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M E M O R A N D U M ă r  y<N dddy   INVOICE EXPSEExpense Subtotals for Math Invoice:A ,p, $0$00INVOICE TOTTotals Invoice for Math Macroz 4p, $0$00INVOICE HEADRHeading Portion of Math Invoice+C`*   4X 99L$0 **(  ӧ XX 2[[[c[SMALLSmall TypestyleFINEFine TypestyleLARGELarge TypestyleEXTRA LARGEExtra Large Typestyle2i[K)ɹVERY LARGEVery Large TypestyleENVELOPEStandard Business Envelope with Header+w ,,EnvelopeZ K e VE L"n,,EnvelopeLarge, Italicized and Under;    ,, 88+  `   Style 14Swiss 8 Pt Without Margins$$D Co> PfQ  )a [ PfQO Style 12Dutch Italics 11.5$$F )^ `> XifQ  )a [ PfQO 2lzStyle 11Initial Codes for Advanced IIJ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 ! )^ `> XifQ ` Advanced Legal WordPerfect II Learning Guide   x )^ `> XifQ Advanced Legal WordPerfect II Learning Guide   j-n )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  jBX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 3oDutch Roman 11.5 with Margins/Tabs )a [ PfQO  ddn  # c0*b, oT9 !Style 4 PSwiss 8 Point with MarginsDq Co> PfQ  dddd  #  Style 1.5Dutch Roman 11.5 Font4h )a [ PfQO  dddn 2|@\Style 2Dutch Italic 11.5$ )^ `> XifQ Style 5Dutch Bold 18 Point$RH$L T~> pfQ_  )a [ PfQO Style 7Swiss 11.5$$V )ao> PfQ ]  )a [ PfQO Style 6Dutch Roman 14 Point$$N w [ PfQ   )a [ PfQO 2Style 10oInitial Codes for AdvancedƯ U )a [ PfQK  dddn  ##  [[ b, oT9 !b, oT9 !n )^ `> XifQ ` Advanced Legal WordPerfect Learning Guide   f )^ `> XifQ Advanced Legal WordPerfect Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  QN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 8PfInitial Codes for Beginninggǯi )a [ PfQK  dddn  # X` hp x (#%'b, oT9  [ &e )^ `> XifQ ` Beginning Legal WordPerfect Learning Guide   d )^ `> XifQ Beginning Legal WordPerfect Learning Guide   jH )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`6 >Page  j )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 Style 9Initial Codes for Intermediateȭ )a [ PfQK  dddn  # X` hp x (#%'b, oT9 Њ [ e )^ `> XifQ ` Intermediate Legal WordPerfect Learning Guide   3 )^ `> XifQ Intermediate Legal WordPerfect Learning Guide   jf )^ `> XifQ    Copyright  Portola Systems, Inc.`+ >Page  jX )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 UpdateInitial Codes for Update Moduleɾ )a [ PfQK  dddn  #  [ X` hp x (#%'b, oT9 !n )^ `> XifQ ` Legal WordPerfect 5.0 Update Class Learning Guide   f )^ `> XifQ Legal WordPerfect 5.0 Update Class Learning Guide   Q" )^ `> XifQ    Copyright  Portola Systems, Inc. 1987, 1988`7 CPage  jN~ )^ `> XifQ    Page ` Copyright  Portola Systems, Inc. 1987, 1988 2d)lxlqBld/UnderlieBold and Underline Text/  Document 8Document 8 Document 4Document 4  Document 6Document 6 2qll{lSDocument 5Document 5 Document 2Document 2 Document 7Document 7 Right Par 1Right Par 1` hp x (#X` hp x (#X` hp x (#` hp x (#2il-KRight Par 2Right Par 2` hp x (#X` hp x (#0X` hp x (#0` hp x (#Document 3Document 3 Right Par 3Right Par 3` hp x (#X` P hp x (#X` P hp x (#` hp x (#Right Par 4Right Par 4` hp x (#X` hp x (#0X` hp x (#0` hp x (#2Right Par 5Right Par 5` hp x (#X` hp x (#X` hp x (#` hp x (#Right Par 6Right Par 6` hp x (#X` hp x (#0X` hp x (#0` hp x (#Right Par 7Right Par 7` hp x (#X` hp x (#X` hp x (#` hp x (#Right Par 8Right Par 8` hp x (#X` hp x (#0X` hp x (#0` hp x (#2!(E$m$lDocument 1Document 1` hp x (#X` hp x (#X` hp x (#` hp x (#Technical 5Technical 5` hp x (#X` hp x (# X` hp x (#` hp x (#Technical 6Technical 6` hp x (#X` hp x (# X` hp x (#` hp x (#Technical 2Technical 2 2slS$l$OTechnical 3Technical 3 Technical 4Technical 4` hp x (#X` hp x (# X` hp x (#` hp x (#Technical 1Technical 1 Technical 7Technical 7` hp x (#X` hp x (# X` hp x (#` hp x (#2g$ITechnical 8Technical 8` hp x (#X` hp x (# X` hp x (#` hp x (#WP Heading 2WP Heading 244#6X@C@##Xv6X@CX@#WP Heading 1WP Heading 144#6X@C@# #Xv6X@CX@#toatoa` hp x (#` hp x (#2}ahead1 #'d#2p}wC@ #para numnumbered indented paragraphs' Y- 1.(i) 1) 1.#Xw P7[hXP# 1. 1.ҲParagraph[1]C^i1. a. i. 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TDS anticipates that such a transaction, if implemented, would be  Xv-completed no later than the end of 1998;3EvM yO/-ԍ Id.3 and if not implemented, TDS asserts that it will  X_-replace Southern Indiana's switch by that date.3F_M yO-ԍ Id.3 TDS asserts that it would be wasteful to spend the more than $1.5 million needed to make the software upgrades to convert these six  X1-LECs to fourdigit CIC capability when TDS plans to replace the switches in 1998.3G1( M yO -ԍ Id.3  X - x15.` ` Home, one of TDS' LEC subsidiaries for which it requests a waiver, does not  X -currently provide equal access.9H M yOU-ԍ Id. at 6.9 TDS acknowledges that Home is not subject to the January  X -1, 1998 conversion deadline, but rather covered by the Commission's proposal, in the CICs  X -Second FNPRM, where the Commission seeks comment on requiring LECs that do not  X -currently provide equal access to provide it.3I H M yO-ԍ Id.3 Nonetheless, TDS requests an indefinite waiver  X-for Home, subject to an order requiring it to upgrade to equal access.3JM yO-ԍ Id.3  Xy-  Xb-xF.` ` Request for Extension of Bruce  X4-x16.` ` Bruce, a small LEC providing equal access in and near the rural community of"4 hJ0*%%ZZ"  X-Bruce, WisconsinKM yOy- xԍ Bruce Petition at 1. Bruce serves one exchange with approximately 1, 635 access lines. Id. Bruce has been  yOA-providing equal access since February 1991. Id. requests an extension of the switch conversion deadline until June 30,  X-1999. Bruce asserts that its exchange is located in, and serves, a lake region.3L M yO-ԍ Id.3 Over the years, Bruce determined that the use of multiple subscriber remotes connected to its host switch constituted the most efficient and economical way for it to deal with the topography  X-and demographics of its exchange area.;MM yO -ԍ Id. at 12.; Bruce asserts that it installed its current host  X-switch, a digital Siemens StrombergCarlson switch, in Bruce in 1982.9N@M yO~ -ԍ Id. at 2.9 Since that time, Bruce has added six subscriber remotes at various locations within the exchange. These  X_-remotes presently serve approximately half of Bruce's 1,635 access lines.9O_M yO-ԍ Id.9 Bruce asserts that it cannot upgrade to accept fourdigit CICs by installing a later software release, because the  X1-later releases cannot accommodate the six remotes.3P1` M yOB-ԍ Id.3 Instead, to become fourdigit CIC compliant, Bruce asserts that it must replace its existing host/remote switching system with a  X -new switch.3Q M yO-ԍ Id.3  X -x17.` ` Bruce asserts that, in 1996, it retained an engineering company, Finley Engineering Company, Inc. (Finley), to prepare a Present Worth of Annual Charge (PWAC) Study, as a preliminary step to seeking Rural Utilities Service (RUS) financing for a new  X-switch.3R M yO-ԍ Id.3 Bruce asserts that Finley delivered the PWAC Study on November 26, 1996. Bruce asserts that in 1997, it has negotiated with potential vendors and evaluated switching options, costs, and financing, a process Bruce asserts that has been more timeconsuming and complicated than expected, given the need to accommodate changing federal and state services  X4-obligations,S4M yO!-ԍ As examples, Bruce cites fourdigit CICs, dialing parity, and number portability. Id. and changing technologies and markets.3T4M yO#-ԍ Id.3 Bruce asserts that it has determined that RUS financing will take too long, and that, in addition to having selected its switching" 0T0*%%ZZ"  X-equipment and vendor, it has nearly completed an alternative financing arrangement.;UM yOy-ԍ Id. at 23.; Bruce  X-asserts that it is ready to negotiate final contractual terms and schedules.9VXM yO-ԍ Id. at 3.9 Bruce believes that it can complete arrangements for the purchase and financing of its new switching system during the first quarter of 1998, and that it can obtain, install, test, adjust, and make the new  X-switching system ready for commercial operation by June 30, 1999.3WM yO= -ԍ Id.3 Bruce asserts that grant of its requested waiver will have a minimal impact on the customers served by its 1,635  Xv-access lines because these customers are presently served by 14 presubscribed IXCs.;XvxM yO -ԍ Id. at 45.; Bruce argues that grant of its waiver request would be consistent with the Commission's policy of  XH-minimizing regulatory burdens on small telephone companies.YHM yO-Ѝ Id. at 67, citing, e.g. Amendment of the Commission's Rules to Establish Competitive Service Safeguards for Local Exchange Carrier Provision of Commercial Mobile Radio Services, Implementation of Section 601(d) of the Telecommunications Act of 1996, WT Docket No. 96-162, FCC 97352 (rel. Oct. 3, 1997);  yOY-Telephone Number Portability, Second Report and Order, CC Docket No. 95116; FCC 97289 (rel. Aug. 18, 1997). In addition, Bruce asserts that grant of its waiver would be consistent with other Bureau decisions granting waivers to LECs  X -who planned to replace their switches.Z  M yO-Ѝ See id. at 56, citing Caller ID Order, 11 FCC Rcd at 1275812759; North State Telephone Company Request for Limited Waiver of Commission Requirements Concerning Implementation of Equal Access in End  yO-Offices Equipped with Stored Program Controlled Switches, Memorandum Opinion and Order, DA 87376, 2 F.C.C.R. 2038 (1987).  X - III. DISCUSSION ă  X -x18.` ` The Commission may waive any provision of its rules, in whole or in part, if  X -good cause is shown.G[ M yO-ԍ See 47 C.F.R.  1.3.G An applicant for waiver must demonstrate that special circumstances warrant a deviation from the general rule and that such deviation will serve the public  Xy-interest.\y0M yOZ"- xԍ Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990); WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969). In the First CICs Waiver Order, we stated the factors we weighed in evaluating each petition for waiver: the LEC's diligence in upgrading its switches; the availability from manufacturers of products required to accomplish the upgrade; and the impact of an extension"K \0*%%ZZ" of the conversion deadline on the IXCs served by the LEC's switches and on customers'  X-ability to reach IXCs through CAC dialing. In the Second CICs Waiver Order, the Third  X-CICs Waiver Order, and again here, we have weighed these same factors in evaluating each petition before us.  X-x A.` ` Grant of Extensions  X_-x19.` ` Requests for Extension of Interstate and Southwest. We find that the joint petition for waiver filed by Interstate and Southwest demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, the petitioners have demonstrated that they are diligently working to upgrade their switches. For example, Interstate is in its final stages of conversion to fourdigit CIC functionality. The new Mitel GX 5000 switches Interstate purchased for each of its three exchanges were delivered in November 1997, but according to the manufacturer, installation will not be complete until shortly after the January 1, 1998 conversion deadline. Southwest's conversion has been delayed because the petitioners were first focusing the jointly owned companies' financial resources on Interstate's conversion. Southwest began working with engineers months ago to meet the January 1, 1998 conversion deadline. Southwest's entire switch conversion process, from purchase, to delivery, to completion of installation, will take Southwest until the end of 1998 to finalize. Second, based the joint petition, we conclude that Interstate and Southwest have demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed the petitioners' ability to meet the January 1, 1998 conversion deadline. The new Mitel GX 5000 switches Interstate purchased for each of its three exchanges were delivered in November 1997, but according to the manufacturer, installation will not be complete until shortly after the January 1, 1998 conversion deadline. Because the manufacturer cannot complete installation by January 1, 1998, the product is effectively "unavailable." We also find that the additional costs that Southwestern would be forced to expend to comply with the January 1, 1998 deadline make the product necessary for conversion effectively "unavailable" for Southwest. Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by Interstate and Southwest, and on the ability of Interstate's and Southwest's customers to reach IXCs through CAC dialing, does not outweigh the burden on Interstate and Southwest that would be imposed by a denial of their joint petition for waiver. Interstate serves a total of only approximately 1,100 access  X -lines,W] M yO -ԍ Interstate and Southwest Petition at 5.W and Southwest serves a total of only approximately 700 access lines.;^ XM yO"-ԍ Id. at 67.; Interstate has requested an extension until February 28, 1998. Accordingly, the grant of its requested waiver will not affect or interfere with the end of the permissive dialing period on June 30, 1998. Because Southwest has requested an extension until December 31, 1998, significantly" ^0*%%ZZ" beyond the end of the permissive dialing period, below, we impose several requirements on  X-Southwest, as a condition to our grant of its extension request.N_M yOb-ԍ See paras. 3031, infra.N  X-x20.` ` Request for Extension of FrontierLakeshore. We find that the petition for waiver filed by FrontierLakeshore demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, FrontierLakeshore has demonstrated that it is diligently working to upgrade its switches. For example, FrontierLakeshore asserts that in June 1997, it had already begun negotiations with Nortel engineers regarding an efficient network solution. It asserts that Frontier Corp. removed FrontierLakeshore from the overall upgrade plan for Frontier Corp.'s affiliates, and attempted to reconfigure the FrontierLakeshore network. After determining that the option of a host/remote configuration would be too costly, Frontier Corp. chose the option of integrating an expedited switch upgrade for FrontierLakeshore with the overall Nortel plan, at an additional cost of over $180,000. FrontierLakeshore asserts that this upgrade will occur by June 30, 1998. Second, based on its petition, we conclude that FrontierLakeshore has demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed its ability to meet the January 1, 1998 conversion deadline. FrontierLakeshore asserts that in light of Nortel's schedule, which has become hectic because of the impending CIC deadline, it can upgrade to fourdigit CIC capability by June 30, 1998. The product, therefore, is effectively "unavailable" to meet the January 1, 1998 deadline. Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by FrontierLakeshore, and on the ability of FrontierLakeshore's customers to reach IXCs through CAC dialing, does not outweigh the burden on FrontierLakeshore that would be imposed by a denial of its  X-petition for waiver. FrontierLakeshore serves only 2,100 access lines.L`XM yO-ԍ FrontierLakeshore Petition.L FrontierLakeshore has requested an extension until June 30, 1998. Accordingly, the grant of its requested waiver will not affect or interfere with the end of the permissive dialing period on June 30, 1998.  X-x21.` ` Request for Extension of Council Grove. We find that the petition for waiver filed by Council Grove demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, Council Grove has demonstrated that it is diligently working to upgrade its switches. Council Grove asserts that it contacted Siemens StrombergCarlson about upgrading its switch in August 1997, but that Siemens StrombergCarlson did not process an upgrade order until November 6, 1997. According to Council Grove, Siemens StrombergCarlson stated that it would begin installation on January 27, 1998, with an expected completion date of February 21, 1998. Second, based on its petition, we conclude that Council Grove has demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed its ability to" `0*%%ZZ" meet the January 1, 1998 conversion deadline. #K   #K Council Grove asserts that Siemens StrombergCarlson is unable to expedite the upgrade installation process. The product necessary for conversion by January 1, 1998, is, therefore, "unavailable." Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by Council Grove, and on the ability of Council Grove's customers to reach IXCs through CAC dialing, does not outweigh the burden on Council Grove that would be imposed by a denial of its petition for waiver. Council Grove serves only 2,099 access lines. Council Grove has requested an extension until June 30, 1998. Accordingly, the grant of its requested waiver will not affect or interfere with the end of the permissive dialing period on June 30, 1998.  X -x22.` ` Request for Extension of TriCounty. We find that the petition for waiver filed by TriCounty demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, TriCounty has demonstrated that it is diligently working to upgrade its switches. For example, all but one of TriCounty's exchanges are already fourdigit CIC compliant. For its one noncompliant switch, TriCounty has been considering various alternatives to upgrading the generic software version in the DMS10 switch, such as  X-reconfiguring its current network and using a "salvaged switch software generic."OaM yO -ԍ TriCounty Supplemental Filing.O TriCounty asserts that it plans to have this switch fourdigit CIC capable by the third quarter of  Xb-1998, at the latest. Second, based on TriCounty's petition, we conclude that TriCounty has demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed TriCounty's ability to meet the January 1, 1998 conversion deadline. TriCounty asserts that the Nortel DMS10 switch in the Dunlap exchange uses generic software version 403.31, which does not provide fourdigit CIC capability. We conclude that the prohibitive costs TriCounty asserts it would be forced to expend to upgrade the Dunlap switch make the product necessary for conversion by January 1, 1998 effectively "unavailable" for TriCounty. Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by TriCounty, and on the ability of TriCounty's customers to reach IXCs through CAC dialing, does not outweigh the burden on TriCounty that would be imposed by a denial of its petition for waiver. The Dunlap switch  Xe-serves only approximately 80 customers.DbeXM yOn-ԍ TriCounty Petition.D Because TriCounty has requested an extension until December 31, 1998, significantly beyond the end of the permissive dialing period, below, we impose several requirements on TriCounty, as a condition to our grant of its  X -extension request.Nc M yO"-ԍ See paras. 3031, infra.N" xc0*%%ZZ\"  X-x23.` ` Requests for Extension of the TDS LECs. We find that the petition for waiver of TDS, on behalf of its ten LEC subsidiaries currently providing equal access, demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, TDS has demonstrated that the ten LEC subsidiaries are diligently working to upgrade their switches. For example, TDS asserts that for Mahanoy, Tipton, and Wolverine, installation of new switches will be completed as follows: for Mahanoy, by January 31, 1998; for Tipton, by March 31, 1998, and for Wolverine, by June 30, 1998. TDS asserts that Island is currently updating its switch software to accept fourdigit CICs, and is attempting to complete the process by January 1, 1998. Nonetheless, TDS requests an extension for Island until June 30, 1998, in the event that Island is not able to meet the January 1, 1998 deadline for unforeseen reasons. TDS asserts that the process for installing new switches for Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana is currently in progress. For Southern Indiana, using a DCO switch in the smallest of its three exchanges, requires a "front end" replacement to become fourdigit CIC compliant. TDS asserts that it has determined that it would be more beneficial to replace the switch entirely rather than to install this costly upgrade. TDS also is exploring the possibility of Southern Indiana's acquiring fourdigit CIC capability through the use of an adjacent LECs' switch. TDS anticipates fourdigit CIC compliance for Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana, by the end of 1998.  XK-  X4-x24.` ` Second, based on TDS' petition, we conclude that TDS has demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed the ability of the ten noncompliant LECs to meet the January 1, 1998 conversion deadline. For Mahanoy, Tipton, and Wolverine, switch manufacturers are unable to complete installation of the new switches by January 1, 1998, and the product is, therefore, effectively "unavailable" to meet the January 1, 1998 deadline. Badger, Central State, EastCoast, Scandinavia, and Oklahoma, use NEC switches that are no longer manufactured and assert that they no longer receive timely and adequate technical support from NEC. For Southern Indiana, we conclude that the $250,00 TDS asserts Southern Indiana would be forced to expend to perform the "front end" replacement, makes the product necessary for conversion by January 1, 1998 effectively "unavailable."  X -x25.` ` Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by the ten noncompliant TDS LECs, and on the ability of their customers to reach IXCs through CAC dialing, does not outweigh the burden on these LECs that would be imposed by a denial of TDS' petition for waiver on their behalf. The number of access lines served by the eleven subsidiaries on whose behalf TDS filed its petition are as follows: Badger, 3939 access lines; Central State, 4715 access lines; EastCoast, 1278 access lines; Scandinavia, 2733 access lines; Oklahoma, 3351 access lines, Mahanoy, 2237 access lines; Southern Indiana, 492 access lines; Home, 788 access lines; Wolverine, 659 access lines;"#c0*%%ZZG""  X-Island, 1,055 access lines; and Tipton, 5,167 access lines.DdM yOy-ԍ TDS Petition at n.1.D TDS has requested extensions for Mahanoy until January 31, 1998, for Tipton until March 31, 1998, and for Wolverine and Island until June 30, 1998. Accordingly, the grant of these extensions will not affect or interfere with the end of the permissive dialing period on June 30, 1998. Because TDS has requested extensions for Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana until January 1, 1999, however, significantly beyond the end of the permissive dialing period, as discussed below, we impose several requirements on these LECs,  X_-as a condition of our grant of TDS' extension request on their behalf.Ne_XM yOh -ԍ See paras. 3031, infra.N  X1-x26.` ` We deny as premature TDS' waiver request on behalf of Home, a LEC subsidiary not currently providing equal access. TDS requests an indefinite waiver for Home, subject to an order requiring it to upgrade to equal access. First, as TDS acknowledges, Home is not subject to the January 1, 1998 conversion deadline because it does not provide  X -equal access. In the CICs Second FNPRM, issued concurrently with the CICs Order on  X -Reconsideration, the Commission noted that some independent incumbent LECs in rural and isolated areas do not provide equal access, and recognized that a requirement that all LEC end office switches be upgraded to accept fourdigit CICs by January 1, 1998, may have the unintended effect of requiring those LECs that have never received a bona fide request for equal access or that are not subject to a specific timetable for providing equal access  XK-nonetheless to upgrade their end offices to offer equal access by January 1, 1998.XfKM yO-ԍ See CICs Second FNPRM at para. 84.X The Commission noted that such a requirement would modify the Commission's equal access implementation schedule for nonGTE independent telephone companies, set by the 1985  X-Independent Telephone Company Equal Access Report and Order. gxM yO/- xԍ See In the Matter of MTS and WATS Market Structure Phase III, Report and Order, CC Docket No. 78-72,  yO-100 F.C.C.2d 860 (1985) (Independent Telephone Company Equal Access Order).  Because more than  X-twelve years have passed since adoption of the Independent Telephone Company Equal  X-Access Report and Order, the Commission tentatively concluded that eventually all LEC end  X-offices should be required to provide equal access.!hM yOB - xԍ Specifically, the CICs Second FNPRM tentatively concluded that (1) LECs with stored programcontrolled  x(SPC) switches that have not received a bona fide request for equal access should be required to upgrade their  yO!- xfacilities to provide equal access and to accept fourdigit CICs within three years of the effective date of an Order  xadopted in this proceeding; and (2) LECs whose end offices are equipped with nonSPC switches should be required  xto provide equal access and to convert their switches to accept fourdigit CICs when they next replace their switching  yO*$-facilities. See CICs Second FNPRM at para. 84.! TDS' petition for waiver is premature  X-because the Commission has not yet released an order addressing the proposals in the CICs"H h0*%%ZZp"  X-Second FNPRM.  X-x27.` ` Request for Extension of Bruce. We find that the petition for waiver filed by Bruce demonstrates the special circumstances meriting a waiver of the January 1, 1998 conversion deadline. First, Bruce has demonstrated that it is diligently working to upgrade its switches. For example, Bruce asserts that, since 1996, it has: retained an engineering company to prepare a PWAC Study; negotiated with potential vendors; evaluated switching options, costs, and financing; determined that RUS financing will take too long; nearly completed an alternative financing arrangement; and is ready to negotiate final contractual terms and schedules. Bruce believes that it can complete arrangements for the purchase and financing of its new switching system during the first quarter of 1998, and that it can obtain, install, test, adjust, and make the new switching system ready for commercial operation by June 30, 1999. Second, based on Bruce's petition, we conclude that Bruce has demonstrated that the product needed to accomplish the upgrade is not readily available from switch manufacturers, which has delayed Bruce's ability to meet the January 1, 1998 conversion deadline. Bruce asserts that it cannot upgrade to fourdigit CICs by installing a later software release to its current host/remote configuration, because the later releases cannot accommodate Bruce's six remotes which serve approximately half of its access lines. The need for Bruce to install a new switch makes the product effectively "unavailable" for compliance with the January 1, 1998 conversion deadline. Third, we conclude that the impact of an extension of the conversion deadline on the IXCs served by Bruce, and on the ability of Bruce's customers to reach IXCs through CAC dialing, does not outweigh the burden on Bruce that would be  X-imposed by a denial of its petition for waiver. Bruce serves only 1,635 access lines.DiM yO-ԍ Bruce Petition at 1.D Bruce also asserts that its customers are presently served by 14 presubscribed IXCs. Because Bruce has requested an extension until June 30, 1999, however, significantly beyond the end of the permissive dialing period, as discussed below, we impose several requirements on Bruce, as a  X-condition of our grant of its extension request.NjXM yO-ԍ See paras. 3031, infra.N  X|- xB.` ` Effect on IXCs and Customers on Grants of Extensions Up  Xe-To and Including June 30, 1998 x`  X7-x28.` ` We recognize that the grant of extensions to Interstate, FrontierLakeshore, Council Grove, Mahanoy, Tipton, Wolverine, and Island will shorten or eliminate the time we provided for IXCs to prepare their networks and to educate their customers, in creating a two X-step transition in our Order on Reconsideration. We find, however, that the technical and economic burden on these LECs that would be imposed by a denial of the extensions outweighs the burden to the IXCs and their customers. The economic burdens imposed by a" j0*%%ZZ" denial of the extensions would be borne by the LECs' customers. We note, moreover, that only IXCs that have been issued a fourdigit CIC (who cannot currently receive CAC calls originating with the LECs' customers) will be affected by the grant of the waivers. The petitioners' networks can, and will continue to, accept CAC calling for IXCs with threedigit CICs until the transition ends on June 30, 1998. Although we recognize the potential anticompetitive effects of the dialing disparity and seek to minimize them, we believe that those effects are outweighed by the economic and technical burdens likely to be imposed on the LECs by a failure to extend the conversion deadline for them. Thus, on balance, we find that the impact of an extension of the conversion deadline on the IXCs served by Interstate, FrontierLakeshore, Council Grove, Mahanoy, Tipton, Wolverine, and Island, and on the ability of those LECs' customers to reach IXCs through CAC dialing, does not outweigh the burden on the LECs that would be imposed by a denial of the extension requests.  X -x29.` ` We note that the CICs Order on Reconsideration, in addition to requiring fourdigit CIC conversion by equal access LECs as of January 1, 1998, also requires that LECs must offer a standard intercept message beginning on or before June 30, 1998, explaining that a dialing pattern change has occurred and instructing the caller to contact its IXC for further  Xy-information.dkyM yO-ԍ See CICs Order on Reconsideration at para. 26.d The Commission requires that, in developing an intercept message, LECs must consult with IXCs and reach agreement on the content of the message and on the period of  XK-time during which the message will be provided.=lKXM yOT-ԍ See id.= We emphasize that Interstate, FrontierLakeshore, Council Grove, Mahanoy, Tipton, Wolverine, and Island must comply with the Commission's intercept message requirement.  X- xC.` ` Effect on IXCs and Customers on Grants of Extensions  X-Beyond June 30, 1998Conditions on Grants of Waivers x`  X-x30.` ` We cannot ignore the difficulties that the IXCs served by Southwest, TriCounty, Badger, Central State, EastCoast, Scandinavia, Oklahoma, Southern Indiana, and Bruce will experience in educating their customers about the forthcoming changes in dialing patterns, and the inability of these IXCs' customers to reach them through CAC dialing after the transition ends on June 30, 1998. We, therefore, condition our grant of these LECs' waiver requests as described below. As of June 30, 1998, IXCs will have converted threedigit CICs to four digits and fivedigit CACs to seven digits. IXCs assigned fourdigit CICs will expect their customers to be able to reach them by dialing sevendigit CACs. Their customers will have the same expectation. As we did with Interstate, FrontierLakeshore, Council Grove, Mahanoy, Tipton, Wolverine, and Island, we require that Southwest, TriCounty, Badger, Central State, EastCoast, Scandinavia, Oklahoma, Southern Indiana, and" l0*%%ZZ" Bruce offer intercept messages by June 30, 1998. We modify that requirement, however, for these LECs to whom we grant extensions beyond June 30, 1998. Specifically, we require that, beginning on June 30, 1998, in their intercept messages: Southwest and TriCounty indicate that callers will not be able to reach their long distance carriers through access code dialing until December 31, 1998; Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana indicate that callers will not be able to reach their long distance carriers through access code dialing until January 1, 1999; and Bruce indicate that callers will not be able to reach their long distance carriers through access code dialing until June 30, 1999. These intercept messages should help minimize disruption to the IXCs served by these LECs, and to those IXCs' customers trying to reach the IXCs by CAC dialing between June 30, 1998, and the expiration of the LECs' waivers. We also require that Southwest, TriCounty, Bruce, Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana  X -provide the same notification in bill inserts to customers.m M yOe - xԍ See Second CICs Waiver Order at para. 24 (imposing similar conditions on Hager Telecom, Inc. and Silver Star Telephone Company, Inc.).  X -x31.` ` In addition, because we grant Southwest, TriCounty, Badger, Central State, EastCoast, Scandinavia, Oklahoma, Southern Indiana, and Bruce extensions significantly beyond the end of the permissive dialing period, we impose an additional requirement on them to assist the Bureau in monitoring these LECs' diligence in converting to fourdigit CIC capability by the expiration of their waivers. Specifically, Southwest, TriCounty, and TDS (on behalf of Badger, Central State, EastCoast, Scandinavia, Oklahoma, and Southern Indiana), and Bruce must file reports on June, 30 1998, and again on September 30, 1998, with the Network Services Division of the Common Carrier Bureau detailing the progress they have made towards becoming fourdigit CIC compliant. Bruce must also file such a report on March 31, 1998. The reports should contain information concerning, but not limited to, the status of steps taken to ensure software upgrades and/or switch replacements to convert to fourdigit CICs. We believe such a reporting condition is necessary to ensure that these LECs comply with the Commission's fourdigit CIC conversion requirement in a manner consistent  X-with the public interest and to avoid further requests for waiver of the conversion deadline.~n M yOd-ԍ See id. at para. 25 (imposing similar condition on Hager Telecom, Inc.).~  Xe-  IV. ORDERING CLAUSES ă  X7-x32.` ` IT IS ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the Joint Request for Waiver of Interstate 35 Telephone Company and Southwest Telephone Exchange, Inc., IS GRANTED, by extending for Interstate 35 Telephone Company the switch conversion"n0*%%ZZ" deadline for fourdigit CIC capability until February 28, 1998, and by extending for Southwest Telephone Exchange, Inc., the switch conversion deadline for fourdigit CIC capability until December 31, 1998, subject to the conditions stated herein.  X-x 33.` ` IT IS FURTHER ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the Petition for Limited Waiver of Frontier Communications of Lakeshore, Inc., IS GRANTED, by extending for it the switch conversion deadline for fourdigit CIC capability until June 30, 1998.  X -x!34.` ` IT IS FURTHER ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the Petition for Waiver of the Council Grove Telephone Company IS GRANTED, by extending for it the switch conversion deadline for fourdigit CIC capability until June 30, 1998.  Xy-x"35.` ` IT FURTHER IS ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the Request of the TriCounty Telephone Association, Inc., for a Waiver Relating to the Commission's Rules for Recognizing FourDigit Carrier Identification Codes IS GRANTED, by extending for it the switch conversion deadline for fourdigit CIC capability until December 31, 1998, subject to the conditions stated herein.  X-x#36.` ` IT IS FURTHER ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the TDS Telecommunications Corporation Petition for Waiver IS GRANTED IN PART, by extending for ten of the eleven carrier's the switch conversion deadline for fourdigit CIC capability as follows: Mahanoy & Mahantango Telephone Company until January 31, 1998; Tipton Telephone Company until March 31, 1998; Wolverine Telephone Company and Island Telephone Company until June 30, 1998; Badger Telecom, Inc., Central State Telephone Co., EastCoast Telecom, Inc., Scandinavia Telephone Company, Oklahoma Communications Systems, Inc., and Communications Corporation of Southern Indiana, until January 1, 1999, subject to the conditions stated herein; and DENIED AS PREMATURE, to the extent it requests an indefinite waiver for Home Telephone Company, as described herein.  X"-x$37.` ` IT IS FURTHER ORDERED, pursuant to Section 1.3 of the Commission's rules, 47 C.F.R.  1.3, and authority delegated in Section 0.91 of the Commission's rules, 47 C.F.R.  0.91, and Section 0.291 of the Commission's rules, 47 C.F.R.  0.291, that the "h$n0*%%ZZ(#"ԌRequest for Waiver of Bruce Telephone Company IS GRANTED, by extending for it the switch conversion deadline for fourdigit CIC capability until June 30, 1999, subject to the conditions stated herein. x` `  hh@hpp  xx 0(#(#X x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@Anna M. Gomez x` `  hh@Deputy  #K Chief, Network Services Division x` `  hh@Common Carrier Bureau