeding. 4. In the Payphone Order, the Commission determined that the Computer III and Open Network Architecture (ONA) nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or cross-subsidize in their provision of payphone service." Accordingly, the Commission required the BOCs to file "CEI plans describing how they will comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI requirements as modified by section 222 of the 1996 Act, network disclosure requirements, and installation, maintenance, and quality nondiscrimination requirements." Obtaining approval of its CEI plan is one of the criteria a BOC must meet before its payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established in the payphone proceeding. 5. The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrument-implemented 'smart payphones' or 'dumb' payphones that utilize central office coin services, or some combination of the two in a manner similar to the LECs." Those tariffs must be filed with the applicable state regulatory commission. Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone operations to provide payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis. III. SERVICE DESCRIPTION 6. PacTel provides several types of local exchange services, which can be used with a "smart" or "dumb" payphone that has touch-tone capability: COPT Service (Basic) service; COPT Coin Line service; COPT Charge-a-Call service; Inmate service, and Enhanced COPT Access Line service. Most of these services can be ordered as either "outward only" or "bothway" service. In all cases, the demarcation point between PacTel's network and unregulated equipment is the minimum point of entry (MPOE). 7. COPT Service (Basic) is a measured (with respect to local calls) local exchange service that is designed to work with "smart" payphone sets. This service is available in two versions: bothway or outward only. This service includes blocking and screening, but the PSP's payphone must provide all desired coin features (such as coin control, call rating, and coin return). While independent PSPs can obtain operator services, including card verification and acceptance, for intraLATA calls, from PacTel, they also may make arrangements with another service provider to do so. 8. COPT Coin Line service is a flat-rated local exchange service that is designed to work with "dumb" payphones. Two versions of this service are available: bothway or outward only. Coin Line service includes central office-based blocking and screening, as well as the following central office-based coin features: coin control, call rating, and coin return. 9. COPT Charge-a-Call service is a measured service designed for coinless payphone sets and may be used only to originate 0+ and toll-free access calls. In particular, the service allows third party, collect, calling card and credit card billing. Two versions of the service are available: bothway or outward only. Billed number screening is included. IntraLATA calls are handled by PacTel's operator services, including its automated card verification and acceptance systems, which generally accept the card of any issuer with which PacTel has a card honoring agreement. 10. Inmate service is offered in several different versions. In California, Pacific Bell offers four measured inmate services for smart payphones, all of which include network- based billed number screening. These services allow PSPs to elect, on a non-chargeable basis, among several types of call handling procedures used by PacTel's operator services are as follows: (1) bothway service that blocks all calls except coin sent-paid calls, intraLATA (toll and local) 0+ collect-only calls, interLATA 0+ calls, and certain free calls; (2) bothway service that blocks all calls except intraLATA 0+ collect-only calls and interLATA 0+ calls; (3) outward only service that blocks all calls except coin sent-paid calls, intraLATA (toll and local) 0+ collect-only calls, interLATA 0+ calls, and certain free calls; and (4) outward only service that blocks all calls except intraLATA 0+ collect-only calls and interLATA 0+ calls. Pacific Bell also offers two flat-rated inmate services for dumb payphones, which include central office coin control and billed number screening. These services allow PSPs to elect, on a non-chargeable basis, among several types of procedures used by PacTel's operator services to handle calls from dumb payphones. These optional procedures are as follows: (1) bothway service that blocks all calls except local coin sent- paid calls and 0+ collect only calls; and (2) outward only service that blocks all calls except local and toll coin sent-paid calls and 0+ collect-only calls. In Nevada, Nevada Bell will offer two inmate services for smart payphones (CPICS). In addition, PSPs may provide CPICS for use by PSPs that wish to offer high capacity digital data services, or, where COPTs or equivalent services are not available, by individual flat rate business line or individual flat rate trunk. These services are: (1) measured line, two way service, which is the same as Basic COPT service; and (2) outgoing only service that blocks all calls except 0+ collect only calls (otherwise, this service is the same as Basic COPT service). 10. Enhanced COPT Access Line service is a measured line service offered by Nevada Bell, which is designed to operate with smart payphones requiring special central office features and equipment. Two versions of this service are available: bothway or outward only. This service provides the following additional central office-based features: standard analog loop, line side answer supervision, and operator services identification. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 11. The Commission's CEI requirements were originally established in the Computer III proceeding, in which the Commission adopted a regulatory framework to govern the provision of integrated enhanced and basic services by the BOCs. As applied in the payphone context, the CEI requirements are designed to give independent PSPs equal and efficient access to the regulated basic payphone services that the BOCs use to provide their own payphone services. BOCs must also provide payphone services to independent PSPs on a nondiscriminatory basis as required in the payphone rulemaking proceeding. The Commission, in its Computer III proceeding, established nine specific CEI requirements, which are discussed below. PacTel has described in its submissions how its basic telephone service will satisfy each of the Commission's nine CEI requirements. We review below PacTel's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 12. The Payphone Order deregulated LEC payphones and classified those payphones as CPE. In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either instrument-implemented "smart" payphones or "dumb" payphones that utilize central office coin services, a LEC must tariff unbundled payphone features that the LEC uses or provides on an unbundled basis. Moreover, BOCS, but not other LECs, must unbundle additional network elements when required by a state or requested by payphone providers based on the specific criteria established in the Computer III and ONA proceedings. 13. The Payphone Order requires BOCs to file CEI plans that explain how they will unbundle basic payphone services. Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic service functions that underlie its provision of payphone service. Nonproprietary information used by the BOC in providing the unbundled basic services must be made available as part of CEI. In addition, any options available to the BOC in the provision of such basic services or functions must be included in the unbundled offerings. 14. PacTel represents that the basic network services used by its payphone service operations ("PubCom") will be offered unbundled from its other basic service offerings, and that independent PSPs and PubCom will have available to them the same tariffed network services for use in providing payphone services. According to PacTel, prior to the effective date of the 1996 Act, it had already made available to independent PSPs services that allowed them to offer payphone services using either smart or dumb payphone sets, and that it is continuing to make such services available. PacTel asserts that these basic network capabilities are associated with specific rate elements in its existing tariffs, and that it will make available to independent PSPs additional unbundled services through the 120-day ONA service request process. 15. APCC and SDPA contend that PacTel's CEI plan must be rejected because it fails sufficiently to unbundle PacTel's payphone services. APCC states that, while PacTel bundles some features with both its COPT Service (Basic) and coin line services (e.g., screening service), some features are only included with coin line service (e.g., answer supervision). APCC argues that PacTel should be required to price features the same, regardless of whether the features are offered on an unbundled basis or bundled with the line, and regardless of whether such features are used with COPT Service (Basic) or coin lines. APCC claims that, without such unbundling and separate tariffing, "it is not possible to determine whether all discrimination between [COPT Service (Basic)] line services and coin line services has been eliminated, and whether PacTel's 'basic payphone line' is uniformly tariffed at cost-based rates." While SDPA acknowledges that the Commission declined to order significant unbundling, it argues that relying only on the ONA procedure unreasonably shifts the burden of pursuing effective unbundling to independent PSPs. 16. PacTel responds that our CEI requirements do not require it to unbundle particular features from existing service offerings. Rather, PacTel argues, the unbundling requirement requires that "the basic, regulated network services that our PSPs use must be unbundled from other basic services so that other PSPs can purchase and use them in the same manner as our PSPs." PacTel claims that its CEI plan demonstrates compliance with this requirement. 17. We find that PacTel's plan satisfies the CEI unbundling requirement contained in the payphone proceeding. The payphone rulemaking proceeding requires BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone services using either "smart" or "dumb" payphones, or to offer inmate calling services. In addition, consistent with the requirements of the payphone proceeding, BOCs must provide, on a tariffed basis, the unbundled features and functions that they provide to unaffiliated PSPs or to their own payphone operations. PacTel's plan, as supplemented, satisfies these requirements. We note that PacTel may unbundle additional features and functions, states may require further unbundling, and independent PSPs may request additional unbundled features and functions through the ONA 120-day service request process. Any other unbundled features and functions provided by PacTel must comply with the tariffing and CEI requirements of the payphone proceeding, Computer III and ONA. 18. We reject APCC's and SDPA's contention that PacTel must further unbundle its payphone services at this time. As noted in the Clarification Order, the Commission's payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled basis." In the Clarification Order, we stated that if, for example, a BOC provides answer supervision bundled with the basic payphone line, the BOC is not required either to unbundle that service from its state tariff for payphone service, or to tariff that service at the federal level. If the LEC, however, provides answer supervision separately, on an unbundled basis, either to affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal jurisdictions. Thus, PacTel is not obligated at this time to unbundle from its basic payphone service offerings any features that PacTel does not offer on an unbundled basis to itself or to others. Independent PSPs may request PacTel to unbundle its coin line service further through the 120 day ONA process. 2. Interface Functionality 19. The interface functionality requirement obligates the BOC to make available standardized hardware and software interfaces that are able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. 20. PacTel represents that it "will interconnect its payphone services to its network only by means of the tariffed network services with standardized technical interconnections that are available to all PSPs." It adds that no special interfaces, signaling, abbreviated dialing, derived channels or other capabilities will be made available only to its pay telephone operations. 21. Telco asserts that PacTel does not adequately describe how it intends to provide interface functionality, but, instead, merely states that PSPs may connect their payphone CPE to Pacific Bell's standardized technical interfaces. Telco claims that Pacific Bell "provides no further explanation or meaningful detail regarding the technical requirements a PSP must meet to connect to the network interfaces, and provides absolutely no description of the interfaces." In addition, SDPA asserts that, even if PacTel does not make special network interfaces available to PubCom in the future, "it does not address unique network serving arrangements for the LEC's payphone division which may already be in place." 22. PacTel responds that, as part of its CEI offering, it is only required to make available standardized interfaces that are able to support functions identical to those utilized in the service provided by the LEC. PacTel claims that it makes such interfaces available through the standard technical interconnections in the tariffs attached to its CEI plan and in the services offered in its new state tariffs attached to its reply. PacTel adds that it provided information and technical disclosures for interfaces in its network disclosures on January 15, 1995. In response to SDPA, PacTel represents that its PSPs do not, and will not, have any high-capacity or specialized serving arrangements that are not available to all PSPs. 23. We find that PacTel's CEI plan comports with the interface functionality requirement. As stated above, the interface functionality requirement only obligates a BOC to make available standardized hardware and software interfaces that will be able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. PacTel represents, and Telco does not deny, that it has done so. Beyond the filing of network disclosures, which PacTel states it has filed, this parameter does not require PacTel to provide technical details in the CEI plan explaining how PSPs will connect to PacTel's network. 3. Resale 24. The resale requirement established in Computer III obligates a "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anticompetitive pricing in unregulated markets." Based on the requirement in the Payphone Order and the Reconsideration Order, any basic services provided by a BOC to its payphone affiliate, as well as any payphone service provided to others, must be available on a nondiscriminatory basis to other payphone providers. 25. In its CEI plan, PacTel represents that its "payphone service operations will take all basic services at unbundled tariffed rates." We therefore find that PacTel's CEI plan comports with the resale requirement. We are not persuaded by Telco's argument that PacTel's plan is insufficient, because it "fails to provide any specificity as to what combinations will be offered for resale, whether resale will be offered on a nondiscriminatory basis, or what mechanisms will exist to enable competitors to ensure that resale obligations are being met." We find that PacTel's representation that all basic services provided to its payphone operations will be available, pursuant to tariffed arrangements, to all PSPs, is sufficient to meet this CEI requirement. It is not required to provide in its CEI plan the level of detail sought by Telco in order to comply with the resale CEI requirement. To the extent that Telco's objections are based on concerns that PacTel's tariffed payphone offerings unlawfully discriminate against unaffiliated PSPs, such specific, fact-based claims should be addressed in federal or state tariff proceedings or in a formal complaint action against PacTel. 4. Technical Characteristics 26. This requirement obligates a carrier to provide basic services with technical characteristics that are equal to the technical characteristics the carrier uses for its own payphone services. 27. PacTel represents that it will use the same tariffed basic services to provide payphone services as are available to its payphone competitors, and that the technical characteristics of the basic services provided to independent PSPs will be equal to those of the basic services used for PacTel's own payphone service operations. Telco does not challenge this representation, but asserts that PacTel should provide further detail to enable the Commission to determine that there will be no discrimination between affiliated and unaffiliated PSPs. We find that PacTel is not required by our CEI rules to furnish the additional information requested by Telco in order to satisfy the technical characteristics requirement. We therefore conclude that PacTel's CEI plan comports with the technical characteristics CEI requirement. To the extent that Telco obtains credible evidence that PacTel has unlawfully discriminated against unaffiliated PSPs in the assignment of access lines, Telco may initiate a formal complaint action against PacTel. 5. Installation, Maintenance, and Repair 28. The Payphone Order requires BOCs to describe in their CEI plans how they will comply with the nondiscrimination requirements in Computer III and ONA regarding the quality of service, installation, and maintenance. This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in a CEI offering to unaffiliated PSPs are the same as those the carrier provides to its own or its affiliated payphone service operations. BOCs also must satisfy reporting and other requirements showing that they have met this requirement. 29. In its CEI plan, PacTel states that "its procedures ensure that the time periods for installation, maintenance, and repair of the basic services and facilities provided to independent PSPs are the same as [it] furnish[es] to [its] own payphone operation." For example, PacTel represents that its employees are trained to process work according to due dates (for service installation) and customer commitment times (for trouble reports), and that many of its systems monitor due dates or commitment times to ensure that work is completed as agreed with the customer. PacTel also avers that its payphone operations will place orders for network services, and make trouble reports on network services and receive information on the status of network repairs, in the same way as do other PSPs. In addition, PacTel states that all service orders are entered into its Service Order Retrieval and Distribution System with standard service intervals or customer-negotiated due dates. Finally, PacTel declares that, "[s]ubject to limited exceptions, trouble reports are worked on in the order received," and that the "primary consideration is the nature of the trouble." 30. APCC and SDPA assert that PacTel's CEI plan must provide further detail regarding how it will provide installation, maintenance, and repair on a nondiscriminatory basis to unaffiliated PSPs. For instance, APCC contends that, while PacTel states that independent PSPs will have comparable access to service order processing, installation, maintenance, and repair service, it does not indicate specifically what type of access is permitted to its payphone division personnel. APCC also asserts that PacTel's plan must discuss Pactel's service ordering procedures when a location provider changes from a PacTel payphone to an independent PSP payphone, or vice versa, to assess whether service orders are treated equally in this context. APCC argues that PacTel must specify the procedures it will use to ensure that PacTel will not engage in unfair marketing practices when its payphones are replaced by independent PSP payphones. In addition, APCC insists that PacTel should amend or refile its CEI plan to state how maintenance and repairs will be handled for the installed base, where no network interface has yet been installed, and to identify for its payphone offerings the demarcation point between the switched network and a payphone provider's inside wire. 31. APCC further asserts that, to the extent PacTel shares personnel, it must describe in detail what specific steps it will take to ensure that there will be no discrimination against independent PSPs. Finally, CPA claims that PacTel has previously accorded the following accommodations, which facilitate efficient installation of payphone stations and enclosures, to its payphone operations: (1) special telephone numbers for ordering services and testing lines; (2) provision of duplicate keys to access lock boxes on customer premises; and (3) access to node boxes for efficient testing of lines. CPA argues that if these accommodations continue to be accorded to PubCom, they must be accorded to all PSPs without discrimination. 32. In its reply, PacTel reiterates that its payphone operations will place orders for network services in the same manner as other PSPs. In addition, PacTel clarifies that its procedures for ordering network services will remain the same when a location provider changes a PacTel payphone division payphone to an independent PSP payphone, and vice versa, and that its network personnel will not service payphones. In response to APCC's concerns about repairs and maintenance for its installed base, PacTel states that, as set forth in its tariffs, the demarcation point is at the minimum point of entry. In response to CPA, PacTel clarifies that: (1) PubCom will not have access to any special telephone numbers for ordering services and testing lines that are not available to all PSPs; (2) it will not provide PubCom keys to access lock boxes on customer premises; and (3) PubCom will not have access to node boxes for efficient testing of lines, unless such access is made available to other PSPs. Finally, PacTel avers that, like any other PSP, its PSPs will not receive notification when a new service order is placed for an independent PSP payphone. 33. On April 10, 1997, CPA filed an ex parte communication with the Commission, which alleged that Pacific Bell had recently initiated changes to its service order procedures that are inconsistent with assurances made by Pacific Bell in its CEI plan and in responses to comments on that plan. Specifically, CPA alleges that Pacific Bell has: (1) eliminated the assignment of account representatives to particular independent PSPs and required that all calls to the COPT Service Center be directed to a single telephone number; (2) required that payphone service regrade orders (i.e., an order by an independent PSP requesting that it replace Pacific Bell's PSP operation in providing service at a particular location) be directed to PubCom in the first instance, rather than to the COPT Service Center; (3) altered its procedures for confirming due dates for service orders; and (4) refused to process "supersedure" orders (which request the conversion of responsibility for a COPT line from one independent PSP to another) until any past due balance on the superseded account has been paid, and rejected such orders rather than holding them until payment has been made. CPA further alleges that COPT Service Center representatives have informed independent PSPs that routine customer service tasks are on hold, because all of the center's resources are being devoted to system record changes to account for all PubCom's coin lines as tariffed COPT Coin lines. 34. PacTel responds that COPT service orders for all PSPs must be submitted to and will be processed by Pacific Bell's COPT service center, regardless of whether an order replaces an existing Pacific Bell PSP service. PacTel also represents that, under its new procedures, all regrades will be handled in the same manner. PacTel states that, when any PSP seeks to replace the service of another PSP at a particular location, the incoming PSP has two choices: (1) request Pacific Bell to install an additional line at the location and incur installation costs, or (2) negotiate an agreement with the existing PSP to supersede the existing service to the incoming PSP, and incur much lower charges by avoiding installation charges. PacTel represents that, historically, when an independent PSP sought to replace Pacific Bell PSP service, the COPT service center would forward information to a contract administrator, who would identify and attempt to resolve any contractual issues. PacTel represents that, by contrast, when an independent PSP sought to replace another independent PSP, the PSPs negotiated supersedure among themselves, and that the COPT service center obtained the outgoing PSP's authority to supersede the account before processing the supersedure order. PacTel represents that, now, all PSPs must negotiate a supersedure with the outgoing PSP, including Pacific Bell's PSP, before placing a supersedure order with the COPT service center, and that the service center has been informing independent PSPs that they must call Pacific Bell's PSP to regrade Pacific Bell PSP service. PacTel adds that independent PSPs that do not want to negotiate a supersedure with Pacific Bell's PSP may, as always, submit a new installation order for the site at issue. 35. In addition, PacTel acknowledges that it no longer assigns COPT service center representatives to particular accounts, but represents that a PSP that requests a particular representative will be transferred to that representative or, if the representative is not available, may elect to have the call returned by that representative or to work with another, available representative. PacTel also represents that the COPT service center has not changed any of its procedures for confirming due dates to PSPs. PacTel further represents that the requirement that an outgoing PSP account be paid in full before a supersedure order is processed is a long standing Pacific Bell policy. Finally, PacTel represents that the COPT service center has not put routine customer tasks on hold pending completion of any special project, and that the Center is not aware of any other deterioration in its ability to process service requests. 36. We find that PacTel's CEI plan comports with the installation, maintenance, and repair requirement. We conclude that PacTel's CEI plan, together with the representations that PacTel has made in this proceeding, provide sufficient detail on the procedures it will employ to ensure that the installation, maintenance and repair functions will be performed on a nondiscriminatory basis. For example, PacTel represents that it will provide installation, maintenance and repair on a nondiscriminatory basis. In addition, PacTel represents that its payphone operations will place orders for network services, and make trouble reports on network services and receive information on the status of network repairs, in the same way as other PSPs, and that the time intervals for providing installation, maintenance and repair will be the same for all PSPs. We find that the record evidence with respect to PacTel's installation, maintenance and repair procedures for PSPs satisfies our CEI requirements. 37. We reject CPA's claim that certain changes to Pacific Bell's service order procedures are inconsistent with representations made by Pacific Bell in its CEI plan. We are satisfied that PacTel has adequately demonstrated that, as a result of these changes, all regrades and supersedure orders will be treated on a nondiscriminatory basis. In addition, we find that Pacific Bell's new procedures do not raise CPNI issues or the possibility of improper notice of new service orders. PacTel represents that Pacific Bell's COPT service center will not disclose any such CPNI regarding independent PSPs to its own payphone operation. The fact that an independent PSP that wants to supersede Pacific Bell's PSP at a particular location will have to negotiate with Pacific Bell's PSP does not alter our conclusion, because Pacific Bell avers that its COPT service center will not disclose any CPNI or information about new service orders to Pacific Bell's payphone operation. Moreover, as PacTel notes, independent PSPs that do not want to negotiate with Pacific Bell's PSP may always submit a new installation order for the site at issue. Additionally, CPA offers no authority, and we find no basis in the Commission's Payphone Orders or CEI rules, for requiring Pacific Bell to assign COPT service center representatives to particular accounts. Finally, we find that PacTel's representations -- namely that Pacific Bell's COPT service center has not changed any of its procedures for confirming due dates to PSPs, that Pacific Bell has long required outgoing PSPs' accounts to be paid in full before processing supersedure orders, and that the COPT service center has not put routine customer service tasks on hold -- adequately respond to the other concerns raised by CPA. 6. End User Access 38. 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 BOCs facilities. This parameter also requires the BOC to provide all end users equal opportunities to obtain access to basic network facilities. 39. According to PacTel, its payphone service operations will use the same tariffed services available to all independent PSPs. As a result, PacTel's payphone service operations will only present end users with the same network-based operational characteristics that are available to independent PSPs for presentation to their end users. PacTel represents that no unique abbreviated dialing or signaling arrangements, and no special service channel access arrangements, are or will be associated with its payphone service operations. We find that PacTel's CEI plan comports with the end user access requirement established by the Commission. 7. CEI Availability 40. 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 testing their payphone service offerings. 41. The payphone rulemaking proceeding established the following tariffing requirements for LECs. LECs must file tariffs in the states for basic payphone services that enable independent PSPs to offer payphone services using either smart or dumb payphones and for any unbundled features that the LECs provide to their payphone operations or to others. LECs are not required to file tariffs for the basic payphone line for smart and dumb payphones with the Commission. As stated in the Clarification Order, a LEC is required to file federal tariffs for payphone-specific, network-based features and functions "only if the LEC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to others . . .." 42. The Clarification Order also granted all LECs a limited waiver of the federal tariffing requirements for unbundled features and functions that a LEC must meet before it is eligible to receive payphone compensation. Pursuant to this waiver, LECs must file interstate tariffs for unbundled features and functions within 45 days of the release date of the Clarification Order, with a scheduled effective date of no later than 15 days after the date the tariff is filed. In addition, each BOC was required to file, by April 10, 1997, a written ex parte document that advises the Commission on the status of intrastate tariffs for the features and functions that it has not yet federally tariffed, and stating that it commits to filing federal tariffs for such features and functions within 45 days of the release date of the Order. 43. PacTel represents that its underlying basic services are, and will be, available to its own payphone service operations and to independent PSPs at the same time in any given geographical service area. PacTel also represents that all of Pacific Bell's CEI services, except inmate services for use with "dumb" payphones, have been available for testing and use by independent PSPs for many years prior to the filing of PacTel's new tariffs, and therefore no additional testing period is required. PacTel adds that Nevada Bell's COPT Service (Basic) has, similarly, been available to independent PSPs for many years, and that no additional testing period is required for that service as well. PacTel acknowledges that Pacific Bell's and Nevada Bell's Inmate Services for use with "dumb" payphones, Nevada Bell's Coin Line service, Nevada Bell's Charge-A-Call service, and Nevada Bell's Enhanced COPT access line service, have not been available to independent PSPs, but represents that these services have been in use by Pacific Bell or Nevada Bell for years. PacTel contends that, if the Commission finds that a testing period would be required for these services absent a waiver, the Commission should grant Pacific Bell and Nevada Bell waivers of the testing period requirement, based on the same rationale that the Commission used to grant waivers of the network disclosure requirements. PacTel represents that, if it adds other CEI services in future, it will provide independent PSPs a reasonable testing period prior to using such new basic service offerings in the provision of its payphone services. 44. PacTel filed with its CEI plan its current state tariffs for payphone services. With its reply, PacTel submitted new state tariffs for payphone services for both Pacific Bell and Nevada Bell. According to PacTel, these new state tariffs were effective on April 1, 1997, for Pacific Bell, and are expected to be effective by April 15, 1997, for Nevada Bell. 45. APCC contends that the CEI plan must be rejected on the ground that PacTel did not file federal tariffs. It contends that, pursuant to the Reconsideration Order, PacTel must file tariffs for unbundled features at both the state and federal levels, and that the only service for which a federal tariff is not required is the basic access line. APCC concludes that PacTel's plan cannot be approved until it has filed all required federal tariffs, including tariffs for coin line features. 46. In an ex parte filing, PacTel represents that, in accordance with the requirements of the Clarification Order, Pacific Bell will file federal tariffs for the following unbundled features and functions: international direct distance calling, 10XXX selective blocking for bothway Basic COPT service, and answer supervision. PacTel further represents that Nevada Bell will file federal tariffs for international direct distance calling. 47. APCC also argues that PacTel must be required to disclose where coin line service is not available and whether PacTel has any payphones currently installed in those areas. PacTel responds that there are no areas in Pacific Bell's or Nevada Bell's service territories where the BOC currently offers, or where, in future, the BOC will offer, payphone services to its affiliated payphone operations that are not available to unaffiliated PSPs. 48. We find that PacTel's plan complies with the CEI availability requirement. We reject APCC's argument that PacTel must file a federal tariff for all payphone service features and functions, except for the basic access lines for payphone services. As stated in the Clarification Order, BOCs need only submit federal tariffs for payphone-specific, network-based features and functions if the BOC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to others. As noted, PacTel has committed to file federal tariffs for international direct distance calling, 10XXX selective blocking for bothway Basic COPT service, and answer supervision in Pacific Bell's territory, and for international direct distance calling in Nevada Bell's territory. 49. We also conclude that PacTel is not required to identify in its CEI plan specific geographic areas where coin line service is not available or to state whether PacTel has any payphones in such areas. PacTel has provided sufficient information about the availability of such services. In addition, PacTel represents that there are no areas in its service territories where it currently offers, or will, in future, offer, payphone services to its affiliated payphone operations without making such services available to independent PSPs. We find that PacTel is not required to identify how many of its payphones are "smart" payphones and how many are coin line. We find no basis in our CEI requirements or the payphone orders for directing PacTel to identify how many of its payphones are "smart" payphones and how many are coin line for purposes of satisfying our CEI requirements. 50. Finally, we grant PacTel's request that we waive the 90-day notice requirement for Nevada Bell's provision of COPT Service (Basic) service, Coin Line service, Charge-A-Call service, and Enhanced COPT access line service, and for Nevada Bell's and Pacific Bell's provision of Inmate Services for use with "dumb" payphones. Therefore, Nevada Bell and Pacific Bell may continue to provide such services through the use of the CEI offering described herein without first providing ninety days for unaffiliated carriers to test the service. This waiver is reasonable in this context because, unlike the provision of a new enhanced service, Nevada Bell and Pacific Bell have been offering payphone services using the foregoing services for many years. To bar Nevada Bell and Pacific Bell from continuing to use such services to provide payphone services for a period of ninety days would result in a suspension of service. Nevada Bell and Pacific Bell are not, however, relieved of their obligation to permit unaffiliated PSPs upon request to conduct testing of the foregoing offerings. For purposes of approving this CEI plan, we simply waive the requirement that Nevada Bell and Pacific Bell may not offer the foregoing services before such testing is accomplished. PacTel states that if and when other basic services are deployed, it will provide independent PSPs a reasonable testing period prior to using such new basic service offerings in the provision of its payphone services. 8. Minimization of Transport Costs 51. This requirement obligates carriers to provide competitors with interconnection facilities that minimize transport costs. PacTel represents that its tariffed basic payphone services are not distance-sensitive, and thus all PSPs, including its own, pay the same price for such services regardless of distance from PacTel's central offices. We find that PacTel's CEI plan comports with the minimization of transport costs requirement established by the Commission. 9. Recipients of CEI 52. This requirement prohibits a BOC from restricting the availability of its CEI offering to any particular class of customer or PSP. 53. PacTel avers that none of the tariffs for its payphone services restrict the ability of independent PSPs or any class of customers to purchase its payphone services. We find that PacTel has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 54. In addition to the CEI requirements established in Computer III, and applied to BOC provision of payphone services in the Payphone Order, a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination reporting. 1. Customer Proprietary Network Information 55. The Payphone Order requires PacTel to explain how it will comply with the Computer III CPNI safeguards, to the extent they are not inconsistent with section 222 of the Communications Act, as amended. Although the requirements of section 222 became effective immediately upon enactment, the Commission has initiated a proceeding to consider regulations interpreting and specifying in more detail a telecommunications carrier's obligations under this provision. The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they do not conflict with section 222. 56. In its payphone CEI plan, PacTel represents that it will comply with section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. PacTel also represents that it will not disclose or use the CPNI of independent PSPs without their approval, except in the provision of services to such PSPs. 57. APCC claims that PacTel's payphone CEI plan does not offer sufficient information concerning how PacTel will comply with CPNI requirements, but rather merely states that PacTel will follow Computer III procedures, except where inconsistent with section 222. APCC contends that PacTel should explain how it will protect, under nondiscriminatory conditions, the CPNI of PSPs, as well as the CPNI of PacTel's existing customers, including current customers of semi-public payphone service. In addition, CPA argues that PubCom personnel should be denied access to service order, billing or other statistical information about PacTel's business or residence customers, and allowed access to directory information about such customers only on the same basis as other PSPs. CPA contends that, if PubCom is allowed access to PacTel's LEC service ordering systems, those systems must be partitioned to protect LEC customers' CPNI and independent PSPs must be allowed equivalent access. 58. APCC and CPA also argue that, since Pactel's existing tariffed semi-public service is being terminated pursuant to section 276, PacTel's payphone operations have no more right to access and use the CPNI of semi-public service customers than any other PSP. APCC contends that the deregulation of semi-public service presents PSPs with a potential marketing opportunity to replace PacTel as the payphone service provider for these customers. APCC argues that semi-public customers should be provided notice and a meaningful opportunity to replace PacTel with another payphone service provider. It contends that PacTel 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 PacTel's payphone operations. 59. PacTel responds that its payphone personnel will not have direct access to its service order systems and will not have access to the CPNI of other PSPs. In addition, Pactel states that it will comply with the Commission's rules to implement section 222, and that it anticipates that neither PubCom nor other PSPs will have access to the CPNI of location providers, except with their approval. PacTel further claims that traffic information concerning the use of its deregulated semi-public payphones, as with public payphone service, belongs to PubCom, which is the purchaser of the line, not the site owner or the end users of the payphone. PacTel adds that, even if the location owners were the subscribers to the telephone lines for semi-public service, it could not provide access to the CPNI to other PSPs without the location owners' written consent, because that would violate section 222(c)(1). PacTel also contends that APCC's and CPA's proposal that PacTel be required to inform site owners about competitive options for semi-public payphone service would violate its First Amendment right to free speech, and that PacTel should not be required to perform marketing for its creditors. 60. In providing payphone services, PacTel must comply with the Commission's pre-existing Computer III CPNI requirements, to the extent that they are consistent with section 222 of the 1996 Act, and any regulations adopted by the Commission pursuant to section 222. PacTel represents that it will comply with section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. Accordingly, we find that PacTel's plan comports with CPNI requirements. In reaching this conclusion, we do not address issues raised by APCC and CPA relating to traffic information on the use of semi-public payphones. Issues relating to the interpretation of section 222, and how it relates to the Computer III CPNI rules, are being addressed in the CPNI rulemaking, and therefore will not be considered here. We do, however, reject APCC's and CPA's request that we require PacTel to inform site owners about competitive options for semi-public payphone service, because no such requirement was adopted in the Payphone Order or in the Reconsideration Order, or is otherwise required by our CEI rules. 2. Network Information Disclosure 61. The Payphone Order requires PacTel to disclose to the payphone services industry information about network changes and new network services that affect the interconnection of payphone services with the network. PacTel must make that disclosure at the "make/buy" point, that is, when PacTel decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface through which a PSP interconnects with PacTel's public switched network. PacTel must provide that information to members of the payphone services industry that sign a nondisclosure agreement within 30 days after the execution of the nondisclosure agreement. PacTel also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that service. 62. In the Payphone Order, the Commission waived the notice period for the disclosure of network information relating to "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory requirements of that order. Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15, 1997. 63. In its plan, PacTel states that no disclosure of network information is required for its currently tariffed payphone services. PacTel represents that interconnection between its PSPs and the underlying basic services is accomplished in all cases through existing published standard network interfaces, and that changes to existing network specifications or publication of new interfaces are not required at this time. PacTel also represents that it will continue to comply with all Commission network disclosure requirements as it develops new services or makes network changes that may affect the interconnection or interoperability of payphone services with the network. Consistent with the requirements of the Payphone Order, PacTel made network disclosures in connection with its payphone services by January 15, 1997. We therefore find that PacTel's CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 64. In the Payphone Order, the Commission directed the BOCs to comply with the Computer III and ONA requirements regarding nondiscrimination in the quality of service, installation, and maintenance. Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semi-annual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of covered service offerings, installation and maintenance. 65. PacTel represents that, on a quarterly basis, it will track and report on the installation and maintenance intervals for basic payphone services provided to its payphone operations and the same intervals for all of its other customers, so that comparisons can be made. PacTel further declares that its reports will contain the same types of information and be in the same format as the information and format the Commission approved in Computer III. We find that PacTel's CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 66. In the Payphone Order and the Accounting Safeguards Order, the Commission concluded that it should apply accounting safeguards identical to those adopted in Computer III to BOCs providing payphone service on an integrated basis. Pursuant to Computer III, the BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These safeguards consist of five principal elements: 1) the establishment of effective accounting procedures, in accordance with the Commission's Part 32 Uniform System of Accounts requirements and affiliate transactions rules, as well as the Commission's Part 64 cost allocation standards; 2) the filing of cost allocation manuals (CAMs) reflecting the accounting procedures and cost allocation standards adopted by the BOC; 3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with their cost allocation manuals; 4) the establishment of detailed reporting requirements and the development of an automated system to store and analyze the data; and 5) the performance of on-site audits by Commission staff. PacTel must comply with these accounting safeguards. We note that the approval granted to PacTel in this order is contingent upon the CAM amendments associated with PacTel's provision of payphone service going into effect. D. Other Issues 1. Sufficiency 67. APCC, SDPA, and Telco generally assert that PacTel's CEI plan insufficiently describes how PacTel intends to comply with the CEI requirements, and request the Commission to require PacTel either to amend or to refile its plan. As discussed above, we find that PacTel adequately complies with each of the CEI requirements. 2. Tariffing Issues 68. APCC raises various objections to the content of PacTel's state tariffs. PacTel responds that the Commission should not allow APCC to turn this CEI proceeding into a tariff proceeding. PacTel argues that the Commission delegated to the states the responsibility for reviewing tariffs for basic payphone lines. 69. We agree with PacTel that this is not the appropriate proceeding to address whether PacTel's tariffed rates are cost-based and non-discriminatory. The Commission stated in the Reconsideration Order that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with the requirements of Section 276." That order required that the tariffs for these LEC services must be: (1) cost based; (2) consistent with the requirements of section 276 with regard, for example, to the removal of subsidies from exchange and exchange access services; and (3) nondiscriminatory. In addition, the order established that "[s]tates must apply these requirements and the Computer III guidelines for tariffing such intrastate services." The order further stated that "[w]here LECs have already filed intrastate tariffs for these services, states may, after considering the requirements of this order, the Report and Order, and section 276 conclude: 1) that existing tariffs are consistent with the requirements of the Report and Order as revised herein; and 2) that in such case no further filings are required." Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs operating in their state to file these tariffs with the Commission." Thus, state and federal payphone tariff proceedings are the appropriate fora to address complaints concerning tariffed rates, terms and conditions for payphone services. 70. On April 11, 1997, CPA filed an ex parte communication with the Commission, which expresses concern that Pacific Bell has filed a request with the California Public Utilities Commission ("CPUC") to defer cancellation of Pacific Bell's tariff for Public Access Line ("PAL") service from April 14, 1997, until April 30, 1997. Pacific Bell sought the extension to ensure "'a smooth and successful conversion of the detariffed product to a product that is offered under tariff with minimal disruption of the COPT customer as well as the end user.'" CPA argues that the "late admission by Pacific itself that it is having trouble confirms that the transition to detariffed payphone operations is not going smoothly at Pacific Bell," and urges the Commission not to approve PacTel's CEI plan until Pacific Bell has satisfactorily responded to CPA's concerns. We find that the Pacific Bell's request to the CPUC for a limited extension of the removal of Pacific Bell's tariff for PAL service until April 30, 1997, does not suggest that the "transition to detariffed payphone operations is not going smoothly at Pacific Bell," nor does it warrant disapproval of PacTel's CEI plan. To the extent CPA obtains credible evidence that Pacific Bell has failed to comply with the requirements of the Payphone Orders, or with the terms of its CEI plan, CPA may initiate a formal complaint action against Pacific Bell. 3. Screening Codes 71. APCC and MCI contend that PacTel is required, pursuant to the Reconsideration Order, to provide PSPs using COPT Service (Basic) lines with screening code digits that uniquely identify their lines as payphone lines. APCC asserts that if PacTel transmits a unique screening code only on its coin lines, which are primarily used by PacTel's own payphone division, and not on its COPT Service (Basic) lines, which are primarily used by unaffiliated PSPs, PacTel is discriminating in favor its payphone division by providing it a great advantage in the collection of per-call compensation from interexchange carriers. In addition, MCI maintains that PacTel's plan does not provide screening code digits that can be transmitted by PSPs for all access methods and from all locations. 72. PacTel responds that the Commission has acknowledged that a LIDB-based solution is a suitable means of identifying an originating line as a payphone line. PacTel represents that it is taking that approach. In addition, PacTel argues that it is not required to provide the same screening capability to COPT Service (Basic) and coin lines, on the ground that the relevant CEI requirements are satisfied so long as the basic network capabilities it provides to its PSPs are available under tariff to other PSPs. 73. We find that the issue of whether PacTel is providing screening information in compliance with the requirements established in the payphone rulemaking is outside the scope of the CEI review process and is more appropriately addressed in that proceeding or in other proceedings. 4. Numbering Assignments 74. According to APCC, the Payphone Order requires LECs to assign line numbers to payphones on a nondiscriminatory basis. It contends that PacTel's CEI plan is deficient in that it does not address the assignment of numbers. For example, APCC maintains that PacTel should be required to reallocate the numbers assigned to the existing base of payphones, without charge, so that an equal percentage of LEC payphones and PSPs are assigned 8000 and 9000 series numbers. In reply, PacTel asserts that it will make number assignments on a nondiscriminatory basis. 75. We agree with APCC that the Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to reallocate existing number assignments. PacTel represents that it will assign payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by PacTel in the context of this CEI plan. 5. Dialing Parity 76. MCI asserts that PacTel does not explain how it will comply with the dialing parity requirement in the Payphone Order, including access to operator services, directory assistance, and directory listings. PacTel responds that this issue should not be dealt with here. It represents that the Commission "'conclude[d] that the technical and timing requirements established pursuant to Section 251(b)(3), and Section 271(c)(2)(B), should apply equally to payphones,'" and that it "will apply those requirements to payphones in connection with implementing those sections of the Act." 77. The Payphone Order concluded that the dialing parity requirements adopted pursuant to section 251(b)(3) of the 1996 Act should extend to all payphone location providers. The Commission stated that such dialing parity for payphones should be implemented at the same time as dialing parity for other telephones. PacTel must, of course, comply with these requirements. We conclude, however, that PacTel is not required, as part of the CEI process, to demonstrate how it will comply with these requirements. In the Payphone Order, the Commission specified that a BOC's CEI plan must describe how it will conform to the CEI requirements with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. Therefore, MCI's request that PacTel be required to elaborate upon how it intends to comply with the dialing parity requirement is outside the scope of this CEI review proceeding. 6. Uncollectibles 78. AT&T asserts that PacTel must explain its treatment of uncollectibles due to fraud. AT&T contends that, to the extent PacTel establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be accorded to non-affiliates. PacTel represents that it does not discriminate in its treatment of uncollectibles, and that it will respond to issues concerning the accounting treatment of uncollectibles in CAM proceedings. 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 PacTel's CAM. 7. Operator Services 79. APCC contends that PacTel's CEI plan fails to specify whether PacTel considers operator services to be part of its deregulated payphone service. APCC claims that, if PacTel's operator services are regulated, Pactel must demonstrate that it is not subsidizing its payphone operations or discriminating between its payphone operations and other PSPs in the provision of these services. For example, if PacTel is offering a commission to its payphone operations for presubscribing its payphones to PacTel's operator services, then such commissions must also be available to unaffiliated PSPs on the same terms and conditions. Operator services are regulated services. Because PacTel must offer such services to affiliated and unaffiliated PSPs on a nondiscriminatory, tariffed basis, PacTel's CEI plan is not deficient because it does not address whether PacTel considers operator services to be part of its deregulated payphone service. We note that, in the Reconsideration Order, the Commission declined to require LECs to make available, on a nondiscriminatory basis, any commission payments provided to their own payphone divisions in return for the presubscription of operator service traffic to the LEC, because the Commission concluded that the level of 0+ commissions paid pursuant to contract on operator service calls was beyond the scope of section 276 and the Payphone proceeding. 8. Inmate Calling Services Issues 80. The Inmate Calling Service Provider Coalition (ICSPC) raises a number of issues related to the provision of inmate calling services (ICS). ICSPC contends that PacTel should be required to identify the network support and tariffed services it will provide to its ICS operations. ICSPC also argues that PacTel must disclose whether its regulated operations will provide its ICS operations with inmate call processing and call control functions and information for fraud protection, and the validation of called numbers. ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. According to ICSPC, PacTel's failure to describe its provision of ICS in detail prevents the Commission from determining whether PacTel has complied with the requirements of section 276. In addition, ICSPC asserts that PacTel should be required to disclose whether its payphone operations will be responsible for the cost of ICS calls for which its payphone operations are unable to collect the charges. 81. ICSPC also asserts that PacTel must show that any call processing and call control system used for its ICS is being provided on a deregulated basis, regardless of whether that system is located at a central office or at a customer premises. According to ICSPC, to the extent PacTel's call processing and call control systems dedicated to ICS are located in PacTel's central offices, PacTel must provide physical or virtual collocation to other providers. ICSPC also contends that PacTel must disclose information on interfaces between PacTel's equipment dedicated to ICS and its regulated network support services, so that other providers can utilize the same interface if they wish. 82. In a subsequent ex parte filing, ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations, because collect calling is fundamental to ICS. According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its network-based operator services division for processing and that division assumes the responsibility and risk associated with billing and collecting for those calls, then the BOC is essentially providing ICS as a regulated service and is still subsidizing that service contrary to the prohibition in section 276. 83. In response to ICSPC's arguments, PacTel represents that it described in its CEI plan the tariffed network services that it will provide to its ICS, and which are available to all other providers of ICS service at the same rates, terms and conditions. PacTel also represents that all of the descriptions concerning how it will meet CEI requirements for payphone service apply equally to ICS, because ICS is included in the definition of payphone service in section 276, and its CEI plan applies to all services meeting that definition. In addition, PacTel represents that its call control and call processing functions are performed in unregulated equipment. With respect to uncollectibles, PacTel asserts that it affords the same treatment to the disputed charges of independent PSPs that purchase its third party billing services as it does for its own disputed charges. PacTel avers that other issues raised by ICSPC concerning PacTel's accounting treatment of uncollectibles relate directly to its cost allocation manuals, and that it will respond in CAM Revision proceedings. PacTel maintains that, as discussed above, it has met the technical requirements relating to interface functionality and technical characteristics. 84. Section 276 specifically defines payphone service to include the provision of inmate telephone service in correctional institutions. In the Reconsideration Order, we clarified that the requirements of the Payphone Order apply to inmate payphones that were deregulated in an earlier order. Thus, PacTel is required to reclassify as unregulated assets all of its payphone assets related to its provision of ICS, with the exception of the loops connecting the inmate telephones to the network, the central office "coin service" used to provide the ICS, and the operator service facilities used to support the ICS. In addition, PacTel is required to offer on a tariffed basis any basic payphone service or network feature used to provide ICS. 85. We conclude that PacTel's CEI plan comports with our CEI requirements with respect to its provision of ICS. PacTel represents that the underlying network services used to interconnect its ICS are available on a tariffed basis to all PSPs under the same terms, prices, and conditions. Although we agree with ICSPC that any call processing and call control equipment related to PacTel's provision of ICS must be reclassified as nonregulated, regardless of whether that equipment is located in a customer premises or a PacTel central office, PacTel represents that it has done so. We find no support in the Payphone Order or in the Reconsideration Order for ICSPC's contention that PacTel is required to provide collect calling as a nonregulated service when used with inmate payphones. 86. 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 no requirement in the Commission's rules, and ICSPC has cited no authority, that obligates PacTel to allow the collocation of nonaffiliated providers' call processing and call control equipment in a central office. As previously noted, the issue of the treatment of uncollectibles will be addressed in the review of PacTel's CAM. Finally, with regard to the disclosure of interface information, we concluded above that PacTel's CEI plan comports with the Commission's network information disclosure requirements. 9. Primary Interexchange Carrier Selection 87. Oncor asserts that in order for PacTel's CEI plan to comply with the "spirit" of the Commission's CEI requirements, the plan must address various issues concerning the payphone PIC selection process. AT&T also asserts that PacTel's CEI plan should describe how PacTel will ensure that the PIC selection process for payphones will be performed on a nondiscriminatory basis. PacTel responds that AT&T's and Oncor's comments concerning PIC selection are not relevant to this proceeding. 88. We conclude that PacTel is not required, as part of the CEI process, to demonstrate how it will administer the PIC selection process for payphones. In the Payphone Order, the Commission specified that a BOC's CEI plan must describe how it will conform to the CEI parameters with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. The payphone rulemaking proceeding did not, however, require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as argued by AT&T and Oncor. Therefore, arguments raised by parties regarding PacTel's role as PIC administrator are beyond the scope of this proceeding. 10. Subscriber-Selected Call Rating 89. APCC and CPA contend that, in order to meet the Commission's CEI requirements, PacTel must provide a coin line service that allows independent PSPs to set their own end user rates for local and intraLATA calls, as well as to establish the length of initial and overtime periods. They therefore request the Commission to require PacTel to develop a more flexible rating feature for its coin line service. PacTel responds that this same request was made by the parties in the Payphone Proceeding, and that the Commission declined to adopt it. In addition, PacTel argues that, "[b]y offering the same COPT coin line service, including the same call rating functionality, to other PSPs as we provide to our own, we have met the CEI plan requirement." 90. We find that the Payphone Order did not require the BOCs to provide to independent PSPs an unbundled call rating feature for coin line services. In addition, on reconsideration of the Payphone Order, in response to a request that the Commission require access to, inter alia, call rating capabilities, the Commission specifically declined to require further unbundling of payphone services beyond those established in the Payphone Order. As previously noted, independent PSPs may seek additional unbundling through the 120 day ONA process, and state regulatory commissions may impose further unbundling requirements. 11. Selection of Operator Services Provider 91. APCC requests that the Commission require PacTel to unbundle operator services from its coin line service so that PSPs may select the operator service provider (OSP) for intraLATA calls. APCC argues that, under section 276, PSPs are entitled to select the OSP for intraLATA calls, including local, operator-assisted calls, and therefore that, to the extent PacTel does not permit OSP selection for its coin line service, its CEI plan is inconsistent with section 276. We concur with PacTel that APCC's request is beyond the scope of this proceeding, which is limited to determining whether PacTel's CEI plan complies with the Commission's Computer III CEI requirements. 12. Billing and Collection and Coin Refund Services 92. CPA and SDPA request that, to the extent PubCom is allowed to use PacTel's billing and collection services, the Commission require PacTel to offer nondiscriminatory access to such services to independent PSPs. We reject CPA's and SDPA's request. In the Payphone Order, the Commission concluded that a LEC must provide billing and collection services provided to its own payphone operations to independent PSPs on a nondiscriminatory basis only if the LEC "provides basic, tariffed payphone services that will only function in conjunction with billing and collection services from the LEC." On reconsideration, the Commission reaffirmed this conclusion, stating that "[w]e decline to require access to unregulated services, such as installation and maintenance of unregulated CPE, and billing and collection (beyond the requirement established in the Report and Order)." Because the basic payphone services offered by PacTel do not require PacTel's billing and collection to function, PacTel may provide billing and collection services on behalf of its payphone operations, without providing such services to third parties in the same manner, so long as PacTel properly accounts for the unregulated use. 93. CPA also requests the Commission to require PacTel to offer independent PSPs an equivalent coin refund service, including providing credits on PacTel subscriber bills, to that provided on behalf of PubCom. We reject CPA's request. PacTel states that, beginning April 15, 1997, its operators will handle calls from end users seeking refunds from PubCom payphones in the same way that they handle calls for refunds from other PSPs' payphones: they will refer callers to signs posted on payphone equipment for the number to call for refunds. Nothing more is required by the Payphone Order. In addition, we agree with PacTel that billing services are not subject to CEI or payphone proceeding nondiscrimination requirements. Thus, PubCom's use of Pactel's billing services to provide coin refunds through credits on customer bills is consistent with the requirements of the Payphone Order. We note that PacTel must, of course, properly account for PubCom's use of such services. 13. Interim Compensation Scheme 94. Telco argues that apart from the numerous deficiencies in PacTel's CEI plan, the Commission should refrain from allowing PacTel or any BOC to participate in the interim compensation scheme outlined in the Payphone Order. We find that this argument is beyond the scope of this CEI review proceeding. Moreover, the interim compensation rules were addressed at length in the payphone rulemaking proceeding. 14. Semi-Public Payphone Service Issues 95. Finally, APCC maintains that, to the extent that PacTel's payphone operations continue to offer "semi-public-like" payphone service that involves charging location providers for lines and usage of their payphones, PacTel must disclose how such service will be supported by its network operations and how charges for the service will be treated on the subscriber's bill. We find these semi-public payphone service issues to be beyond the scope of the CEI review process. V. CONCLUSION 96. We conclude that PacTel's CEI plan complies with the Computer III requirements, contingent upon the effectiveness of its state tariffs for payphone services. Accordingly, in this Order, we approve PacTel's CEI plan to offer Basic Payphone Service, as described herein. VI. ORDERING CLAUSE 97. IT IS HEREBY ORDERED that, pursuant to Sections 1, 4(i) and (j), 201, 202, 203, 205, 218, 222, 276 of the Communications Act of 1934, as amended, 47 U.S.C.  151, 154(i) and (j), 201, 202, 203, 205, 218, 222, and 276 and authority delegated thereunder pursuant to Sections 0.91, 0.291, and 1.3 of the Commission's rules, 47 C.F.R.  0.91, 0.291, and 1.3, PacTel's Comparably Efficient Interconnection Plan for the Provision of Basic Payphone Service IS APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger, Jr. Deputy Chief, Common Carrier Bureau