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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 ) ) U S WEST's Comparably Efficient ) Interconnection Plan for ) Payphone Services ) ) 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 . . . . . . . . . . . . . . . . . . . . . . . 10 A. CEI Plan Requirements . . . . . . . . . . . . . . . . . 10 B. Other Nonstructural Safeguards. . . . . . . . . . . . . . 56 C. Accounting Safeguards . . . . . . . . . . . . . . . . . . 70 D. Other Issues. . . . . . . . . . . . . . . . . . . . . . . 71 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 VI. ORDERING CLAUSE . . . . . . . . . . . . . . . . . . . . . . . . 100 I. INTRODUCTION 1. On January 6, 1997, pursuant to the requirements of the Commission's orders in the payphone rulemaking proceeding, U S WEST, Inc. (U S WEST) filed a comparably efficient interconnection (CEI) plan for payphone service. In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan describing how it will comply with the Commission's Computer III CEI equal access parameters and nonstructural safeguards for the provision of payphone services. Bocs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations to provide payphone services. 2. The Commission issued a public notice of U S WEST's CEI plan on January 8, 1997. On February 7, 1997 seven parties filed comments opposing the plan. U S WEST submitted reply comments on February 24, 1997. For the reasons discussed below, we approve U S WEST's CEI plan. II. BACKGROUND 3. The payphone rulemaking proceeding implemented section 276 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (1996 Act). Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone service. The 1996 Act provided that such safeguards must, at a minimum, include the nonstructural safeguards adopted in the Computer III proceeding. 4. In the Payphone Order, the Commission determined that the Computer III and Open Network Architecture (ONA) nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or cross-subsidize in their provision of payphone service." Accordingly, the Commission required the BOCs to file "CEI plans describing how they will comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI requirements as modified by section 222 of the 1996 Act, network disclosure requirements, and installation, maintenance, and quality nondiscrimination requirements." Obtaining approval of its CEI plan is one of the criteria a BOC must meet before its payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established in the payphone proceeding. 5. The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrument-implemented 'smart payphones' or 'dumb' payphones that utilize central office coin services, or some combination of the two in a manner similar to the LECs." Those tariffs must be filed with the applicable state regulatory commission. Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone affiliate to provide payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis. III. SERVICE DESCRIPTION 6. U S WEST represents that it will "continue to operate its payphone business on an integrated basis through U S WEST Public Services (USWPS) which is part of U S WEST Communications, Inc." USWPS provides three types of payphone service: (1) Public Telephone Service; (2) Semi-Public Telephone Service and Shared Payphone Service; and (3) Inmate Calling Service. 7. Public Telephone Service is either outgoing only or two-way service and can be coin or coinless. USWPS offers four Public Telephone Service options: - Coin-Operated Payphone Service (Classic or "Dumb" Payphone). This service relies on an operating company's central office controls to collect and return coins at the payphone set. End users have access to local, toll and operator network services. The payment options available to end users are cash or billing as a collect call, a charge to a third party number, or a calling card. - Coin Operated Payphone Service ("Smart" Payphone). This service offering uses payphone sets that are capable of rating local calls, collecting and returning coins, rating and routing toll calls, and providing "station-based operator services." The payment options available to end users are cash or billing as collect, third party, or calling card. - Card and Coin Payphone Service (Advanced Payphone). This service offering is similar to the Coin Operated Payphone Service but provides the additional payment options of using commercial credit cards or cash cards. - Coinless Payphone Service. This service offering uses payphone sets that rely on central office and operator systems to rate and bill for calls placed from the sets. It has a unique screening feature that prohibits coin paid direct-dialed-call billing. End users have access to local and toll services. The payment options available to end users are limited to billing as collect, third party, or calling card. 8. The Semi-Public Telephone Service and Shared Payphone Service offered by U S WEST utilize a "dumb" payphone set that relies on central office control to collect and return coins. The end users have access to local, toll, and operator network services. The payment options available to end users are cash or billing as collect, third party, or calling card. The Semi-Public Telephone Service and Shared Payphone Service recover a portion of U S WEST's costs through separate monthly service charges billed to the location site provider. 9. The Inmate Calling Service provides a payphone set that relies on central office and operator or premises-based call management systems for the control of rating and billing. It has unique screening features that prohibit direct-dialed calls, calling card, and third-number billing. This service option provides end users access to local and toll services on a collect billing arrangement. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 10. 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 payphone service providers 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 payphone providers 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. U S WEST has described in its submissions how it will satisfy each of these nine requirements. We review below U S WEST's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 11. The Payphone Order deregulated LEC payphones and classified those payphones as customer premises equipment (CPE). In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either "smart" payphones or "dumb" payphones that utilize central office coin services, a LEC must also tariff unbundled payphone features that the LEC uses or provides on an unbundled basis. Moreover, BOCs, but not other LECs, must unbundle additional network elements when requested by payphone providers based on the specific criteria established in the Computer III and ONA proceedings. 12. 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. 13. The basic services underlying U S WEST's payphone services consist of a Basic Public Access Line (Basic PAL) used with "smart" payphones and a Smart Public Access Line (Smart PAL) used with "dumb" payphones. 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. 14. U S WEST describes Smart PAL service as a voice-grade switched line that provides a payphone service provider with a line side connection to the circuit switched network. In addition, central office functions determine when a coin should be collected or returned and rates all coin paid long distance calls. 15. The Basic PAL service is a voice-grade switched line that provides a payphone service provider with a line side connection to the circuit switched network. U S WEST also offers certain optional features on an unbundled basis in conjunction with its Basic PAL service. These features are: answer supervision-line side; billed number screening; CUSTOMNET service, which provides toll access screening options that allow a payphone service provider using Basic PAL service to restrict the classes of chargeable calls originating over some or all of the Basic PAL lines; blocking for "10XXX1+" domestic toll and "10XXX011+" international toll calls; and international call blocking. 16. U S WEST represents that all of the features and functions associated with these basic services are available to independent payphone providers on the same basis that they are offered to U S WEST's payphone operations. It further represents that any additional basic services or features that U S WEST's payphone operations may use in the future will be added to its CEI plan by way of amendment prior to use. In addition, U S WEST asserts that it will respond to independent payphone providers' additional requests for unbundled basic services through the existing 120-day ONA process and will make those services available where such requests comply with the factors established by the Commission for selection of ONA services. 17. APCC and APA argue that the CEI plan must be rejected because it does not sufficiently unbundle payphone features and functionalities from the payphone access line. APCC contends that U S WEST is required to offer the basic payphone lines for its Basic PAL and Smart PAL services, and to offer separately the features and functionalities that U S WEST proposes to offer as part of those basic payphone offerings. Specifically as to the Smart PAL service offering, APCC maintains that PSPs must be able to subscribe to U S WEST's coin line without being required to take and pay for all of the additional features, such as coin signaling, pay-per-call blocking, call screening and operator services, that U S WEST proposes to provide as part of its coin line service. Moreover, APCC argues that U S WEST should price these additional features at the same rate whether they are used with COCOT or coin lines. APCC and APA argue that such unbundling and separate tariffing are necessary to ensure that U S WEST's payphone offerings are nondiscriminatory and free from cross subsidization. APA further contends that it is technically feasible for U S WEST to unbundle coin supervision features from the coin line service access line as evidenced by the state tariff filings of independent LECs that unbundle the line from coin supervision functions. 18. U S WEST responds that its Basic PAL and Smart PAL offerings comply with the CEI unbundling parameter. It argues that this parameter only requires a BOC to unbundle features and functionalities that the BOC itself uses on an unbundled basis. 19. We find that U S WEST's plan satisfies the CEI unbundling requirement contained in the payphone rulemaking proceeding. The payphone rulemaking proceeding requires BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone services using either a "smart" or "dumb" payphones or to offer inmate calling services. 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 their payphone operations. U S WEST's plan satisfies those requirements. We note, however, that US WEST may choose to unbundle additional functions and features, states may require further unbundling, and payphone providers may request additional unbundled features and functions through the ONA 120-day service request process. Any other unbundled features and functions provided by U S WEST must comply with the tariffing and CEI requirements of the payphone rulemaking proceeding, Computer III and ONA. 20. We reject APCC's contention that U S WEST must unbundle the coin supervision and other features of its Smart PAL service offering. As noted in the Clarification Order, the Commisssion's payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled basis." In the Clarification Order, we stated that, for example, if a BOC provides answer supervision bundled with the basic payphone line, the BOC is not required either to unbundle that service from its state tariff for payphone service, or to tariff that service at the federal level. If the LEC, however, provides answer supervision separately, on an unbundled basis, either to affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal jurisdictions. Because U S WEST offers, and will use, the Smart PAL service as a "unitary whole," that is, on a bundled basis, it need not unbundle the individual features that comprise that service in its CEI plan. Moreover, U S WEST has unbundled, and federally tariffed, basic features that U S WEST offers to payphone providers, both affiliated and unaffiliated, that subscribe to its Basic PAL service. No further unbundling is required at this time. Independent payphone providers may seek further unbundling by making a request pursuant to the ONA process. 2. Interface Functionality 21. 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. 22. U S WEST claims that its payphone operations and the payphone operations of unaffiliated PSPs will obtain access to U S WEST's network through existing network interfaces that are publicized through U S WEST's standard network disclosure procedures which comply with the Commission's network disclosure rules. U S WEST also represents that USWPS will use no interface, signaling, abbreviated dialing, derived channels, or other unique capabilities to access U S WEST's basic services that are not also available to unaffiliated PSPs through a tariff or published price lists or catalogs. According to U S WEST, if such access arrangements are made available to USWPS, they will be made available to unaffiliated PSPs at the same time, in the same jurisdictions, and on the same terms and conditions. Finally, U S WEST states that it will comply with all applicable network disclosure requirements. 23. Telco asserts that U S WEST's statement that PSPs will access the network through existing interfaces available through U S WEST's standard network disclosure procedures is insufficient. Telco argues that U S WEST must provide "further explanation or meaningful detail regarding the technical requirements [a PSP] must meet to connect to network interfaces . . . ." Telco also faults U S WEST for providing no description of the interfaces. U S WEST responds that it provided information on the technical requirements an unaffiliated PSP must meet to connect to U S WEST's network interfaces. U S WEST represents that it provided this information for the Smart PAL service in its January 6, 1997 network disclosure. 24. We find that U S WEST 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 service. U S WEST avers that it has met this requirement. Beyond the filing of network disclosures, which U S WEST states that it has filed, and Telco does not dispute U S WEST's claims, this parameter does not require U S WEST to provide technical details in the CEI plan explaining how PSPs will connect to U S WEST's network. 3. Resale 25. 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. 26. U S WEST represents that its payphone operations will "impute the tariffed rates for all basic services used to provide its payphone services." We find that U S WEST has met the resale requirement. We are not persuaded by Telco's argument that U S WEST'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 ensure that resale obligations are being met." We find that U S WEST's representation 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 U S WEST's tariffed payphone offerings unlawfully discriminate against unaffiliated PSPs, contrary to U S WEST's express representation in this proceeding, such specific, fact-based claims should be addressed in federal or state tariff proceedings or formal complaint actions against U S WEST. 4. Technical Characteristics 27. 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. 28. According to U S WEST's CEI plan, USWPS's payphone services will interconnect with U S WEST's basic services through existing standard network interfaces. U S WEST represents that the facilities provided to USWPS and unaffiliated PSPs comply fully with the Commission's parameters for technical quality. U S WEST represents that it will only utilize tested, inventoried facilities (i.e., lines and associated equipment) and that the testing and acceptance of this equipment is performed without regard to the type of customer or intended use of the circuit. Finally, U S WEST represents that, pursuant to Commission requirements, it has filed annual affidavits since March 1990 attesting that there has been no discrimination in the provision of basic services used with its enhanced services and that future affidavits will address basic services used for payphone services. We find that U S WEST's CEI plan comports with the technical characteristics requirement established by the Commission. 5. Installation, Maintenance, and Repair 29. 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. 30. U S WEST's CEI plan states that the procedures for processing orders and installing and maintaining payphone lines ensure that there can be no discrimination between U S WEST's payphone operations and that of unaffiliated PSPs. U S WEST declares that USWPS will be subject to the same scheduling procedures and time periods as unaffiliated PSPs. U S WEST represents that intervals for installation and maintenance/repair are based on standard intervals or guidelines applied to all customers without regard to customer affiliation. U S WEST's plan notes that U S WEST's mechanized maintenance systems prevent service intervals from being changed once the repair has been posted. 31. The CEI plan also states that U S WEST's payphone personnel and the personnel of unaffiliated PSPs will have comparable access to U S WEST's Operation Support Systems (OSS) supporting installation, maintenance, and repair functions. U S WEST also represents that all personnel associated with the provisioning of network services understand and apply the Commission's nondiscrimination rules applicable to payphone services. U S WEST avers that these employees will review annually the rules on nondiscrimination and will be advised that violation of the rules may lead to disciplinary action. 32. APCC argues that U S WEST's CEI plan must provide further detail regarding how it will provide installation and repair on an non-discriminatory basis to unaffiliated PSPs. APCC also objects to the plan because it fails to specify how U S WEST's payphone personnel will have access to U S WEST's OSS. APA contends that U S WEST must allow unaffiliated PSPs the same, not just comparable, access to U S WEST's OSS. APA contends that it would be anticompetitive if USWPS personnel have electronic access to U S WEST's computer databases for placing orders or service requests while independent PSP personnel continue to place such orders through voice communications or written orders sent by facsimile transmission. Finally, APA asserts that U S WEST favors its own payphone operations when scheduling repairs by, for example, undertaking line repairs for U S WEST payphone services on the weekend, but refusing to do so for independent payphone service providers. 33. APCC also asserts that U S WEST should explain whether it intends to share personnel between its operating company and payphone operations and, if so, the measures it will implement to ensure that the use of shared personnel will not lead to discrimination in the provision of installation, maintenance and repair. APCC contends that U S WEST must describe the service ordering procedures it will follow when a location provider changes from a U S WEST payphone to an unaffiliated PSP payphone and vice versa. APCC asserts that these procedures must be specified to ensure that conflicts that arise in this context are resolved in a nondiscriminatory fashion. APCC also argues that U S WEST must specify the procedures that it will use to ensure that it will not engage in unfair marketing practices when payphones are replaced. In this regard, APCC contends that, for example, U S WEST's procedures must bar USWPS from being notified when a new service order is placed for an unaffiliated PSP payphone. Finally, APCC argues that U S WEST should identify for its payphone offerings the demarcation point between the switched network and a payphone provider's inside wire. 34. In an ex parte submitted on April 2, 1997, U S WEST clarified that access to U S WEST's OSS by USWPS personnel and the personnel of unaffiliated PSPs would be the same, not merely comparable. U S WEST represents that personnel from both USWPS and unaffiliated PSPs will obtain access to U S WEST's operation support systems through U S WEST's Interconnect Services Center. A request for installation or repair and maintenance will be sent to U S WEST Interconnect Services Center by USWPS personnel or by the personnel of unaffiliated PSPs. U S WEST Interconnect Services Center personnel will then access U S WEST's OSS systems to input these requests. U S WEST represents, however, that it will require several months to make necessary modifications in U S WEST's indirect OSS access system to enable that system to accommodate requests for access by USWPS. This is because the indirect access system was originally designed for use solely by unaffiliated PSPs. U S WEST represents that these modifications will be completed by July 1, 1997, and at that time USWPS will use the same indirect access system used by the personnel of unaffiliated PSPs. U S WEST requests that we approve its CEI plan on the condition that USWPS's access to OSS services will be the same as that of unaffiliated PSPs no later than July 1, 1997. 35. U S WEST disputes APA's contention that U S WEST treats USWPS more favorably in the scheduling of repairs. U S WEST denies that it does weekend line repairs for USWPS but not for others. U S WEST represents that its policy is not to undertake such work on the weekend, either for USWPS or for unaffiliated PSPs, but rather to hold such work until the next business day. It also contends that questions about U S WEST's personnel sharing are irrelevant because the Commission did not require structural separation between U S WEST and its payphone operations. U S WEST asserts that disputes involving changes in location providers raise contractual issues outside the scope of this proceeding. As to the determination of the demarcation point, U S WEST represents that all work on the network side of the demarcation point, which U S WEST identifies as the protector, will be charged to regulated accounts and all work on the payphone set side of the demarcation point is deregulated inside wire serivce, and will be charged to nonregulated accounts. 36. We find that U S WEST has met the installation, maintenance and repair requirement. We conclude that U S WEST'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. With respect to OSS access, we find that U S WEST's representations in its OSS ex parte that USWPS personnel will obtain the same access to U S WEST's OSS that unaffiliated personnel will obtain satisfies the Computer III/ONA requirements. We expressly condition our approval of this CEI plan on U S WEST providing USWPS access to OSS services under the same technical and other arrangements that unaffiliated PSPs obtain acces to U S WEST's OSS service, not later than July 1, 1997. 37. We find that APA has not substantiated its contention that U S WEST discriminates against competing PSPs in conducting weekend repairs. APA has offered no evidence to support its claim and U S WEST denies APA's allegation that U S WEST favors its payphone operations by conducting certain weekend repairs for its payphone operations but not unaffiliated PSPs. It U S WEST represents that it's "policy is to hold line work until Monday" and that "[t]his policy applies to both [PSPs] and USWPS." In other words, U S WEST will perform maintenance and repair work requested by either its own payphone operations or unaffiliated PSPs during regular business hours. 38. We also reject APCC's argument that U S WEST must provide further explanation about personnel sharing in order to ensure that there will be no discrimination against unaffiliated PSPs. U S WEST contends that APCC's concern about personnel sharing is another attempt to impose structural separation which the Commission has rejected. We agree with U S WEST that it may share personnel with USWPS. More importantly, we find that U S WEST's CEI plan sufficiently describes its procedures to address concerns about discrimination, even with shared personnel. For example, U S WEST represents in its plan that USWPS will be subject to the same scheduling procedures and time periods as other PSPs. It represents that U S WEST maintenance and repair intervals are based upon standard guidelines which are applied equally to USWPS and unaffiliated PSPs. U S WEST also asserts that the design of its mechanized maintenance systems prevents service intervals from being changed once the repair activity has been posted. U S WEST will also file quarterly reports on maintenance intervals for its operations and for unaffiliated PSPs. To the extent that APCC objects to the fact that a U S WEST technician dedicated to USWPS can repair both line problems and problems in a payphone set on one visit, whereas an unaffiliated PSP may need to send one technician for set repair and rely on a U S WEST technician for line repair, we find that objection unreasonable. To require U S WEST to use one technician for payphone set repairs and another for line repairs would be to undercut the efficiencies of integrated operations. We note that the Commission's rules require BOCs to allocate properly the costs, including costs associated with the use of personnel, between regulated and nonregulated operations. We also note that, pursuant to section 64.904 of the Commission's rules, LECs that file CAMs are required to have an independent audit performed annually. 39. We conclude that U S WEST has sufficiently identified the demarcation point to determine when maintenance becomes the payphone provider's responsibility and is not part of the access network service. It has identified this point as the "protector," and U S WEST represents that it will classify all work on the network side of the protector as regulated and all work on the payphone set side of the protector as deregulated, inside wire service. Finally, we find that APCC's request that service procedures address potential unfair marketing practices is beyond the scope of the installation, maintenance and repair requirement. To the extent that APCC's concern about unfair marketing practices raises issues about access to CPNI of unaffiliated PSPs, we conclude below that U S WEST's plan complies with applicable CPNI requirements. 6. End User Access 40. With regard to payphone services, this parameter requires the BOC to provide to all end users the same network capabilities to activate or obtain access to payphone services that utilize the BOC's facilities. This parameter also requires the BOC to provide all end users equal opportunities to obtain access to basic network facilities. 41. U S WEST states that the same basic services it provides to USWPS will be tariffed and available to unaffiliated PSPs. Telco argues that U S WEST's description of how it will provide end user access is too vague and that U S WEST must specify how end users will obtain access. We find that U S WEST is not required to provide the information requested by Telco in order to satisfy this CEI parameter. We find that U S WEST's CEI plan comports with the end-user access requirement established by the Commission. 7. CEI Availability 42. 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. Past decisions also have referred to this as the 90-day notice requirement. 43. The payphone rulemaking proceeding established the following tariffing requirements for LECs. LECs must file tariffs in the states for basic payphone services that enable independent PSPs to offer payphone services using either smart or dumb payphones and for any unbundled features that the LECs provide to their payphone operations or to others. LECs are not required to file tariffs for the basic payphone line for smart and dumb payphones with the Commission. As stated in the Clarification Order, LECs are required to file federal tariffs for payphone-specific, network-based features and functions "only if the LEC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to others . . . ." 44. U S WEST represents that all underlying basic services are currently or will be available to unaffiliated PSPs under tariff, catalog, or price list. It further represents that, if and when other basic services are to be deployed, U S WEST will make testing capability available to unaffiliated PSPs at the same time that such capability is made available to U S WEST's payphone operations. U S WEST states that it will not utilize any basic payphone service except pursuant to this CEI plan. U S WEST also requests that the Commission not enforce the prior testing requirement for U S WEST's provision of coin line service because it has used that service for years with its Classic ("Dumb") Payphone offering. To meet the testing requirement, U S WEST states that it would have to suspend offering its coin line service to the public during the testing period. 45. U S WEST filed with its CEI plan an illustrative state tariff for its coin line service and illustrative federal tariffs and sample state tariffs for the unbundled basic features it will offer in conjunction with its COCOT service. U S WEST also submitted sample state tariffs for the COCOT service. 46. APCC contends that the CEI plan must be rejected because U S WEST did not file the required federal tariffs. It contends that, pursuant to the Reconsideration Order, U S WEST must file tariffs for unbundled features at both the state and federal level, and that the only service for which a federal tariff is not required is the basic line for smart and dumb payphones. APCC argues that all basic payphone services and features other than the access line must be federally tariffed. APCC concludes that, because U S WEST did not file a federal tariff for the coin supervision and other features of its coin line service, the CEI plan must be rejected. 47. U S WEST responds that it has filed the required federal tariffs. It contends that the federal tariffing requirement extends only to the basic network services or unbundled features used by a BOC's operations to provide payphone service. U S WEST represents that it will use Smart PAL service as a unitary whole and therefore need not file a separate federal tariff for the coin supervision functions included in the Smart PAL service. U S WEST states that federal tariffs have been filed for those unbundled features, such as answer supervision and call blocking, that USWPS or unaffiliated PSPs may use in conjunction with COCOT service. 48. APCC notes that U S WEST's illustrative coin line tariff offers coin line service only "subject to the availability of existing [Central Office] facilities and special operator equipped locations." According to APCC, U S WEST must, therefore, be required to disclose where coin line service is not available and whether U S WEST has any payphones currently installed in those areas. AT&T argues that, at minimum, U S WEST's CEI plan must be amended to clarify that coin line service will be available to independent payphone service providers at every central office where such service is provided to U S WEST's payphone service affiliate, and to reflect such conditions of availability in its tariffs. APA maintains that the CEI plan must address how U S WEST will allocate central office facilities between its own payphone operations and independent payphone operators if there is a scarcity of such facilities. U S WEST responds that where coin line service is not available, U S WEST will provide COCOT service to payphone service providers, including U S WEST's payphone operations. U S WEST states that it will allocate facilities on a "first-come-first-served" basis for the types of services that it provides its customers. 49. APCC further contends that the CEI plan is incomplete because U S WEST only filed illustrative or sample tariffs which, in some cases, did not include prices. In response, U S WEST argues that filing representative samples is consistent with past practice and is all that is required. 50. We find that the plan complies with the CEI availability requirement. We reject APCC's argument that U S WEST must file a federal tariff for all payphone service features and functions except for the basic access line for COCOT and coin line service. 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. Because U S WEST will use, and offer, the features and functions of the Smart PAL service on a bundled basis, U S WEST need not unbundle those features and thus it need not file a separate federal tariff for them. U S WEST has filed a federal tariff for the unbundled features offered in conjunction with the Basic PAL service. We reject as well APCC's contention that U S WEST may not rely on illustrative or sample tariffs. We do not require carriers to file a complete set of tariffs with their CEI submissions. Sample or illustrative tariffs are sufficient. 51. We also conclude that U S WEST is not required to identify in its CEI plan specific geographic areas where coin line service is not available or to state whether U S WEST has any payphones in such areas or what type of service, Smart PAL or Basic PAL, is being provided. U S WEST's illustrative state coin line tariff provides that coin line service will be available at locations accessible to the public, subject to the availability of existing central office facilities and special operator equipped locations. U S WEST represents that where coin line service is not available, it will make COCOT service available to all payphone providers, including U S WEST's payphone operations. We find that the state tariff together with U S WEST's representation provides adequate information concerning the availability of its coin line service for purposes of our CEI plan requirements. We also find no basis in our CEI requirements or the payphone orders for directing U S WEST to identify how many of its payphones are Basic PAL and how many are Smart PAL for purposes of satisfying our CEI requirements. We also conclude that U S WEST has adequately responded to APA's concern about the allocation of facilities by stating that it will allocate on a first-come, first-served basis. 52. Finally we grant U S WEST's request not to enforce the 90-day notice requirement for U S WEST's provision of coin line service. Therefore, USWPS may continue to provide coin line service through the use of the CEI offering described herein for such service without first providing ninety days for unaffiliated carriers to test such service. This waiver is reasonable in this context because, unlike the provision of a new enhanced service, USWPS has been offering payphone service using coin line service for many years. To bar USWPS from continuing to use coin line service to provide payphone service for a period of ninety days would result in a suspension of service. U S WEST is not, however, relieved of its obligation to permit unaffiliated PSPs upon request to conduct testing of the coin line CEI offering. For purposes of approving this CEI plan, we simply waive the requirement that USWPS may not offer coin line service before such testing is accomplished. U S WEST states that if and when other basic services are deployed, U S WEST will make testing capability available to unaffiliated PSPs at the same time that such capability is available to USWPS. 8. Minimization of Transport Costs 53. This requirement obligates carriers to provide competitors with interconnection facilities that minimize transport costs. U S WEST states that its payphone operations utilize the same tariffed services as independent PSPs and, therefore, no differences in transmission costs exist. We find that U S WEST's CEI plan complies with the minimization of transport costs requirement. 9. Recipients of CEI 54. This requirement prohibits a BOC from restricting the availability of its CEI offering to any particular class of customer or PSP. 55. U S WEST avers that USWPS and the independent PSPs will obtain "access to the same tariffed services." We find that U S WEST has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 56. 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 57. The Payphone Order requires U S WEST 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. 58. In its CEI plan, U S WEST represents that it will not disclose the CPNI of an unaffiliated payphone service provider to USWPS (or any other PSP) without the express authorization of that unaffiliated PSP. U S WEST represents that its procedures comply with the Commission's current rules governing the use of CPNI to support enhanced services. 59. APCC and Telco claim that U S WEST's payphone CEI plan does not offer sufficient information concerning how it will comply with CPNI requirements. APCC contends that U S WEST should explain how it will protect, under nondiscriminatory conditions, the CPNI of unaffiliated PSPs, as well as the CPNI of U S WEST's existing semi-public payphone customers. APCC argues that, since the existing tariffed semi-public service will be terminated pursuant to section 276, U S WEST's payphone personnel have no more right to access and use the CPNI of semi-public service end users than any other PSP. APCC also contends that the deregulation of semi-public service presents PSPs with a potential marketing opportunity to replace U S WEST as the payphone service provider for these customers. APCC argues that semi-public customers should be provided notice and a meaningful opportunity to replace U S WEST with another payphone service provider. It contends that U S WEST 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 U S WEST's payphone operations. 60. APA contends that unaffiliated PSPs and USWPS "must be allowed the same acces to information available from the U S WEST network side of the business" in order prevent USWPS from gaining an unfair competitive advantage. APA argues that, for example, both unaffiliated PSPs and USWPS "should have the same access to customer information and the availability of facilities that is collected and maintained by U S WEST in its network group." 61. U S WEST responds that it will treat the CPNI of independent payphone providers as restricted from USWPS personnel. U S WEST maintains that this procedure affords the independent payphone providers with protections similar to those required by the Commission's CPE Computer II/ONA CPNI rules and is consistent with the obligations of sections 222(a) and (b) of the Telecommunications Act. Specifically, U S WEST represents the it will implement CPNI protections through methods and procedures that bar U S WEST payphone personnel from accessing the accounts of unaffiliated PSPs, and that this restriction will be enforced through internal audits. U S WEST avers that violators will be subject to disciplinary action, including dismissal. 62. With respect to semi-public service, U S WEST contends that, with the deregulation of semi-public payphone service, CPNI associated with semi-public service will become proprietary. Thus, unaffiliated payphone providers will have no right to it. U S WEST also maintains that APCC's request that U S WEST notify its semi-public payphone customers that this service is being deregulated and that the customer may choose another payphone provider is beyond the scope of this CEI plan review proceeding. 63. Finally, with respect to APA's contention that unaffiliated PSPs and USWPS must have the same access to information available from the U S WEST network side of the business, U S WEST argues that there is no requirement that competitors must be allowed "equal access" to "customer information." U S WEST contends that, to the extent "customer information" means CPNI, section 222 establishes different standards for internal company use of information and external third-party use. U S WEST argues, moreover, that to the extent "account information is not CPNI . . . but commercial proprietary information of USWPS, such information need not be disclosed by USWPS to its competitors." 64. In providing payphone services, U S WEST must comply with the Commission's pre-existing 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. U S WEST represents that it's procedures provide the protections required by the Commission's rules and are consistent with section 222. Accordingly, we find that U S WEST's plan comports with CPNI requirements. In reaching this conclusion, we do not address issues raised by APCC relating to the CPNI associated with 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 request that we require U S WEST 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. We also reject APA's broad request that unaffiliated PSPs and USPWS must have the same access to information from U S WEST's "network side of the business." APA has cited no authority that a such a requirement must be included in U S WEST's CEI plan. To the extent that APA's request encompasses CPNI, we find that the issue of "equal access" to CPNI is best addressed in the CPNI rulemaking proceeding. 2. Network Information Disclosure 65. The Payphone Order requires U S WEST 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. U S WEST must make that disclosure at the "make/buy" point, that is, when U S WEST decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface. U S WEST 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. U S WEST also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that service. 66. In the Payphone Order, the Commission waived the notice period for disclosure of network information relating to the "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory requirements of that order. Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15, 1997. 67. U S WEST's CEI plan avers that all new services and network interfaces offered by U S WEST have been and will be disclosed pursuant to the Commission's rules. U S WEST states that it has procedures in place to comply with these rules. As previously noted, U S WEST made its network disclosure on January 6, 1997. We find that U S WEST's CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 68. In the Payphone Order, we 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. 69. U S WEST's CEI plan represents that it tracks promised installation dates met and maintenance time intervals for both basic services used with its payphone services and basic services provided to independent PSPs. It represents that the nondiscrimination reports will be filed quarterly and will include: (1) the percentage of installation orders for which the promised intervals were met for basic services used by U S WEST's payphone operations and for all others, and (2) the average duration of reported troubles or outages for basic services used by U S WEST's payphone operations and for all others. U S WEST's plan provides that this information will be separately identified in a report that will be filed for all CEI services. U S WEST submitted a sample report. We find that U S WEST's CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 70. In the Payphone Order and the Accounting Safeguards Order, the Commission concluded that it should apply accounting safeguards identical to those adopted in Computer III to BOCs providing payphone service on an integrated basis. Pursuant to Computer III, the BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These safeguards consist of five principal elements: 1) the establishment of effective accounting procedures, in accordance with the Commission's Part 32 Uniform System of Accounts requirements and affiliate transactions rules, as well as the Commission's Part 64 cost allocation standards; 2) the filing of cost allocation manuals (CAMs) reflecting the accounting rules and cost allocation standards adopted by the BOC; 3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with their cost allocation manuals; 4) the establishment of detailed reporting requirements and the development of an automated system to store and analyze the data; and 5) the performance of on-site audits by Commission staff. U S WEST must comply with these accounting safeguards. We note that the approval granted to U S WEST in this order is contingent upon the CAM amendments associated with U S WEST's provision of payphone service going into effect. D. Other Issues 1. Sufficiency 71. APCC, APA and Telco generally assert that U S WEST's CEI plan insufficiently describes how U S WEST intends to comply with the CEI parameters; therefore, these parties request that the Commission require U S WEST to either amend or refile its plan. As discussed above, however, we find that U S WEST adequately complies with each of the required parameters. 2. Tariffing Issues 72. APCC and APA raise various objections to the content of U S WEST's state and federal tariffs. U S WEST responds that complaints about the adequacy of the rates or other aspects of its state tariffs should be raised in state tariff proceedings not in this CEI proceeding. It argues that the Commission has delegated to the states the responsibility for reviewing U S WEST's coin line tariffs. Similarly, U S WEST argues that issues concerning the pricing of the federally tariffed services must be raised in the context of those tariff proceedings. 73. We agree with U S WEST that the state and federal payphone tariff proceedings are the appropriate fora to address complaints concerning tariffed rates, terms and conditions. The Commission stated in the Reconsideration Order that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with 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." Similarly, we find that the objections to the rates in U S WEST's federal tariff appropriately are raised in this Commission's tariff proceeding where, in fact, APCC has filed a petition challenging U S WEST's rates. 3. Screening Codes 74. APCC, MCI and APA contend that U S WEST is required, pursuant to the Reconsideration Order, to provide PSPs using COCOT lines with screening code digits that uniquely identify their lines as payphone lines. APCC asserts that if U S WEST transmits a unique screening code only on its coin lines, which are primarily used by U S WEST's own payphone division, and not on its COCOT lines, which are primarily used by unaffiliated PSPs, U S WEST is discriminating in favor its payphone division by providing it a great advantage in the collection of per-call compensation from IXCs. In addition, MCI maintains that U S WEST does not provide screening code digits that can be "transmitted by PSPs for all access methods and from all locations." 75. U S WEST responds that it will provide screening codes in a nondiscriminatory fashion. It represents that all users of U S WEST's coin line service will use the "27" code while all users, USWPS or unaffiliated PSPs, of U S WEST's COCOT service will use the "07" code. U S WEST also argues that the "07" code does specifically identify the line as a payphone line once the interexchange carrier (IXC) makes a Line Information Database (LIDB) query. U S WEST contends that its use of the LIDB solution, i.e., the IXC making a LIDB query, satisfies the Commission's requirements. 76. We find that the issue of whether U S WEST is providing screening information in compliance with the requirements established in the payphone rulemaking proceeding to be outside the scope of the CEI review process and is more appropriately raised in that proceeding or in other proceedings. 4. Numbering Assignments 77. According to APCC, the Payphone Order requires LECs to assign line numbers to payphones on a nondiscriminatory basis. It contends that U S WEST should be required to reallocate the numbers assigned to the existing base of payphones, without charge, so that an equal percentage of LEC payphones and PSP payphones are assigned 8000 and 9000 series numbers. In reply, U S WEST contends that APCC's proposal to reallocate numbers without charge would impose needless burden and expense on LECs. U S WEST states that if an existing unaffiliated PSP or USWPS payphone does not have an 8000 or 9000 series number, U S WEST will reassign another 8000 or 9000 number, subject to availability, upon request at the tariffed rate for a number change. 78. 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. U S WEST states that it presently assigns payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by U S WEST in the context of this CEI plan. 5. Dialing Parity 79. MCI asserts that U S WEST also does not explain how it will comply with the dialing parity requirement in the Payphone Order, including access to operator service, directory assistance, and directory listings. U S WEST contends that this is not a CEI issue. 80. We agree with U S WEST. 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 location providers. The Commission stated that such dialing parity for payphones should be implemented at the same time as dialing parity for other telephones. U S WEST must, of course, comply with these requirements. We conclude, however, that U S WEST 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 parameters 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 U S WEST detail how it will comply with the dialing parity requirement is outside the scope of this CEI review proceeding. 6. Uncollectibles 81. AT&T asserts that U S WEST must explain its treatment of uncollectibles due to fraud. AT&T contends that, to the extent U S WEST establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be accorded to non-affiliates. U S WEST responds that there will be no cross-subsidization or discrimination in the way U S WEST treats uncollectibles. U S WEST represents that USWPS pays (and will continue to pay) all toll and access line billing from U S WEST. 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 U S WEST's CAM. 7. Operator Services 82. APCC contends that U S WEST's CEI plan fails to address whether U S WEST's intraLATA operator services are part of its deregulated payphone services. APCC argues that, if operator services are part of U S WEST's regulated operations, U S WEST must show that it is not subsidizing its payphone operations or discriminating between its payphone operations and unaffiliated PSPs in the provision of operator services. For example, if U S WEST is offering a commission to its payphone operations for presubscribing its payphones to U S WEST's operator services, then such commissions must also be available to unaffiliated PSPs on the same terms and conditions. U S WEST responds that its intraLATA operator services offered in connection with USWPS's payphones are part of U S WEST's regulated operations and will be offered to affiliated and nonaffiliated PSPs on a nondiscriminatory basis. U S WEST also represents that its accounting for payphone operations ensures that there will be no cross-subsidization. It represents that the coin line rate includes the cost of these operator services, and that USWPS will take those services at the tariffed rates. We conclude that U S WEST has sufficiently addressed the concerns raised by APCC. 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 83. The Inmate Calling Service Provider Coalition (ICSPC) raises a number of issues related to the provision of inmate calling services (ICS). ICSPC contends that U S WEST should be required to identify the network support and tariffed services its regulated operations will provide to USWPS's provision of ICS. ICSPC also argues that U S WEST must disclose whether its regulated operations will provide USWPS 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, U S WEST's failure to describe its provision of ICS in detail prevents the Commission from determining whether U S WEST has complied with the requirements of section 276. In addition, ICSPC asserts that U S WEST should be required to disclose whether its payphone operations will be responsible for the cost of ICS calls for which they are unable to collect. 84. ICSPC also asserts that U S WEST must show that call processing and call control systems used in USWPS's provision of ICS have been deregulated. According to ICSPC, to the extent U S WEST's call processing and call control systems dedicated to ICS are located in U S WEST's central offices, U S WEST must provide physical or virtual collocation to other providers. ICSPC also contends that U S WEST must disclose information on interfaces between U S WEST's equipment dedicated to ICS and its regulated network support services, so that other providers can utilize the same interface if they wish. 85. 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. 86. In response, U S WEST represents that, although it identified ICS as one of the payphone services that it offers, it did not separately discuss this service in detail because its treatment of ICS is consistent with its treatment of USWPS's other payphone services. U S WEST further represents that all payphone equipment, including call control equipment uniquely associated with ICS that provides time, PIN and other call-control functions, is classified as deregulated facilities and no such equipment is collocated in U S WEST's central offices. U S WEST also avers that the interface between its regulated network and such equipment and services provided by that equipment is the same interface that is available to any other PSP. U S WEST states that USWPS's inmate calling services will purchase the same tariffed services, coin line or COCOT, that are offered to unaffiliated providers of inmate calling services. In an ex parte filing, U S WEST states that it will assume the risk for uncollectibles where its inmate calling services utilize U S WEST's operator services to complete collect calls. U S WEST represents that it will similarly assume the risk for uncollectibles for unaffiliated ICS providers that utilize U S WEST's operator services to complete collect calls. According to U S WEST, it "assumes the uncollectible risk" by incorporating that risk into the amount of commissions it pays to USWPS or independent providers that use U S WEST operator services. 87. 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, U S WEST 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, U S WEST is required to offer on a tariffed basis any basic payphone service or network feature used by its payphone operations to provide ICS. 88. We conclude that U S WEST's CEI plan comports with our CEI requirements with respect to its provision of ICS. U S WEST avers that it will treat as deregulated all of its payphone equipment, including any call control equipment uniquely associated with ICS that provides timing, PIN, and other call-control functions. Additionally, USWPS will purchase the same tariffed network services, coin line or COCOT, to provide ICS as are available to all PSPs. U S WEST also has represented that its call control equipment is not collocated at its central offices. We find no support in the Payphone Order or Reconsideration Order for ICSPC's contention that U S WEST is required to provide collect calling as a nonregulated service when used with inmate payphones. 89. We conclude that the other issues raised by ICSPC related to the provision of ICS either already have 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 U S WEST 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 U S WEST's CAM. Finally, with regard to the disclosure of interface information, we have already concluded that U S WEST's CEI plan comports with the Commission's network information disclosure requirements. 9. Primary Interexchange Carrier Selection 90. Oncor asserts that, in order for U S WEST'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 U S WEST's CEI plan fails to describe how U S WEST will ensure that the PIC selection process for payphones will be performed on a nondiscriminatory basis. In reply, U S WEST contends that concerns regarding the payphone PIC selection and ordering process are beyond the scope of this proceeding and are not relevant to U S WEST's satisfaction of its CEI obligations toward payphone providers. 91. We conclude that U S WEST is not required as part of the CEI process to demonstrate how it will administer the PIC selection process for payphones. In the Payphone Order, the Commission specified that a BOC's CEI plan must describe how it will conform to the CEI parameters with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. The payphone rulemaking proceeding, however, did not require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as argued by AT&T and Oncor. Therefore, arguments raised by parties regarding U S WEST's role as PIC administrator are beyond the scope of this proceeding. 10. Call Rating 92. APCC contends that, in order to meet the Commission's CEI requirements, U S WEST must provide a coin line service that allows unaffiliated PSPs both to set their own end user rates for local and intraLATA calls and to establish the length of initial and overtime periods. 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 therefore requests the Commission to require U S WEST to develop a more flexible rating feature for its coin line service. U S WEST responds that APCC's call rating request is beyond the scope of this proceeding and states that the Commission considered and rejected the same request in the payphone proceeding. We agree. The Payphone Order did not require the BOCs to provide to unaffiliated PSPs an unbundled call rating feature for coin line services. In addition, on reconsideration of the Payphone Order, in response to a request that the Commission require access to, inter alia, call rating capabilities, the Commission specifically declined to require further unbundling of payphone services beyond those established in the Payphone Order. As previously noted, independent PSPs may seek additional unbundling through the 120-day ONA process. The appropriate state regulatory authorities may also impose further unbundling requirements. 11. Selection of Operator Services Provider 93. APCC requests that the Commission require U S WEST to unbundle operator services from its coin line service so that unaffiliated PSPs may select a third-party operator service provider for intraLATA calls. APCC argues that, under section 276, PSPs are entitled to select the operator service provider (OSP) for intraLATA calls, including local, operator-assisted calls, and therefore that, to the extent U S WEST does not permit OSP selection for its coin line service, its CEI plan is inconsistent with section 276. U S WEST responds that, as with the request to unbundle call rating, APCC's request is simply an effort to relitigate an issue decided in the payphone rulemaking proceeding and is beyond the scope of the CEI proceeding. We concur with U S WEST that APCC's request is beyond the scope of this proceeding, which is limited to determining whether U S WEST's CEI plan complies with the Commission's Computer III CEI requirements. 12. Millennium Payphones 94. APA argues that U S WEST has recently introduced a new "smart" payphone called the "Millennium" payphone which, APA contends, "provides special buttons to access certain services provided by U S WEST." This payphone, according to APA, is linked to a centralized platform that allegedly provides call rating and routing functions and prevents fraud. APA asserts that U S WEST's CEI plan is deficient because it does not describe the network features used by this new payphone and does not affirm that unaffiliated PSPs have equal access to such features. U S WEST responds that the "network control center" (NCC) that provides the functionality for the Millennium is CPE, not network equipment, and that unaffiliated PSPs have no right to obtain access to U S WEST's deregulated CPE. In an ex parte filing, US WEST further explains that the Millennium phone uses a COCOT line, the same line available to all other PSPs, to access the public switched telephone network. The switch then routes queries from the Millennium payphone over U S WEST's packet switched network (a tariffed product called Digipac) to the NCC. U S WEST represents that the NCC is a separate, stand-alone, computer-based system that is not part of the public switched network or Digipac. We conclude that U S WEST has adequately addressed questions concerning the Millennium payphone. 13. Interim Compensation Scheme 95. Finally, Telco argues that apart from the numerous deficiencies in U S WEST's CEI plan, the Commission should refrain from allowing U S WEST 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 proceeding. Moreover, the interim compensation rules were addressed at length in the payphone rulemaking proceeding. 14. Miscellaneous Other Issues 96. APA and APCC raise several other issues relating to U S WEST's payphone operations. APA contends that U S WEST's CEI plan must address U S WEST's use of agents to provide payphone services. APA argues that U S WEST's plan must be rejected because it does not include a plan to ensure the "nondiscriminatory" payment of certain commissions. APA also contends that U S WEST's publishing affiliate pays a fee to U S WEST for the "right" to place phone books at payphone locations, but does not offer such a fee to location owners or unaffiliated PSPs. We find that these issues are beyond the scope of this proceeding. 97. APA contends that U S WEST must address the nature of the relationship between USWPS and U S WEST's Interconnect Service Group. In particular, APA proposes that the two must operate in an arm's length fashion and that any agreements for unbundled goods and services must be documented in written agreements. U S WEST responds that APA's proposal is unnecessary for integrated operations and that the Accounting Safeguards Order addresses the proper accounting of transactions involving U S WEST's payphone operations. We agree. The Payphone Order expressly rejected structural separation requirements, and issues relating to proper accounting of transactions involving U S WEST's payphone operations were addressed in the accounting safeguards proceeding. 98. Finally, APCC maintains that, to the extent that U S WEST's payphone operation continues to offer "semi-public-like" payphone service that involves charging location providers for lines and usage of their payphones, U S WEST must disclose how such a 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 service issues to be beyond the scope of the CEI review process. V. CONCLUSION 99. We conclude that U S WEST's CEI plan complies with the Computer III requirements. Accordingly, in this Order, we approve U S WEST's CEI plan to offer payphone service, as described herein. We also approve U S WEST's request for a waiver of the testing requirement for the provision of its Smart PAL service as described above. VI. ORDERING CLAUSE 100. 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, U S WEST, Inc.'s Comparably Efficient Interconnection Plan for Payphone Service IS APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger, Jr. Deputy Chief, Common Carrier Bureau