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A.  a7DocumentgDocument Style StyleyXX` ` (#` a1Right ParRight-Aligned Paragraph Numbers:`S@ I.  X(# 2RC@ JA A Ba2Right ParRight-Aligned Paragraph NumbersC @` A. ` ` (#` a3DocumentgDocument Style Style B b  ?  1.  a3Right ParRight-Aligned Paragraph Numbers L! ` ` @P 1. ` `  (# a4Right ParRight-Aligned Paragraph Numbers Uj` `  @ a. ` (# 2F C CD EEa5Right ParRight-Aligned Paragraph Numbers _o` `  @h(1)  hh#(#h a6Right ParRight-Aligned Paragraph Numbers h` `  hh#@$(a) hh#((# a7Right ParRight-Aligned Paragraph NumberspfJ` `  hh#(@*i) (h-(# a8Right ParRight-Aligned Paragraph NumbersyW"3!` `  hh#(-@p/a) -pp2(#p 2rIFG=HHa1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . a6TechnicalTechnical Document Style)D (a) . a2TechnicalTechnical Document Style<6  ?  A.   29LIKJJKa3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   a1TechnicalTechnical Document StyleF!<  ?  I.   a7TechnicalTechnical Document Style(@D i) . 2ckLLRf yXa8TechnicalTechnical Document Style(D a) . "i~'K2^$(8<><q*"xxxxWWxxxWWkkxxx,?2?2>,H2H2H2H2H2J2J2!2222!2I822F2>>$?2>>J2:J2J2H2H2YHB$B$C26&6&6&62>$>?2J2J2J2J2J2J2^HH2@,@,@,J2?2J262?2H2<!22!!!WddddddddddddddddddddddddddddddddddddddddddddddddxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHHH222!,))22X222YY2#2222Y#!!442Ydd22<"(#I 1 XxPII. BACKGROUND p>"(#I 3 XxPIII. SERVICE DESCRIPTION p>"(#I 6 XxPIV. COMPLIANCE ISSUES p!(#B 10  Y-XxX` ` xA.` ` CEI Plan Requirements ` p!(#B 10  Y-XxX` ` xB.` ` Other Nonstructural Safeguards ` p"(#F 56  Y -XxX` ` xC.` ` Accounting Safeguards ` p"(#F 70  Y!-XxX` ` xD.` ` Other Issues ` p"(#F 71 XxPV. CONCLUSION p"(#F 99 XxPVI. ORDERING CLAUSE p!(#? 100 ";&0*''[[`'"Ԍ Y-ԙB I. INTRODUCTION ׃  Y-x1. ` ` On January 6, 1997, pursuant to the requirements of the Commission's orders  Y-in the payphone rulemaking proceeding,' xP5-ԍXxImplementation of the Pay Telephone Reclassification and Compensation Provisions of the  xP-Telecommunications Act of 1996, CC Docket No. 96128, Report and Order, FCC 96388 (rel. Sept.  xP-20, 1996) (Payphone Order), appeal docketed sub nom., Illinois Public Telecommunications Assn. v.  xP-FCC and United States, Case No. 961394 (D.C. Cir., filed Oct. 17, 1996), recon., FCC 96439 (rel.  xPU-November 8, 1996) (Reconsideration Order); Order, DA 97678 (Common Carrier Bur. rel. April 4,  xP -1997) (Clarification Order).(# U S WEST, Inc. (U S WEST) filed a comparably  Y-efficient interconnection (CEI) plan for payphone service.@' xP -ԍXxU S WEST, Inc.'s Comparable Efficient Interconnection Plan for Payphone Services (filed Jan. 6, 1997) (Payphone CEI Plan). U S WEST filed an erratum to its plan on January 8, 1997. Erratum to (# XxU S WEST, Inc.'s Comparably Efficient Interconnection Plan for Payphone Services (filed Jan. 8, 1997). U S WEST, Inc. filed the Payphone CEI Plan on behalf of all of U S WEST, Inc., including (# XxU S WEST Communications, Inc. CEI Payphone Plan at 1.(# In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan  Yw-describing how it will comply with the Commission's Computer III w ' xP-ԍXxAmendment of Section 64.702 of the Commission's Rules and Regulations, CC Docket No. 85229,  xP-PhaseI, 104 FCC 2d 958 (1986) (Phase I Order), recon., 2 FCC Rcd 3035 (1987) (Phase I  xP-Reconsideration Order), further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Reconsideration  xPp-Order), second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further Reconsideration),  xP8-Phase I Order and Phase I Reconsideration Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir.  xP-1990) (California I); Phase II, 2 FCC Rcd 3072 (1987) (Phase II Order), recon., 3 FCC Rcd 1150  xP-(1988) (Phase II Reconsideration Order), further recon., 4 FCC Rcd 5927 (1989) (Phase II Further  xP-Reconsideration Order), PhaseII Order vacated, California I, 905 F.2d 1217 (9th Cir. 1990);  xPX-Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA Remand Order), recon., 7 FCC  xP -Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (California  xP-II); Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier1 Local  xP-Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order), recon. dismissed in  xPx-part, Order, CC Docket Nos.90623 & 92256, FCC 96222 (rel. May17, 1996); BOC Safeguards  xP@-Order vacated in part and remanded, California v. FCC, 39 F.3d 919 (9th Cir. 1994) (California III),  xP-cert. denied, 115 S.Ct. 1427 (1995) (referred to collectively as the ComputerIII proceeding).(#ƫ CEI equal access  Y`-parameters and nonstructural safeguards for the provision of payphone services.\`p' xP-ԍXxPayphone Order, at para. 202.(#\ Bocs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations  Y -to provide payphone services.Z ' xP#-ԍXxId. at paras. 146, 200204.(#Z " 0*%%[[ "Ԍ Y-x2. ` ` The Commission issued a public notice of U S WEST's CEI plan on January  Y-8, 1997. ' xPb-ԍXxPleading Cycle Established for Comments on Comparably Efficient Interconnection Plan for Payphone  xP*-Service Providers, Public Notice, CC Docket No. 96128, DA 9731 (rel. Jan. 8, 1997).(#  On February 7, 1997 seven parties filed comments opposing the plan. ' xP-ԍXxComments of the American Public Communications Council on U S WEST, Inc.'s CEI Plan (APCC Comments); Comments of the Arizona Payphone Association, Colorado Payphone Association, Minnesota Independent Payphone Association and Northwest Payphone Association (collectively referred to herein as APA) to U S WEST, Inc.'s Proposed CEI Plan (APA Comments); MCI Telecommunications Corporation Comments (MCI Comments); Comments of Telco Communications Group, Inc., on U S WEST, Inc.'s Comparably Efficient Interconnection Plan (Telco Comments); Comments of Oncor Communications, Inc. (Oncor Comments); Comments of the Inmate Calling Service Providers Coalition on U S WEST Inc.'s CEI Plan (ICSPC Comments); AT&T's Comments On U S WEST's Comparably Efficient Interconnection Plan (AT&T Comments). APCC filed an erratum to its comments on February 12, 1997.(#Ɖ U S WEST submitted reply comments on February 24, 1997. For the reasons discussed below, we approve U S WEST's CEI plan.  Y- II. BACKGROUND ׃  Y`-x3. ` ` The payphone rulemaking proceeding implemented section 276 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996 (1996  Y2-Act).M2 ' xP-ԍXx47 U.S.C.  276. (#M 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  Y -service.U H ' xP-ԍXx47 U.S.C.  276(b)(1)(C).(#U The 1996 Act provided that such safeguards must, at a minimum, include the  Y -nonstructural safeguards adopted in the Computer III proceeding.U ' xPH-ԍXx47 U.S.C.  276(b)(1)(C).(#U  Y-x4. ` ` In the Payphone Order, the Commission determined that the Computer III and  Yz-Open Network Architecture (ONA) zh' xP!-ԍXxSee Filing and Review of Open Network Architecture Plans, 4 FCC Rcd 1 (1988) (BOC ONA Order),  xP["-recon., 5 FCC Rcd 3084 (1990) (BOC ONA Reconsideration Order); 5 FCC Rcd 3103 (1990) (BOC  xP##-ONA Amendment Order), erratum, 5 FCC Rcd 4045, pets. for review denied, California v. FCC, 4  xP#-F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 97 (1993) (BOC ONA Amendment Reconsideration  xP$-Order); 6 FCC Rcd 7646 (1991) (BOC ONA Further Amendment Order); 8 FCC Rcd 2606 (1993)"$ 0*%%$"  xP-(BOC ONA Second Further Amendment Order), pet. for review denied, California v. FCC, 4 F.3d  xPX-1505 (9th Cir. 1993) (collectively referred to as the ONA Proceeding).(#Ə nonstructural safeguards would "provide an appropriate"z  0*%%[[," regulatory framework to ensure that BOCs do not discriminate or crosssubsidize in their  Y-provision of payphone service."8  ' xP-ԍXxPayphone Order, at para. 199. In addition, the Commission adopted accounting safeguards for BOC  xP-and incumbent LEC provision of payphone service on an integrated basis. See Implementation of the  xPJ-Telecommunications Act of 1996: Accounting Safeguards Under the Telecommunications Act of 1996,  xP-CC Docket No. 96150, Report and Order, FCC 96490, para. 100 (rel. Dec. 24, 1996) (Accounting  xP-Safeguards Order).(#8 Accordingly, the Commission required the BOCs to file  Y-"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  Y-nondiscrimination requirements." x' xP-ԍXxPayphone Order, at para. 199. In its notice of proposed rulemaking regarding the CPNI and other customer information provisions of the 1996 Act, the Commission concluded that its previously established CPNI requirements would remain in effect, pending the outcome of that rulemaking, to  xPf-extent that they do not conflict with the CPNI provisions of the 1996 Act. See Implementation of the Telecommunications Act of 1996: Telecommunication Carriers' Use of Customer Proprietary Network  xP-Information and Other Customer Information, CC Docket No. 96115, Notice of Proposed Rulemaking,  xP-11 FCC Rcd 12513, 12529 (1996) (CPNI NPRM). (# Obtaining approval of its CEI plan is one of the criteria a BOC must meet before its payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established  YH-in the payphone proceeding.fH' xP -ԍXxReconsideration Order, at para. 132. In addition to an approved CEI plan, in order to receive  xP-compensation, the Reconsideration Order requires that "a LEC must be able to certify the following: (1) it has an effective cost accounting manual ("CAM") filing; (2) it has an effective interstate CCL tariff reflecting a reduction for deregulated payphone costs and reflecting additional multiline subscriber line charge ("SLC") revenue; (3) it has effective intrastate tariffs reflecting the removal of charges that recover the costs of payphones and any intrastate subsidies; (4) it has deregulated and reclassified or transferred the value of payphone customer premises equipment ("CPE") and related costs as required  xP-in the [Payphone Order]; (5) it has in effect intrastate tariffs for basic payphone services (for "dumb" and "smart" payphones); and (6) it has in effect intrastate and interstate tariffs for unbundled  xP-functionalities associated with those lines." Id. at para. 131.(#f  Y -x5. ` ` The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrumentimplemented 'smart payphones' or 'dumb'" 0*%%[[m "  Y-payphones that utilize central office coin services, ' xPy-ԍXxA "smart" payphone has capabilities programmed into it that perform certain functions, such as rating calls or collecting or returning coins. A "dumb" payphone does not have such capabilities, but must  xP -instead rely on central office controls to collect and return coins or perform other functions. See U S WEST Payphone CEI Plan at 3.(#ƣ or some combination of the two in a  Y-manner similar to the LECs."c' xPJ-ԍXxReconsideration Order, at para. 162.(#c Those tariffs must be filed with the applicable state  Y-regulatory commission.T@' xP -ԍXxId. at paras. 16263.(#T Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone affiliate to provide  Y-payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis.' xP% -ԍXxPayphone Order, at paras. 146148; Reconsideration Order, at paras. 162163; Clarification Order, at para. 8.(#Ƹ  Xv- III. SERVICE DESCRIPTION ׃  YH-x6.` ` 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  Y -WEST Communications, Inc."Y ( ' xP-ԍXxU S WEST Payphone CEI Plan at 2.(#Y USWPS provides three types of payphone service: (1) Public Telephone Service; (2) SemiPublic Telephone Service and Shared Payphone Service;  Y -and (3) Inmate Calling Service.B ' xPU-ԍXxId.(#B  Y -x7. ` ` Public Telephone Service is either outgoing only or twoway service and can be coin or coinless. USWPS offers four Public Telephone Service options:  Yy-Xx© CoinOperated 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.(#  Y-Xx© Coin Operated Payphone Service ("Smart" Payphone). This service offering uses payphone sets that are capable of rating local calls, collecting and returning coins,"H 0*%%[["  Y-rating and routing toll calls, and providing "stationbased operator services."' xPy-ԍXxStationbased operator services are mechanized operator services programmed into the set that prompt the caller on how to place and complete a call. (# The payment options available to end users are cash or billing as collect, third party, or calling card. (#  Y-Xx© 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.(#  YJ-Xx© 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 directdialedcall billing. End users have access to local and toll services. The payment options available to end  Y -users are limited to billing as collect, third party, or calling card.J ' xP-ԍXxId. at 23.(#J(#  Y -x8. ` ` The SemiPublic 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 SemiPublic 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  Y8-provider.H8' xP-ԍXxId. at 4.(#H  Y -x9. ` ` The Inmate Calling Service provides a payphone set that relies on central office and operator or premisesbased call management systems for the control of rating and billing. It has unique screening features that prohibit directdialed calls, calling card, and thirdnumber billing. This service option provides end users access to local and toll services  Y-on a collect billing arrangement.B@' xP-ԍXxId.(#B "0*%%[["Ԍ Y- IV. COMPLIANCE ISSUES ׃  X- A.xCEI Plan Requirements   Y-x 10. ` ` The Commission's CEI requirements were originally established in the  Y-Computer III proceeding, in which the Commission adopted a regulatory framework to  Yw-govern the provision of integrated enhanced and basic services by the BOCs.w' xP-ԍXxSee Phase I Order, 104 FCC 2d at 1026, para. 128. Requiring BOCs to file CEI plans was one of the nonstructural safeguards adopted by the Commission, in lieu of structural separation, to prevent cross xP -subsidization and discrimination. As a first step in implementing the Computer III framework, the Commission permitted the BOCs, which remained subject to various structural separation requirements, to offer individual enhanced services on an integrated basis following approval of servicespecific CEI plans. BOCs were required to describe in their CEI plans: (1) the enhanced service or services to be offered; (2)how the underlying basic services would be made available for use by competing ESPs;  xPh -and (3)how the BOCs would comply with the other nonstructural safeguards imposed by ComputerIII.  xP0-See Phase I Order, 104 FCC 2d at 103459, paras. 142200.(# 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  Y -payphone rulemaking proceeding.s ' xPM-ԍXxSee Reconsideration Order, at paras. 163165..(#s The Commission, in its Computer III proceeding,  Y -established nine specific CEI requirements,v ( ' xP-ԍXxPhase I Order, 104 FCC 2d at 10391043, paras. 154166.(#v 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.  X-x 1.` ` Unbundling of Basic Services  Yc-x 11.` ` The Payphone Order deregulated LEC payphones and classified those  YL-payphones as customer premises equipment (CPE).\L ' xP-ԍXxPayphone Order, at para. 142.(#\ In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either "smart" payphones or "dumb" payphones that utilize central office coin services, a LEC must also  Y-tariff unbundled payphone features that the LEC uses or provides on an unbundled basis.H ' xP#-ԍXxPayphone Order, at paras. 146148; Reconsideration Order, at paras. 162163, 165; Clarification  xP#-Order, at para. 8.(# Moreover, BOCs, but not other LECs, must unbundle additional network elements when"0*%%[["  Y-requested by payphone providers based on the specific criteria established in the Computer  Y-III and ONA proceedings.' xPb-ԍXxPayphone Order, at para. 148; Reconsideration Order, at para. 165.(#Ƈ  Y-x 12.` ` The Payphone Order requires BOCs to file CEI plans that explain how they  Y-will unbundle basic payphone services.\X' xP-ԍXxPayphone Order, at para. 204.(#\ Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic  Yv-service functions that underlie its provision of payphone service. v' xP -ԍXx#c P7 P#Id. (citing Phase I Order, 104 FCC 2d at 1040). See also, Reconsideration Order, at para. 213 .(# Nonproprietary information used by the BOC in providing the unbundled basic services must be made  YH-available as part of CEI.!Hx' xPq-ԍx#c P7 P#Payphone Order, at para. 204 (citing Phase I Order, 104 FCC 2d at 1040). In addition, any options available to the BOC in the provision of  Y1-such basic services or functions must be included in the unbundled offerings."1' xP-ԍxId. See also, Reconsideration Order at para. 213 (citing Phase I Order at 1040).  Y -x 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  Y -Access Line (Smart PAL) used with "dumb" payphones.%#X ' xP-ԍXxU S WEST's underlying basic services also includes a "Single Party Flat Rate Business" service available only in Iowa and Minnesota as permitted by the regulatory commissions in those two states. U S WEST Payphone CEI Plan at Exh. A.(#% 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.  Yy-x 14. ` ` U S WEST describes Smart PAL service as a voicegrade 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  Y4-returned and rates all coin paid long distance calls.T$x4 ' xP-ԍXx Id. U S WEST's Illustrative Smart PAL tariff states that this line utilizes central office coin features, and that this service provides the following: coin signaling, including coin collect and coin return; company completed and carried local and intraLATA toll messages, both sent paid and nonsent paid; company operator services/systems for all 0, 0+, and 1+ intraLATA toll calls, and 0+ local calls; routing to the presubscribed carrier for all 0+ and 00 interLATA calls; paypercall blocking; incoming and outgoing call screening; and access to directory assistance, 911 emergency code, all interexchange carriers, 800/800type service and 950 telephone numbers, and company repair service."M$#0*%%\$"  xP-Id. at Exh. B.(#T"4X$0*%%[["Ԍ Y-ԙx15. ` ` The Basic PAL service is a voicegrade switched line that provides a payphone  Y-service provider with a line side connection to the circuit switched network.M%X' xP-ԍXxId. at Exh. A.(#M U S WEST also offers certain optional features on an unbundled basis in conjunction with its Basic PAL  Y-service. These features are: answer supervisionline side; billed number screening;&X' xPT-ԍXxBilled number screening indicates to the operator numbers that are associated with payphone lines and, consequently, may not be used to bill collect calls or third party number calls. U S WEST Payphone CEI Plan at Exh. A.(# 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  Y_-"10XXX011+" international toll calls; and international call blocking.C'_' xP-ԍXxId. (#C  Y1-x16.` ` 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 120day ONA process and will make those services available where such requests comply with the factors established by the  Yy-Commission for selection of ONA services.|(Xy' xP-ԍXxId. at 6. The ONA factors are market demand, utility as perceived by the independent payphone  xP-providers, and technical feasibility. See In the Matter of Filing and Review of Open Network  xPR-Architecture Plans, Memorandum Opinion and Order, 4 FCC Rcd. 1, 207 (1988). (#| h  YK-x17.` ` APCC and APA argue that the CEI plan must be rejected because it does not  Y4-sufficiently unbundle payphone features and functionalities from the payphone access line.) 4 ' xP-ԍXxAPCC Comments at 67; APA Comments at 5. See also Letter from Gregory A. Ludvigsen, on Behalf of the Arizona Payphone Association, Colorado Payphone Association, Minnesota Payphone Association and Northwest Payphone Association, to the Secretary, Federal Communications  xP!-Commission (March 10, 1997) (APA's Ex Parte).(#ơ 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 " )0*%%[["Ԍ Y-U S WEST proposes to offer as part of those basic payphone offerings.N*' xPy-ԍXxAPCC Comments at 67.(#N 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, paypercall blocking, call screening and operator services, that U S  Y-WEST proposes to provide as part of its coin line service.C+X' xP-ԍXxId. (#C Moreover, APCC argues that U S WEST should price these additional features at the same rate whether they are used with  Yv-COCOT or coin lines.H,v' xP -ԍXxId. at 7.(#H 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  YH-from cross subsidization._-Hx' xPq-ԍXxId. at 67; APA Comments at 78.(#_ 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  Y -supervision functions.M. ' xP-ԍXxAPA Comments at 67.(#M  Y -x18. ` ` 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  Y -unbundle features and functionalities that the BOC itself uses on an unbundled basis.X/ ' xP-ԍXxU S WEST Reply Comments at 89.(#X  Yy-x19. ` ` 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  Y4-services using either a "smart" or "dumb" payphones or to offer inmate calling services.T04( ' xP -ԍxPayphone Order, at para. 146.T 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  Y-their payphone operations.\1 ' xPX"-ԍxReconsideration Order, at para. 146. \ 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" H 10*%%[["  Y-features and functions through the ONA 120day service request process.^2' xPy-ԍxClarification Order, at para. 8, n. 23.^ Any other unbundled features and functions provided by U S WEST must comply with the tariffing and  Y-CEI requirements of the payphone rulemaking proceeding, Computer III and ONA. 0  Y-x20.` ` 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  Yv-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  YH-unbundled basis."3HX' xPQ -ԍXxClarification Order, at para. 16 (citing Payphone Order at para. 148; Reconsideration Order, at para. 165).(#ƶ 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  Y -feature in both the state and federal jurisdictions.24 ' xP6-ԍXxClarification Order, at para. 16. That Order clarified that the unbundled features and functions addressed in the payphone rulemaking proceeding are network services similar to basic service elements ("BSEs") under the ONA regulatory framework. BSEs are defined as optional unbundled features that  xP-an enhanced service provider may require or find useful in configuring its enhanced service. Id. at  xPV-para. 17 (citing Filing and Review of Open Network Architecture Plans, Phase I, Memorandum  xP-Opinion and Order, FCC 88381, 4 FCC Rcd 1 (1988) ("BOC ONA Order")). In this case, the unbundled features are payphonespecific, networkbased features and functions used in configuring unregulated payphone operations provided by PSPs or LECs. Some of the LECs use terms such as tariffed "options" and "elective features" to refer to network services that other LECs call features and  xP>-functions. The Clarification Order concluded that "[o]ptions and elective features must be federally tariffed in the same circumstances as features and functions must be federally tariffed, depending on whether they are provided on a bundled basis with the basic network payphone line (state tariff), or  xP-separately on an unbundled basis (federal and state tariffs)." Id. (citing Application of Open Network  xP^-and Nondiscrimination Safeguards to GTE Corporation, 11 FCC Rcd 5558 (1995)). (#2 Because U S WEST offers, and will use,  Y -the Smart PAL service as a "unitary whole,"X5 h' xP-ԍXxU S WEST Reply Comments at 89.(#X 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  Yy-payphone providers, both affiliated and unaffiliated, that subscribe to its Basic PAL service.6Xy' xP"#-ԍXxId. at 8. U S WEST represents that it has filed a federal tariff for every payphone specific feature or function that USPWS takes or that U S WEST offer to unaffiliated PSPs. Letter from BB Nugent, Exec. Dir. Federal Regulatory, to William F. Caton, Acting Secretary, Federal Communications"$50*%%$" Commission (March 20, 1997).(#ƨ "y X60*%%[[,"  Y-No further unbundling is required at this time.a7X' xP -ԍXxPayphone Order, at paras. 146148.(#a Independent payphone providers may seek  Y-further unbundling by making a request pursuant to the ONA process.Q8' xP-ԍXxId., at para. 148.(#Q  X-  X-x2.` ` Interface Functionality  Y-x21.` ` The interface functionality requirement obligates the BOC to make available standardized hardware and software interfaces that are able to support transmission,  Y_-switching, and signaling functions identical to those used by the BOC's payphone service.9_x' xP -Ѝx#c P7 P#Id. at paras. 20203; Phase I Order, 104 FCC 2d at 1039, para. 157.  Y1-x22.` ` 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  Y -which comply with the Commission's network disclosure rules.[: ' xP-ԍXxU S WEST Payphone CEI Plan at 45.(#[ 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  YK-network disclosure requirements.Y;K' xP-ԍXxU S WEST Payphone CEI Plan at 5.(#Y  Y-x23. ` ` 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  Y-network interfaces . . . ."O<( ' xP"-ԍXxTelco Comments at 23.(#O Telco also faults U S WEST for providing no description of the" <0*%%[["  Y-interfaces.B=' xPy-ԍXxId.(#B 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  Y-in its January 6, 1997 network disclosure.>X' xP-ԍXxU S WEST Reply Comments at 24. PSPs may obtain information on U S WEST's technical interfaces through a U S WEST website.(#Ƴ  Y-x24. ` ` 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.  X -x 3. Resale  Y-x25.` ` The resale requirement established in Computer III obligates a "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper costshifting to regulated  YK-operations and anticompetitive pricing in unregulated markets."?K' xP-Ѝx#c P7 P#Phase I Order, 104 FCC 2d at 1040, para. 159. Based on the requirement  Y4-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  Y-available on a nondiscriminatory basis to other payphone providers.@@' xP-ԍxPayphone Order, at para. 200; Reconsideration Order, at para. 211.  Y-x26.` ` U S WEST represents that its payphone operations will "impute the tariffed  Y-rates for all basic services used to provide its payphone services."[A' xPB -ԍXxU S WEST Payphone CEI Plan at 67.(#[ We find that U S WEST has met the resale requirement. We are not persuaded by Telco's argument that U S  Y-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"g ` A0*%%[[{"  Y-resale obligations are being met."\B' xPy-ԍxTelco Comments at 3 (emphasis in original).\ 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, factbased claims should be addressed in federal or state tariff proceedings or formal complaint actions against U S WEST.  XH-x 4. Technical Characteristics  Y -x27.` ` 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  Y -payphone services.C X' xP-  ЍXxPayphone Order, at paras. 199207; Reconsideration Order, at 218220; and #c P7 P#Phase I Order, 104 FCC 2d at 1041, para. 160.(#  Y -x28.` ` 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  Yb-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  Y-and that future affidavits will address basic services used for payphone services.[D' xPP-ԍXxU S WEST Payphone CEI Plan at 78.(#[ We find that U S WEST's CEI plan comports with the technical characteristics requirement established by the Commission.  X- x 5. Installation, Maintenance, and Repair  Ye-x29.` ` The Payphone Order requires BOCs to describe in their CEI plans how they  YN-will comply with the nondiscrimination requirements in Computer III and ONA regarding the  Y7-quality of service, installation, and maintenance.TE7@' xP($-ԍxPayphone Order, at para. 207.T This requirement ensures that the time"7E0*%%[[=" 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  Y-its affiliated payphone service operations.F' xPK-ЍxPayphone Order at para. 203; #c P7 P#Phase I Order, 104 FCC 2d at 1041, para. 161. BOCs also must satisfy reporting and other  Y-requirements showing that they have met this requirement.7G X' xP-  0ЍXxU S WEST must provide quarterly reports on installation and maintenance of its basic services. Phase I  xP-  Order, at 10551056, paras. 192193. The Payphone Order does not impose any new continuing reporting  xPT-  requirement because BOCs are already subject to reporting requirements pursuant to Computer III and  xP -ONA. BOCs must report on payphone services as they do for basic services.(#7  Y-x30.` ` 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  Y1-PSPs.[H1@' xP"-ԍXxU S WEST Payphone CEI Plan at 89.(#[ 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  Y -prevent service intervals from being changed once the repair has been posted.HI ' xPm-ԍXxId. at 9.(#H  Y -x31. ` ` 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  Y-Support Systems (OSS) supporting installation, maintenance, and repair functions.JJ` ' xP-ԍXxId. at 9. (#J 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  Y-action.IK ' xP-ԍXxId. at 10.(#I x  Y-x32.` ` APCC argues that U S WEST's CEI plan must provide further detail regarding how it will provide installation and repair on an nondiscriminatory basis to unaffiliated  Y-PSPs.ML ' xP$-ԍXxAPCC Comments at 15.(#M APCC also objects to the plan because it fails to specify how U S WEST's"L0*%%[[" payphone personnel will have access to U S WEST's OSS. APA contends that U S WEST  Y-must allow unaffiliated PSPs the same, not just comparable, access to U S WEST's OSS.OM' xPb-ԍXxAPA Comments at 1314.(#O 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  Y-sent by facsimile transmission.INX' xP-ԍXxId. at 13.(#I 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  YH-payphone service providers.IOH' xP -ԍXxId. at 17.(#I  Y -x 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  Y -the provision of installation, maintenance and repair.OP x' xP-ԍ XxAPCC Comments at 17.(#O APCC contends that U S WEST must describe the service ordering procedures it will follow when a location provider changes  Y -from a U S WEST payphone to an unaffiliated PSP payphone and vice versa.LQ ' xP`-ԍXxId. at 1516.(#L APCC asserts that these procedures must be specified to ensure that conflicts that arise in this  Yy-context are resolved in a nondiscriminatory fashion.CRy' xP-ԍXxId..(#C 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  Y-order is placed for an unaffiliated PSP payphone.IS( ' xP-ԍXxId. at 16.(#I Finally, APCC argues that U S WEST should identify for its payphone offerings the demarcation point between the switched  Y-network and a payphone provider's inside wire.LT ' xPX"-ԍXxId. at 1617.(#L  Y-x!34. ` ` In an ex parte submitted on April 2, 1997, U S WEST clarified that access to"H T0*%%[[" U S WEST's OSS by USWPS personnel and the personnel of unaffiliated PSPs would be the  Y-same, not merely comparable.U' xPb-ԍXxLetter from Elridge Stafford, Exec. DirectorFederal Regulatory, to William Caton, Acting Secretary, Federal Communications Commission, (April 2, 1997) (OSS ex parte).(# 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  YH-OSS access system to enable that system to accommodate requests for access by USWPS.MVH ' xP -ԍXxOSS ex parte at 12.(#M This is because the indirect access system was originally designed for use solely by  Y -unaffiliated PSPs.W ' xP{-ԍXxId. U S WEST represents that this indirect access system will be available to unaffiliated PSPs by April 15, 1997.(#Ʋ 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.  Y-x"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  Yb-for USWPS but not for others.OXb' xP-ԍxU S WEST Reply Comments at 13.O 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  Y-between U S WEST and its payphone operations.LY' xPO-ԍXxId. at 1314.(#L U S WEST asserts that disputes involving changes in location providers raise contractual issues outside the scope of this  Y-proceeding.Z( ' xP!-ԍXxSee Letter from Elridge A. Stafford, Exec. Dir. Federal Regulatory, to William F. Caton, Acting Secretary, Federal Communications Commission (March 21 1997) at 3.(# 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" Z0*%%[["  Y-protector,?[X' xPy-ԍXxU S WEST Reply Comments at 14. U S WEST describes the protector as a piece of equipment used to take stray voltage to the ground; it is usually placed where the standard network interface would be  xP -located. Id. at 15 n. 37.(#? 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  Y-accounts.\' xPk-ԍXxLetter from Elridge A. Stafford, Exec. Dir. Federal Regulatory, to William F. Caton, Acting Secretary, Federal Communications Commission (April 4, 1997) (April 4 ex parte).(#  Y-x#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  Y -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.  Y -x$37. ` ` We find that APA has not substantiated its contention that U S WEST discriminates against competing PSPs in conducting weekend repairs. APA has offered no evidence to support its claim and U S WEST denies APA's allegation that U S WEST favors its payphone operations by conducting certain weekend repairs for its payphone operations  YK-but not unaffiliated PSPs.W]K@' xP<-ԍXxU S WEST Reply Comments at 13.(#W It U S WEST represents that it's "policy is to hold line work  Y4-until Monday" and that "[t]his policy applies to both [PSPs] and USWPS."B^4' xP-ԍXxId.(#B In other words, U S WEST will perform maintenance and repair work requested by either its own payphone operations or unaffiliated PSPs during regular business hours.  Y-x%38. ` ` We also reject APCC's argument that U S WEST must provide further explanation about personnel sharing in order to ensure that there will be no discrimination against unaffiliated PSPs. U S WEST contends that APCC's concern about personnel sharing is another attempt to impose structural separation which the Commission has  Y|-rejected.Z_|` ' xP$-ԍXxU S WEST Payphone CEI Plan at 13.(#Z We agree with U S WEST that it may share personnel with USWPS. More"| _0*%%[[|" 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  Y-unaffiliated PSPs.X`' xP-ԍXxUS WEST Payphone CEI Plan at 9.(#X 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  Y_-posted. U S WEST will also file quarterly reports on maintenance intervals for its operations  YH-and for unaffiliated PSPs.ZaHX' xPQ -ԍXxU S WEST Payphone CEI Plan at 14.(#Z 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  Y -with the use of personnel, between regulated and nonregulated operations.gb ' xP@-ԍXxSee 47 C.F.R.  64.901, 64.903. (#g We also note that, pursuant to section 64.904 of the Commission's rules, LECs that file CAMs are  Yy-required to have an independent audit performed annually.Ycyx' xP-ԍXxSee 47 C.F.R.  64.904.(#Y  YK-x&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  Y-service.nd' xP-ԍXxU S WEST Reply Comments at 14; April 4 ex parte at 1.(#n 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. "ed0*%%[[{"Ԍ X- x6. End User Access  Y-x'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  Y-all end users equal opportunities to obtain access to basic network facilities.e' xP-ЍXxSee Phase I Order, 104 FCC 2d at 1041, para. 162; Payphone Order, at para. 199.(#Ƥxx  Y_-x(41.` ` U S WEST states that the same basic services it provides to USWPS will be  YH-tariffed and available to unaffiliated PSPs.|f HX' xPQ -ԍXxU S WEST Payphone CEI Plan at 10. As noted above, U S WEST represents that USWPS will use no interface, signaling, abbreviated dialing, derived channels, or other unique capabilities to access U S WEST's basic services which are not also available to unaffiliated PSPs through a tariff, published price lists, or catalogs.(#| 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  Y -users will obtain access.Mg @' xP -ԍXxTelco Comments at 3.(#M 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 enduser access requirement established by the Commission.  X -x 7.` ` CEI Availability  Yy-x)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  Y-testing their payphone service offerings.h' xP-ԍXxPhase I Order, 104 FCC 2d at 1041, para.163. The testing period is necessary "to balance the conflicting interests of the carrier, which should have a reasonable period to develop, test, and 'debug' its CEI offerings before making them publicly available, and other CEI users, such as competitors, that might suffer an unfair competitive disadvantage if carriers were able to test and perfect their . . . services particularly, their interconnection with the basic underlying facilities while withholding  xP -those same basic facilities from others." Id.(#Ɗ Past decisions also have referred to this as the  Y-90day notice requirement.iXH ' xP"-ԍXxSee e.g., Bell Operating Companies' Joint Petition for Waiver of Computer II Rules, Ameritech's Request for Waiver Related to Minor Amendment to Ameritech's Plan to Provide Comparable Efficient  xP$-Interconnection to Providers of Voice Mail Messaging Service, CCBPol 9623, Order, DA 961894"$h0*%%$"  xP-(rel. Nov. 14, 1996) (Ameritech Minor Amendments).(#"Xi0*%%[["Ԍ Y-ԙx*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  Y-others.ijX' xP-ԍXxSee Clarification Order, at para. 8.(#i LECs are not required to file tariffs for the basic payphone line for smart and  Y-dumb payphones with the Commission.hk' xP& -ԍXxReconsideration Order, at paras. 162163.(#h As stated in the Clarification Order, LECs are required to file federal tariffs for payphonespecific, networkbased features and functions "only if the LEC provides them separately and on an unbundled basis from the basic  YH-payphone line, either to its payphone operations or to others . . . ."`lHx' xPq-ԍXxClarification Order, at para. 18.(#`  Y -x+44.` ` U S WEST represents that all underlying basic services are currently or will  Y -be available to unaffiliated PSPs under tariff, catalog, or price list.Zm ' xP-ԍXxU S WEST Payphone CEI Plan at 11.(#Z 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  YK-offering its coin line service to the public during the testing period.BnK' xP-ԍXxId.(#B  Y-x,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  Y-it will offer in conjunction with its COCOT service.ho ( ' xP -ԍXxSee U S WEST Payphone CEI Plan at Exh. B; Erratum to U S WEST, Inc's Comparably Efficient Interconnection Plan for Payphone Services (filed Jan. 8, 1997), Exh. B. As to one of the unbundled features, international blocking, U S WEST relies on an existing FCC tariff. U S WEST Payphone CEI Plan Exh. B.(#h U S WEST also submitted sample state tariffs for the COCOT service. "o0*%%[["Ԍ Y-x-46. ` ` APCC contends that the CEI plan must be rejected because U S WEST did not  Y-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  Y-payphones.Lp' xP-ԍXxAPCC Comments at 5.(#L APCC argues that all basic payphone services and features other than the  Y-access line must be federally tariffed.BqX' xP-ԍXxId.(#B 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.  Y1-x.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  Y -features used by a BOC's operations to provide payphone service.Vr ' xP-ԍXxU S WEST Reply Comments at 8.(#V 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  Y-COCOT service.Jsx' xP-ԍXxId. at 89.(#J  Yb-x/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  Y-payphones currently installed in those areas.Lt' xP-ԍXxAPCC Comments at 9.(#L 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  Y-availability in its tariffs.Lu' xP!-ԍXxAT&T Comments at 2.(#L APA maintains that the CEI plan must address how U S WEST will allocate central office facilities between its own payphone operations and independent"( u0*%%[["  Y-payphone operators if there is a scarcity of such facilities.Kv' xPy-ԍXxAPA Comments at 9.(#K U S WEST responds that where coin line service is not available, U S WEST will provide COCOT service to payphone  Y-service providers, including U S WEST's payphone operations.\wX' xP-ԍXxU S WEST Reply Comments at 5 n. 13.(#\ U S WEST states that it will allocate facilities on a "firstcomefirstserved" basis for the types of services that it  Y-provides its customers.Ix' xP= -ԍXxId. at 14.(#I  Yv-x049. ` ` APCC further contends that the CEI plan is incomplete because U S WEST  Y_-only filed illustrative or sample tariffs which, in some cases, did not include prices.Ly_x' xP -ԍXxAPCC Comments at 6.(#L In response, U S WEST argues that filing representative samples is consistent with past practice  Y1-and is all that is required.Vz1' xP-ԍXxU S WEST Reply Comments at 9.(#V  Y -x150. ` ` We find that the plan complies with the CEI availability requirement.{ ' xPL-ԍXxWe note that our conclusion that US WEST's CEI plan complies with the CEI availability requirement, and therefore our approval of its CEI plan, is contingent on the effectiveness of U S WEST's state tariffs for payphone services. We note further that, because we are relying on the states to review LEC tariffs for basic payphone services, our conclusion that U S WEST has satisfied the CEI availability requirement does not represent a determination that U S WEST's basic payphone services  xP4-are tariffed in accordance with the requirements of section 276. See also infra at Section IV.D.2. (#Ư 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  Y -stated in the Clarification Order, BOCs need only submit federal tariffs for payphonespecific, networkbased features and functions if the BOC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to  Yy-others.|@y' xP:-ԍXxClarification Order, at para. 18. The Clarification Order also granted LECs a limited waiver of the federal tariffing requirement to the extent that a BOC was using or offering an unbundled feature for which it had filed a state tariff but not a federal tariff. That order required BOCs to advise the Commission by April 10, 1997, on the status of any such state tariffs and to commit to filing any  xPZ"-necessary federal tariffs. Clarification Order, at paras. 1822. U S WEST advised the Commission that it was in full compliance with the federal tariffing requirement and thus did not need a waiver in order to receive compensation pursuant to the payphone orders. Letter from BB Nugent, Exec. Dir. Federal Regulatory, to William F. Caton, Acting Secretary, Federal Communications Commission,"${0*%%$" April 10, 1997. (#Ƴ Because U S WEST will use, and offer, the features and functions of the Smart"yX|0*%%[[J" 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  Y-illustrative tariffs are sufficient.E}XX' xP-ԍXxSee Phase I Order, at 1055, para. 190 ("The CEI Plan must also include sample state and federal tariffs for the Basic Interconnection Charge and the distancesensitive transmission charges that satisfy our CEI pricing requirements") (emphasis added).(#E  Y_-x251. ` ` 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  Y -existing central office facilities and special operator equipped locations.[~ x' xP-ԍXxU S WEST Reply Comments at Exh. B.(#[ 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 firstcome, firstserved basis.  Y-x 352. ` ` Finally we grant U S WEST's request not to enforce the 90day 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  Ye-years.Ze' xP#-ԍXxU S WEST Payphone CEI Plan at 11.(#Z 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"70*%%[[=" 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  Y-capability is available to USWPS.B' xP-ԍXxId.(#B x  Xv-x 8.` ` Minimization of Transport Costs  YH-x453.` ` This requirement obligates carriers to provide competitors with interconnection  Y1-facilities that minimize transport costs.1X' xP: -ԍxPayphone Order, at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.164. U S WEST states that its payphone operations utilize the same tariffed services as independent PSPs and, therefore, no differences in  Y -transmission costs exist.Z ' xP-ԍXxU S WEST Payphone CEI Plan at 12.(#Z We find that U S WEST's CEI plan complies with the minimization of transport costs requirement.  X -x 9.` ` Recipients of CEI  Y-x554. ` ` This requirement prohibits a BOC from restricting the availability of its CEI  Yy-offering to any particular class of customer or PSP.yx' xP-ԍxPayphone Order, at paras. 20203; Phase I Order, 104 FCC 2d at 1042, para.165.  YK-x655. ` ` U S WEST avers that USWPS and the independent PSPs will obtain "access to  Y4-the same tariffed services."Z4' xP-ԍXxU S WEST Payphone CEI Plan at 12.(#Z We find that U S WEST has proposed to provide service to CEI recipients in compliance with the Commission's requirements.  X- B.xOther Nonstructural Safeguards   Y-  Y-x756. ` ` In addition to the CEI requirements established in Computer III, and applied to  Y-BOC provision of payphone services in the Payphone Order,' xP!-ԍxPayphone Order, at para. 202. See also, Reconsideration Order, at para. 210. a BOC that provides payphone services must comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination"|( 0*%%[["  Y-reporting.g' xPy-ԍxPhase II Order, 2 FCC Rcd at 3082, paras.7375.g  X-x 1.` ` Customer Proprietary Network Information  Y-x857. ` ` The Payphone Order requires U S WEST to explain how it will comply with  Y-the ComputerIII CPNI safeguards,nX' xP-ԍxSee Phase II Order, 2 FCC Rcd at 3095, para.156.n to the extent they are not inconsistent with section 222  Yv-of the Communications Act, as amended.v' xP -ԍxPayphone Order, at para. 205 (citing 47 U.S.C.  222 and the CPNI NPRM). Although the requirements of section 222 became effective immediately upon enactment, the Commission has initiated a proceeding to consider regulations interpreting and specifying in more detail a telecommunications carrier's  Y1-obligations under this provision.V1x' xPZ-ԍxCPNI NPRM, 11 FCC Rcd at 12514.V The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they  Y -do not conflict with section 222. ' xP-ԍXxId. at 12515. (noting that, to the extent that the 1996 Act requires more of a carrier, or imposes greater restrictions on a carrier's use of CPNI, the statute governs).(#  Y -x958. ` ` In its CEI plan, U S WEST represents that it will not disclose the CPNI of an  Y -unaffiliated payphone service provider to USWPS (or any other PSP) without the express  Y -authorization of that unaffiliated PSP.  ` ' xP-ԍXxU S WEST Payphone CEI Plan at 15. U S WEST there represents that "CPNI related to the basic payphone services to which [a PSP] or [USWPS] subscribes will not be available or accessible by any other payphone service provider absent affirmative direction otherwise by the subscribing payphone  xP-service provider." Id.(#Ǝ U S WEST represents that its procedures comply with the Commission's current rules governing the use of CPNI to support enhanced  Yy-services.ByH ' xPr-ԍXxId.(#B  YK-x:59. ` ` APCC and Telco claim that U S WEST's payphone CEI plan does not offer  Y4-sufficient information concerning how it will comply with CPNI requirements.X4' xP"-ԍXxAPCC Comments at 2426; Telco Comments at 3 (arguing that U S WEST's commitment to withhold CPNI absent authorization is too vague to satisfy the Commission's requirement to explain how it will comply with CPNI requirements).(# APCC"40*%%[[)" 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  Y-semipublic payphone customers.Q@' xPK-ԍXxAPCC Comments at 24. See also Letter from Michael S. Wroblewski, on behalf of Peoples Telephone Company, Inc., to William S. Caton, Acting Secretary, Federal Communications Commission, dated  xP-March 5, 1997 (Peoples's March 5 Ex Parte). U S WEST states that, before passage of the 1996 Telecommunications Act, semipublic service consisted of the tariffed provision of a regulated line and  xPk-payphone equipment from U S WEST's payphone division, USWPS, to an end user, i.e., the location provider. U S WEST Reply Comments at 18. U S WEST acknowledges that this service offering generated enduser CPNI, as APCC notes, and that USWPS was entitled to and did access this CPNI.  xP -Id. at 18. (#Q APCC argues that, since the existing tariffed semipublic 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 semipublic service end users than any other  Y-PSP.P' xP-ԍXxAPCC Comments at 2425.(#P APCC also contends that the deregulation of semipublic service presents PSPs with a potential marketing opportunity to replace U S WEST as the payphone service provider for these customers. APCC argues that semipublic 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  Y -payphone operations.L ` ' xP-ԍXxId. at 2526.(#L  Y -x;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  YK-its network group."LK ' xP-ԍXxAPA Comments at 14.(#L  Y-x<61. ` ` U S WEST responds that it will treat the CPNI of independent payphone  Y-providers as restricted from USWPS personnel.^ ' xP7"-ԍXxU S WEST Reply Comments at 16, n. 44.(#^ 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"0*%%[["  Y-sections 222(a) and (b) of the Telecommunications Act.J' xPy-ԍXx Id. at 16.(#J 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  Y-be subject to disciplinary action, including dismissal.IX' xP-ԍXxId. at 17.(#I  Yv-x=62. ` ` With respect to semipublic service, U S WEST contends that, with the deregulation of semipublic payphone service, CPNI associated with semipublic service will  YH-become proprietary. Thus, unaffiliated payphone providers will have no right to it.LH' xP -ԍXxId. at 1920.(#L U S WEST also maintains that APCC's request that U S WEST notify its semipublic payphone customers that this service is being deregulated and that the customer may choose another  Y -payphone provider is beyond the scope of this CEI plan review proceeding.N x' xP,-ԍXxId. at 20 n.54.(#N  Y -x>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  Y-"equal access" to "customer information."I' xPI-ԍXxId. at 21.(#I 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 thirdparty use. U S WEST argues, moreover, that to the extent "account information is not CPNI . . . but commercial proprietary information  Y4-of USWPS, such information need not be disclosed by USWPS to its competitors."W4' xP}-ԍXxU S WEST Reply Comments at 21.(#W  Y-x?64. ` ` In providing payphone services, U S WEST must comply with the  Y-Commission's preexisting Computer III CPNI requirements to the extent that they are consistent with section 222 of the Communications Act, as amended, and any regulations adopted by the Commission pursuant to section 222. 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 semipublic payphones. Issues relating to the interpretation of"e( 0*%%[["  Y-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  Y-for semipublic payphone service, because no such requirement was adopted in the Payphone  Y-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.  X - x2.` ` Network Information Disclosure (#`  Y -x@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  Y -interconnection of payphone services with the network.\ ' xP -ԍXxPayphone Order, at para. 206.(#\ 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  Yb-interface.bX' xPk-ԍx#c P7 P#Phase II Order, 2 FCC Rcd at 3086, para. 102. 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  Y4-nondisclosure agreement.4' xP-ԍx#c P7 P#Id. at 30913093, paras. 134140. U S WEST also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that  Y-service. x' xP/-ԍXx#c P7 P#Id. at 3092, para. 136. We note that, under the Commission's rules, if a BOC is able to introduce the service within twelve months of the make/buy point, however, it may make public disclosure at the make/buy point. It may not, however, introduce the service earlier than six months after the public disclosure.(#Ɵ  Y-xA66. ` ` 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  Y-deregulatory requirements of that order.\` ' xP#-ԍXxPayphone Order, at para. 146.(#\ Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no"| 0*%%[["  Y-later than January 15, 1997.L' xPy-ԍXxSee id.(#L  Y-xB67. ` ` 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.  Y-U S WEST states that it has procedures in place to comply with these rules.ZX' xP-ԍXxU S WEST Payphone CEI Plan at 14.(#Z 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.  X1-x 3.` ` Nondiscrimination Reporting  Y -xC68.` ` In the Payphone Order, we directed the BOCs to comply with the Computer  Y -III and ONA requirements regarding nondiscrimination in the quality of service, installation,  Y -and maintenance.T ' xPn-ԍxPayphone Order, at para. 207.T Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semiannual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of  Yy-covered service offerings, installation and maintenance.Fxyx' xP-ԍXxSee Payphone Order at para. 207; BOC ONA Reconsideration Order, 5 FCC Rcd 3084, 3096,  xPj-Appendix B (1990), BOC ONA Amendment Order, 5 FCC Rcd 3103 (1990), Erratum, 5 FCC Rcd  xP2-4045, pets. for review denied, California II, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 7646  xP-(1991), BOC ONA Second Further Amendment Order, 8 FCC Rcd 2606 (1993), pet. for review  xP-denied, California II, 4 F.3d 1505 (9th Cir. 1993); Phase II Order, 2 FCC Rcd at 3082, para.73; and  xP-Filing and Review of Open Network Architecture Plans, CC Docket No. 882, Memorandum Opinion and Order, Phase I, 6 FCC Rcd 7646, 764950 (1991).(#F  YK-xD69.` ` 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  Y-services used by U S WEST's payphone operations and for all others.Z ' xP*$-ԍXxU S WEST Payphone CEI Plan at 14.(#Z U S WEST's plan"H 0*%%[[" provides that this information will be separately identified in a report that will be filed for all  Y-CEI services. U S WEST submitted a sample report._' xPb-ԍxErratum to U S WEST Payphone CEI Plan, Exh. C._ We find that U S WEST's CEI plan comports with the Commission's nondiscrimination reporting requirements.  X- C.xAccounting Safeguards   Yv-xE70.` ` In the Payphone Order and the Accounting Safeguards Order, the Commission  Y_-concluded that it should apply accounting safeguards identical to those adopted in Computer  YH-III to BOCs providing payphone service on an integrated basis.HX' xPQ -ԍxPayphone Order, at paras. 157,199, 201; Accounting Safeguards Order, at para. 100. 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 onsite audits by  YK-Commission staff.K' xP-ԍx#c P7 P#BOC Safeguards Order, 6 FCC Rcd at 7591, para. 46. 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.  X- D.xOther Issues   X-x 1.` ` Sufficiency  Y-xF71.` ` 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  YN-refile its plan.jNx' xPw"-ԍx APCC Comments at 13; APA Comments at 45; Telco at 23.j As discussed above, however, we find that U S WEST adequately complies  Y7-with each of the required parameters.@ " 0*%%[[<"Ԍ X-x 2. ` ` Tariffing Issues  Y-xG72. ` ` APCC and APA raise various objections to the content of U S WEST's state  Y-and federal tariffs.m' xP4-ԍXxSee APCC Comments at 89; APA Comments at 15. (#m 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  Y-proceeding.[X' xP-ԍXxU S WEST Reply Comments at 910. (#[ It argues that the Commission has delegated to the states the responsibility for  Yv-reviewing U S WEST's coin line tariffs.Bv' xP -ԍXxId.(#B Similarly, U S WEST argues that issues concerning the pricing of the federally tariffed services must be raised in the context of those  YH-tariff proceedings.NHx' xPq-ԍXxId. at 9 n. 21.(#N  Y -xH73. ` ` 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  Y -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  Y -the requirements of section 276."Z ' xPw-ԍxReconsideration Order at para. 163.Z That order required that the tariffs for these LEC services must be: (1) cost based; (2) consistent with the requirements of section 276 with regard, for example, to the removal of subsidies from exchange and exchange access  Yy-services; and (3) nondiscriminatory.y' xP-ԍXxReconsideration Order at para. 163; see also Id. at n.492 (noting that the "new services test required in  xP-the Report and Order is described at 47 C.F.R. Section 61.49(g)(2)").(# In addition, the order established that "[s]tates must  Yb-apply these requirements and the Computer III guidelines for tariffing such intrastate  YK-services.":K ' xP-ԍxId.: The order further stated that "[w]here LECs have already filed intrastate tariffs  Y4-for these services, states may, after considering the requirements of this order, the Report  Y-and Order, and section 276 conclude: 1) that existing tariffs are consistent with the  Y-requirements of the Report and Order as revised herein; and 2) that in such case no further  Y-filings are required.": ' xP #-ԍxId.: 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" 0*%%[["  Y-Commission.":' xPy-ԍxId.: 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  Y-has filed a petition challenging U S WEST's rates.X' xP-ԍXxPetition of the American Public Communications Counsel to Suspend and Investigate, Proposed Tariff Revisions U S WEST Communications, Inc.Transmittal No. 823, filed Feb. 10, 1997.(#  X-x 3.` ` Screening Codes  Yv-xI74.` ` APCC, MCI and APA contend that U S WEST is required, pursuant to the  Y_-Reconsideration Order, to provide PSPs using COCOT lines with screening code digits that  YH-uniquely identify their lines as payphone lines.~H' xP -ԍxAPCC Comments at 1921; MCI Comments at 12; APA Ex Parte at 34.~ 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 percall compensation from IXCs. In addition, MCI maintains that U S WEST does not provide screening code digits that can be "transmitted by  Y -PSPs for all access methods and from all locations."  @' xP-ԍXxMCI Comments at 3. MCI maintains that, for example, LECs "do not provide automatic number identification or information digits with feature group B access and from nonequal access areas." Accordingly, argues MCI, "PSPs would not be able to transmit specific payphone coding digits from  xP-payphones in these circumstances and, therefore, they would not be eligible for compensation." Id.(#  Y-xJ75. ` ` U S WEST responds that it will provide screening codes in a  Yy-nondiscriminatory fashion.Wy( ' xPR-ԍXxU S WEST Reply Comments at 23.(#W 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  Y-Line Information Database (LIDB) query.B ' xP -ԍXxId.(#B U S WEST contends that its use of the LIDB  Y-solution, i.e., the IXC making a LIDB query, satisfies the Commission's requirements.LH ' xP"-ԍXxId. at 2324.(#L  Y-xK76.` ` We find that the issue of whether U S WEST is providing screening"!0*%%[[" 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  Y-raised in that proceeding or in other proceedings.@' xPK-ԍxSee e.g., Policy and Rules Concerning Operator Service Access and Pay Telephone Compensation, CC Docket No. 9135, CCB/CPD File Nos. 9618, 9625, and 9632, Memorandum Opinion and Order, DA 962169 (rel. Dec. 20, 1996), p. 2 n. 7 (citing MCI petition for clarification of LECs' obligation to provide screening code digits and stating that MCI's petition would be addressed in a subsequent order). We note that  xPk-in its Reconsideration Order, the Commission stated that, once percall compensation becomes effective, "[e]ach payphone must transmit coding digits that specifically identify it as a payphone, and not merely as a restricted  xP-line." Reconsideration Order, at para. 64. That order further required that "all LECs must make available to  xP -PSPs, on a tariffed basis, such coding digits as part of the ANI for each payphone." Id.    X-x 4.` ` Numbering Assignments  Yv-xL77.` ` According to APCC, the Payphone Order requires LECs to assign line  Y_-numbers to payphones on a nondiscriminatory basis.g_' xP-ԍxAPCC at 18 (citing Payphone Order at para. 149).g 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  Y -and 9000 series numbers.!X ` ' xP+-ԍXxId. at 1819. APCC states that assignment of numbers in the 8000 to 9000 range provides a distinct advantage in the prevention of fraud by alerting overseas operators to refrain from completing collect calls to such 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  Y -8000 or 9000 series number, U S WEST will reassign another 8000 or 9000 number, subject  Y -to availability, upon request at the tariffed rate for a number change.Z ' xP-ԍXxU S WEST Reply Comments at 2223.(#Z  Y-xM78.` ` 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  Yb-reallocate existing number assignments.\b' xP# -ԍXxPayphone Order, at para. 149.(#\ 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. ""0*%%[["Ԍ X-x 5.` ` Dialing Parity  Y-xN79.` ` MCI asserts that U S WEST also does not explain how it will comply with the  Y-dialing parity requirement in the Payphone Order, including access to operator service,  Y-directory assistance, and directory listings.F' xP-ԍxMCI Comments at 23.F U S WEST contends that this is not a CEI  Y-issue.WX' xP-ԍXxU S WEST Reply Comments at 29.(#W  Y_-xO80.` ` 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  Y1-extend to all payphone location providers.T1' xP -ԍxPayphone Order, at para. 292.T The Commission stated that such dialing parity for payphones should be implemented at the same time as dialing parity for other  Y -telephones.: x' xP,-ԍxId.: 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  Y -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  Y-payphone services.W' xPI-ԍxPayphone Order, at para. 20304.W 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.  XK-x 6.` ` Uncollectibles  Y-xP81. ` ` 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  Y-accorded to nonaffiliates.N' xP! -ԍXxAT&T Comments at 34.(#N U S WEST responds that there will be no crosssubsidization or  Y-discrimination in the way U S WEST treats uncollectibles.W( ' xP"-ԍXxU S WEST Reply Comments at 29.(#W U S WEST represents that"# 0*%%[["  Y-USWPS pays (and will continue to pay) all toll and access line billing from U S WEST.' xPy-ԍXxId. APA contends that U S WEST's plan is insufficient because it does not address the "walkaway" fraud problem which occurs when a payphone user completes a call without paying for additional time. U S WEST responds that all fraud, including "walk away" fraud is the responsibility of the payphone provider, whether it is USWPS or an unaffiliated PSP. U S WEST Reply Comments at 29. We find that this issue is beyond the scope of our CEI plan review.(#  Y-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.  X_- x7.` ` Operator Services  Y1-xQ82. ` ` APCC contends that U S WEST's CEI plan fails to address whether U S  Y -WEST's intraLATA operator services are part of its deregulated payphone services.H x' xPC-ԍxAPCC Comments at 2223.H 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  Y -its payphone operations and unaffiliated PSPs in the provision of operator services.I ' xP-ԍXxId. at 23.(#I 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 "F  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  YK-nonaffiliated PSPs on a nondiscriminatory basis.OK' xP-ԍxU S WEST Reply Comments at 28.O U S WEST also represents that its accounting for payphone operations ensures that there will be no crosssubsidization. It represents that the coin line rate includes the cost of these operator services, and that  Y-USWPS will take those services at the tariffed rates.B( ' xP-ԍXxId.(#B We conclude that U S WEST has  Y-sufficiently addressed the concerns raised by APCC. We note that, in the Reconsideration  Y-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"$ 0*%%[[" beyond the scope of section 276 and the"$ 0*%%[["  Y-Payphone proceeding.Z' xPy-ԍxReconsideration Order, at para. 52.Z  X- x8.` ` Inmate Calling Services Issues  Y-xR83.` ` 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  Y_-operations will provide to USWPS's provision of ICS.K_X' xPh -ԍxICSPC Comments at 23, 11.K 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  Y -of called numbers.R ' xP-ԍxId. at 1012, 1416, 1718.R 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  Y -U S WEST has complied with the requirements of section 276.@ x' xP-ԍxId. at 3.@ 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.  Yy-xS84.` ` ICSPC also asserts that U S WEST must show that call processing and call  Yb-control systems used in USWPS's provision of ICS have been deregulated.@b' xP-ԍxId. at 9.@ 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  Y-collocation to other providers.A' xPf-ԍxId. at 18.A 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  Y-wish.A( ' xP!-ԍxId. at 19.A "% 0*%%[["Ԍ Y-xT85.` ` In a subsequent ex parte filing,' xPy-ԍXxSee Letter from Albert H. Kramer and Robert F. Aldrich, attorneys for ICSPS, to William F. Caton, Acting Secretary, Federal Communications Commission, (Mar. 19, 1997). (# ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations  Y-because collect calling is fundamental to ICS.J ' xP-ԍXxId. at 12.(#J According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its networkbased operator services division for processing and that division assumes the responsibility and risk associated with billing and collecting for those calls, then the BOC is essentially providing ICS as a regulated service  Yv-and is still subsidizing that service contrary to the prohibition in section 276.Hv' xP -ԍXxId. at 2.(#H  YH-xU86.` ` In response, U S WEST represents that, although it identified ICS as one of  Y1-the payphone services that it offers,Y1@' xP"-ԍXxU S WEST Payphone CEI Plan at 4.(#Y 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 callcontrol functions, is classified as deregulated facilities and no such equipment is collocated in U S  Y -WEST's central offices.W ' xP?-ԍXxU S WEST Reply Comments at 22.(#W 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  Yb-providers of inmate calling services.Bb` ' xPs-ԍXxId.(#B 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  Y4-operator services to complete collect calls.\4 ' xP-ԍXxU S WEST ex parte at 5.(#\ U S WEST represents that it will similarly assume the risk for uncollectibles for unaffiliated ICS providers that utilize U S WEST's  Y-operator services to complete collect calls. B ' xP7"-ԍXxId.(#B According to U S WEST, it "assumes the uncollectible risk" by incorporating that risk into the amount of commissions it pays to"&0*%%[["  Y-USWPS or independent providers that use U S WEST operator services.B' xPy-ԍXxId.(#B  Y-xV87.` ` Section 276 specifically defines payphone service to include the provision of  Y-inmate telephone service in correctional institutions.GX' xP-ԍx47 U.S.C.  276(d).G In the Reconsideration Order, we  Y-clarified that the requirements of the Payphone Order apply to inmate payphones that were  Y-deregulated in an earlier order. ' xP& -ԍXxReconsideration Order, at para. 131 (citing Petition for Declaratory Ruling by the Inmate Calling  xP -Services Providers Task Force, Declaratory Ruling, 11 FCC Rcd 7362, 7373 (rel. Feb. 20, 1996)  xP -(Inmate Service Order); Petitions for Waiver and Partial Reconsideration or Stay of InmateOnly  xP~ -Payphones Declaratory Ruling, Order, 11 FCC Rcd 8013 (Com. Car. Bur. 1996)).(# 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  YH-to provide the ICS, and the operator service facilities used to support the ICS.dH' xP-ԍxSee Payphone Order, at paras. 157, 159.d In addition, U S WEST is required to offer on a tariffed basis any basic payphone service or network  Y -feature used by its payphone operations to provide ICS. ` ' xP+-ԍxSee Payphone Order, at paras. 14649; Reconsideration Order, at paras. 16263.  Y -xW88.` ` 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  Y -that provides timing, PIN, and other callcontrol functions.R ' xPH-ԍxU S WEST Payphone CEI Plan at 22.R Additionally, USWPS will purchase the same tariffed network services, coin line or COCOT, to provide ICS as are  Yy-available to all PSPs.Qy ' xP-ԍxU S WEST Reply Comments at 22. Q U S WEST also has represented that its call control equipment is  Yb-not collocated at its central offices.Bb' xP# -ԍXxId.(#B We find no support in the Payphone Order or  YK-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.  Y-xX89. ` ` 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"'0*%%[[" 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.  YH- x 9 . ` ` Primary Interexchange Carrier Selection  Y2-  Y -xY90.` ` 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  Y -concerning the payphone PIC selection process.$ ' xPf -ԍXxOncor Comments at 5. According to Oncor, U S WEST must describe how it will manage the payphone PIC selection and order implementation process. In addition, Oncor states that U S WEST should describe how it will ensure that all PIC orders obtained pursuant to USWPS's agreements with location owners will be handled on a nondiscriminatory basis, and that all valid PIC orders and location provider agreements will be honored and will not be subject to interference by U S WEST or anyone else. Further, Oncor states that U S WEST should describe how its marketing personnel will be trained and supervised to ensure that they do not misrepresent U S WEST's role in the payphone PIC selection process. Finally, Oncor asserts that U S WEST should describe how its personnel involved in the PIC ordering and implementation processes will be trained and supervised to ensure that they do not  xPn-"interfere" with the sales and marketing of interexchange services from payphones. Id.(#$ 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  Y -payphones will be performed on a nondiscriminatory basis.D ` ' xP-ԍxAT&T Comments at 4.D 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  Yz-obligations toward payphone providers.Oz ' xP-ԍxU S WEST Reply Comments at 26.O  YL-xZ91.` ` 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  Y-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  Y-offer and how it will unbundle those basic payphone services.W ' xP!#-ԍxPayphone Order, at para. 20304.W The payphone rulemaking proceeding, however, did not require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as argued by AT&T and Oncor. Therefore, arguments"(0*%%[[" raised by parties regarding U S WEST's role as PIC administrator are beyond the scope of this proceeding.  X-x 10.` ` Call Rating  Y-x[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  YH-overtime periods. H' xP -ԍXxAPCC Comments at 1013. APCC argues that, permitting U S WEST to offer a coin line service that forces its subscribers to price payphone calls at U S WEST's set rates would be contrary to the purpose of Section 276 of promoting payphone competition, and would permit U S WEST to discriminate in favor of its payphone division. APCC Comments at 1113.(#Ɵ 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  Y -five minutes.S ' xP{-ԍXxAPCC Comments at ll, n. 8.(#S APCC therefore requests the Commission to require U S WEST to develop a  Y -more flexible rating feature for its coin line service.H @' xP-ԍxAPCC Comments at 1112.H U S WEST responds that APCC's call rating request is beyond the scope of this proceeding and states that the Commission  Y -considered and rejected the same request in the payphone proceeding.X ' xPV-ԍXxU S WEST Reply Comments at 56.(#X We agree. The  Y -Payphone Order did not require the BOCs to provide to unaffiliated PSPs an unbundled call  Y -rating feature for coin line services. ` ' xP-ԍxPayphone Order, at paras. 14648. See also, Reconsideration Order, at para. 165. In addition, on reconsideration of the Payphone  Y-Order, in response to a request that the Commission require access to, inter alia, call rating  Yy-capabilities,rXy ' xP-ԍXxOn reconsideration, the New Jersey Payphone Association requested that the Commission require access to call rating capabilities, answer supervision, call tracking, joint marketing, installation and  xP-maintenance, and billing and collection. See Reconsideration Order, at para. 155.(#r the Commission specifically declined to require further unbundling of  Yb-payphone services beyond those established in the Payphone Order.ab' xP# -ԍxReconsideration Order, at para. 165.a As previously noted, independent PSPs may seek additional unbundling through the 120day ONA process. The appropriate state regulatory authorities may also impose further unbundling requirements. ")0*%%[["Ԍ X-x 11.` ` Selection of Operator Services Provider  Y-x\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 thirdparty operator  Y-service provider for intraLATA calls.J' xP-ԍxAPCC Comments at 1314. J APCC argues that, under section 276, PSPs are entitled to select the operator service provider (OSP) for intraLATA calls, including local, operatorassisted calls, and therefore that, to the extent U S WEST does not permit OSP  Y_-selection for its coin line service, its CEI plan is inconsistent with section 276.:_X' xPh -ԍxId.: 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  Y -the scope of the CEI proceeding.X ' xP-ԍXxU S WEST Reply Comments at 56.(#X 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  Y -CEI plan complies with the Commission's Computer III CEI requirements.  X -x 12.` ` Millenn ium Payphones  Y-x]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  Y-equal access to such features. x' xP/-ԍXxAPA Comments at 9. APA also questions whether U S WEST is providing a special data line for the Millennium payphone but refuses to make such a data line available to other PSPs. APA Comments at 11. U S WEST denies this allegation and states that the Millennium uses the same lines available to other PSPs. U S WEST Reply Comments at 15. (#Ə U S WEST responds that the "network control center" (NCC) that provides the functionality for the Millennium is CPE, not network equipment,  Y-and that unaffiliated PSPs have no right to obtain access to U S WEST's deregulated CPE.]` ' xP -ԍXxU S WEST Reply Comments at 15 n. 41.(#]  Y-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"|* 0*%%[[" represents that the NCC is a separate, standalone, computerbased system that is not part of  Y-the public switched network or Digipac.V' xPb-ԍXxU S WEST ex parte at 1.(#V We conclude that U S WEST has adequately addressed questions concerning the Millennium payphone.   X- x13.` ` Interim Compensation Scheme  Yv-x^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  YH-participate in the interim compensation scheme outlined in the Payphone Order.GHX' xPQ -ԍxTelco Comments at 47.G We find that this argument is beyond the scope of this CEI proceeding. Moreover, the interim  Y -compensation rules were addressed at length in the payphone rulemaking proceeding. ' xP-ԍXxSee e.g., Reconsideration Order, at para. 11415 (describing the interim compensation mechanism  xP{-adopted in the Payphone Order).(#  X -x 14. ` ` Miscellaneous Other Issues  Y -x_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  Y-agents to provide payphone services.O@' xP-ԍXxAPA Comments at 1819.(#O 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  Yb-commissions.Ob' xP-ԍXxAPA Comments at 1112.(#O 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  Y4-fee to location owners or unaffiliated PSPs.I4` ' xPE-ԍXxId. at 19.(#I We find that these issues are beyond the scope of this proceeding.  Y-x`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  Y-goods and services must be documented in written agreements.I ' xPK$-ԍXxId. at 18.(#I U S WEST responds that"+ 0*%%[["  Y-APA's proposal is unnecessary for integrated operations and that the Accounting Safeguards  Y-Order addresses the proper accounting of transactions involving U S WEST's payphone  Y-operations.W' xPK-ԍXxU S WEST Reply Comments at 26.(#W 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.  Yv-xa98. ` ` Finally, APCC maintains that, to the extent that U S WEST's payphone operation continues to offer "semipubliclike" 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  Y -will be treated on the subscriber's bill.P X' xP# -ԍXxAPCC Comments at 2627.(#P We find these semipublic service issues to be beyond the scope of the CEI review process. x  Y - V. CONCLUSION ׃  Y -xb99.` ` 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. "L,0*%%[["  Y-= VI. ORDERING CLAUSE ׃  Y- xc100.` ` 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. x` `  hh@Federal Communications Commission x` `  hh@A. Richard Metzger, Jr. x` `  hh@Deputy Chief, Common Carrier Bureau