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K B KYD KF"i~'^"(22TN"""28"2222222222888,\HBBH>8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d"">>\g0>03\\\\\\\\\\>>ggg\yyyyyF\yrrygryyrr>3>g\>\\Q\Q>\g33\3g\\\FF3gQy\QF>(>g>0gg>>>0>>>>>>\>\3y\y\y\y\y\yQyQyQyQyQF3F3F3F3g\\\\ggggrQy\\\\rQ\r\y\y\y\yQyQygyQyQyQyQyQ\\\g\ggF3F\F>F\gggy\r3r_r>rFr3ggg\\yFyFyFgFgFgFggrcr3rgggggggyrgrFrFrF\r>ggFr>r\0\\=3=WddddddddddddddddddddddddddddddddddddddddNBnnB\\F\\\\\\07\7>\7>>\\\??n\\pBnnBigg>\\7"yyyy\nyc\gnn\~2R^MH/My.X80,ɒX\  P6G;P  7jC:,ynXj\  P6G;XP2a=5,u&a\  P6G;&P2e=5,&e4  pG;&y.\80,>\4  pG;7nC:,ensure that PSPs receive fair compensation while LECs, PSPs, and IXCs transition to providing and  xreceiving payphonespecific coding digits to identify calls from payphones. We also conclude that  x?granting this waiver and allowing IXCs to pay perphone instead of percall compensation where payphonespecific coding digits are not available is in the public interest.  S - ` #x3.` ` The Bureau Coding Digit Waiver Order required that payments must be remitted at least  xon a quarterly basis. That order required that the payment for the October 1997 through December 31,  x1997 period must be paid no later than April 1, 1998. Because the waiver we grant herein will require  xsome IXCs to obtain additional information and calculate their perphone compensation amounts, these  xIXCs may need additional time to make the payments to PSPs for the October 1997 through December  x31, 1997 period for payphone compensation. Thus, IXCs may make this payment no later than April 30,  x1998, but must include additional interest for the period after April 1, 1998, at the rate of 11.25 percent  S-simple interest per year, if the payment was not made by April 1, 1998.   xx  Sl- ` x4. ` ` This order is effective immediately to ensure that all PSPs continue to receive  SD- xcompensation as required by the Payphone Orders and the Second Report and Order. Without this  xwaiver, and the clarifications set forth in this order, many PSPs would not be compensated for payphone  xycalls that began October 7, 1997, because the LECs servicing them are not yet able to provide payphone xspecific coding digits, and some of the IXCs are unable to identify certain payphone calls. The immediate  xkimplementation of this order is crucial to the Commission's efforts to ensure fair compensation for all  xPSPs, encourage the deployment of payphones, and enhance competition among PSPs, as mandated by  SV-Section 276. ` `  S- II. BACKGROUND Đ S-TP  S-xA.` ` Payphone Compensation  Sh- ` ~x5. ` ` In the Payphone Orders, the Commission adopted new rules and policies governing the"h0*&&99"  S- xpayphone industry to implement Section 276 of the Communications Act.  {Oh-ԍxReport and Order, 11 FCC Rcd at 20,541; Order on Reconsideration, 11 FCC Rcd at 21,235.#&a\  P6G;u&P#ѻ Those rules and policies in  x.part establish a plan to ensure fair compensation for "each and every completed intrastate and interstate  S- x>call using [a] payphone[.]" Z  yO-ԍXx#X\  P6G;ɒP#47 U.S.C.  276(b)(1)(A).#&a\  P6G;u&P#(#ƣ Prior to the Payphone Orders, PSPs received no revenue for originating  S- x>certain calls (i.e., for subscriber 800 and other tollfree number calls) and could not block callers from  Sd- x\making some of these calls (e.g., access code calls). Based on evidence in the record, the Commission  xconcluded that PSPs must be compensated, pursuant to Section 276 of the Act, for access code, subscriber  S-800, and other tollfree number calls, whether they are jurisdictionally intrastate or interstate.  S- ` x6. ` ` In the Payphone Orders, the Commission concluded that the appropriate percall  xcompensation amount, in the absence of a negotiated agreement, ultimately is the amount the particular  xpayphone charges for a local coin call, because the market will determine the fair compensation rate for  SP - xthose calls.w &P   {O-  Ѝx#X\  P6G;ɒP#See Report and Order, 11 FCC Rcd at 20,577, para. 70; Order on Reconsideration, 11 FCC Rcd at 21,242,  {O- xZpara. 15. The Commission defined "fair compensation" as the amount to which a willing seller (i.e., PSP) and a  {On- x,willing buyer (i.e., customer, or IXC) would agree to pay for the completion of a payphone call. Report and Order,  yO8-11 FCC Rcd at 20,568, para. 52 n.187.#&a\  P6G;u&P#w The Commission further concluded that if a rate is compensatory for local coin calls, then  xit is an appropriate compensation amount for other calls as well, because the Commission found the costs  xof originating various types of payphone calls such as access code and subscriber 800 calls to be similar  S -to the costs incurred when initiating a local coin call.7    {OP-  {Ѝx#X\  P6G;ɒP#See Report and Order, 11 FCC Rcd at 20,57778, para. 70; Order on Reconsideration, 11 FCC Rcd at  yO-21,26869, para. 71. #&a\  P6G;u&P#7  S - ` x7. ` ` Before moving to a local coin call default rate, however, the Commission found that it  x\was necessary to observe over time how the payphone marketplace would function in the absence of  xlregulation. The Commission recognized that competitive conditions, which are a prerequisite to a  xderegulatory marketbased approach, did not yet exist, and would not be achieved instantaneously.  x\Therefore, the Commission established a twophase interim plan to address coin calls and a twoyear  xinterim plan for payphone compensation for subscriber 800 and access code calls, based on a rate of $0.35  xper call, beginning November 7, 1996. Under the first phase of interim compensation, the Commission  xrequired IXCs with annual toll revenues in excess of $100 million to pay, collectively, a flat-rate  SH- xcompensation amount of $45.85 per payphone per month5 H2  yO -  >Ѝx#X\  P6G;ɒP#This compensation amount is based on an average of 131 subscriber 800 and access code calls per month  yO -at the default rate of $0.35 per call.#&a\  P6G;u&P#5 in shares proportionate to their share of total  xmarket long distance revenues. During the second phase of interim compensation, the first year of percall  x=compensation, which began on October 7, 1997, all IXCs were required to pay $0.35 per subscriber 800  S-call or access code call unless they negotiated with the PSP to pay a different amount.   S- ` 4x8. ` `  In Illinois Public Telecomm., the court affirmed many aspects of the Commission's" 0*&&99"  S- xPayphone Orders, but it vacated, among other things: (1) the default percall compensation rate the  S- xCommission had set for subscriber 800 and access code calls at the same marketbased $0.35 rate as for  xjlocal coin calls; and (2) the requirement that only those IXCs with annual toll revenues over $100 million  S- xpay PSPs for these calls during the first year of the interim period.  {O-ԍXx#X\  P6G;ɒP#Illinois Public Telecomm., 117 F.3d at 558. #&a\  P6G;u&P#(#ƹ After receiving comment on this and  Sb- x{other issues,ZbZ  {O\-  Ѝx#X\  P6G;ɒP#See Pleading Cycle Established for Comment on Remand Issues in the Payphone Proceeding, CC Docket  {O&-No. 96128, DA 971673 (rel. Aug. 5, 1997) ("Remand Notice").#&a\  P6G;u&P#Z the Commission adopted the Second Report and Order, which established a default  x compensation rate of $0.284 per call, absent a negotiated agreement, for subscriber 800, access code,  S- xyinmate, and 0+ calls.  {Oj -Ѝx#X\  P6G;ɒP#Second Report and Order, 13 FCC Rcd at 17961809, paras. 4267. See infra note 52. The Commission also extended the default percall compensation period from one  S- xto two years, for the first two years of percall compensation, i.e., from October 7, 1997 until October 6,  S- x1999, to allow participants, including IXCs, LECs, and PSPs, additional time to adjust to marketbased  S-percall payphone compensation for subscriber 800 and access code calls."H  yO-  Mԍx#X\  P6G;ɒP#The default percall rate is the rate that applies in the absence of a negotiated agreement between parties  xduring the first two years of percall compensation. Thereafter, the default rate, in the absence of a negotiated  xagreement, is the marketbased local coin rate less $0.066. For coinless payphones, $0.284 will continue to be the  {O-percall default rate, absent a negotiated agreement.  Second Report and Order at 17781779, para. 1 n.1. #&a\  P6G;u&P#ё     SN -xB.` ` PayphoneSpecific Coding Digits   S( -x` `  S - ` x9.` ` In the Payphone Orders, the Commission imposed a requirement that, by October 7, 1997,  xLECs transmit payphonespecific coding digits to PSPs, and that PSPs transmit those digits from their  S - xpayphones to IXCs.< 2  {O-  Ѝ#K\  P@QɒP#x See Report and Order, 11 FCC Rcd at 20,591, paras. 9899; Order on Reconsideration, 11 FCC Rcd at  yON-21,26566, para. 64, and 21,27880, paras. 9399. < The Commission also required IXCs to implement methods to track payphone  S - xcalls.  {O-ԍx#X\  P6G;ɒP#See Report and Order, 11 FCC Rcd at 20,59091, paras. 9697.#&a\  P6G;u&P# In the Order on Reconsideration, the Commission clarified that the provision of payphonespecific  Sd- xicoding digits is a prerequisite to payphone percall compensation payments by IXCs to PSPs for subscriber  S<- x800 and access code calls<  {O-#X\  P6G;ɒP#эxSee Order on Reconsideration, 11 FCC Rcd at 21,26566, para. 64, and 21,27880, paras. 9399.  and that each payphone must transmit coding digits that "specifically identify  S- xyit as a payphone, and not merely as a restricted line."  {Od!-ԍx#X\  P6G;ɒP#Id.   #&a\  P6G;u&P#ќ Finally, that order clarified that LECs must make  S-available to PSPs, on a tariffed basis, such coding digits as part of their ANI for each payphone.B  {O#-ԍx#X\  P6G;ɒP#Id. at 21,26566, para. 64. #&a\  P6G;u&P#ѧ "0*&&99"Ԍ S- ` x 10.` ` On October 7, 1997, the Bureau provided, on its own motion,v  {Oh-ԍxSee Section 1.3 of the Commission's rules, 47 C.F.R.  1.3. v a limited waiver until  xMarch 9, 1998, for those payphones from which the necessary coding digits to identify individual  S- xpayphone calls were not provided.pZ  {O-ԍxBureau Waiver Order, 12 FCC Rcd at 16,388, para. 2.p The limited waiver was to afford LECs, IXCs, and PSPs an extended  xKtransition period for the provision of payphonespecific coding digits without further delaying the payment  xof percall compensation for each and every call originated from a payphone as required by Section 276  S8- x?of the Communications Act.8  yO -ԍ x#X\  P6G;ɒP#47 U.S.C.  276.#&a\  P6G;u&P#ѓ This limited waiver applied to the requirement that LECs provide  xpayphonespecific coding digits to PSPs, and that PSPs provide coding digits from their payphones before  x.they can receive percall compensation from IXCs for subscriber 800 and access code calls. The Bureau  xjstated, however, that LECs and PSPs capable of transmitting coding digits for some or all of their serving  S-area remained obligated to do so.|  {O-ԍx#X\  P6G;ɒP#See Bureau Waiver Order, 12 FCC Rcd at 16,388, para. 3.   SH - ` 3x 11. ` ` On March 9, 1998, in the Bureau Coding Digit Waiver Order, the Bureau clarified the  S" - xrequirements established in the Payphone Orders for the provision of payphonespecific coding digits by  x"LECs and PSPs, to IXCs. Specifically, the Bureau clarified that flexible automatic numbering  S - xidentification ("FLEX ANI")   yO-  /ԍxFLEX ANI, which is a switch software feature, enables the transmission of a number of additional coding  {OJ- xdigits with a call that can, inter alia, uniquely identify a call as coming from a payphone. FLEX ANI codes are  xgenerated in end office databases and FLEX ANI is more flexible and easily modified to add additional coding digits  x-than conventional ANI ii. When FLEX ANI codes are available, they are outpulsed with the call, instead of the  xembedded hardcoded ANI ii digits. FLEX ANI enables the assignment of more two digit codes (potentially 0099)  x;for payphones in addition to the "27" code already provided by ANI ii, including "29" for prison/inmate payphones  xhand "70" for "smart" payphones. FLEX ANI coding digits are transmitted as part of the ANI signaling sequence and  {O- xare used by the receiving switch to identify the type of originating line or the type of call being made. See Bureau  {O-Coding Digit Waiver Order at para. 20.  and automatic number information indicators ("ANI ii") are the methods  S - xto provide payphonespecific coding digits that comply with the requirements of the Payphone Orders.   yO0-  >ԍ#K\  P@QɒP#x In most cases, when the IXC subscribes to Feature Group D (FGD access), LECs currently provide along  xwith the billing number (ANI), the ANI ii, which identifies calls coming from certain payphones. ANI ii is a widely  xused technology that sends a twodigit code along with the ANI. The transmitted ANI ii codes, hardwired as part  xLof the switch's generic software, identify the call as "27" if the call is from a "dumb" payphone or "07" for a  xirestricted line, which includes "smart payphones" as well as other types of calls, such as hotel calls. Thus, ANI ii  xprovides, along with the billing number, a unique coding digit identifying dumb payphones with the "27" code, but  xdoes not provide a unique coding digit identifying smart payphones, which are identified with the "07" coding digit  {O"- xthat also identifies other calls such as hotel and hospital calls. To comply with the Payphone Orders, LECs must  {Or#- x<hardcode additional payphonespecific coding digits ("70," "29"). In the Bureau Coding Digit Waiver Order the  xZBureau required LECs to implement FLEX ANI unless "a LEC hardcodes into all of its switches all the payphone  {O%- xKspecific coding digits necessary for identifying payphone calls for percall compensation." Bureau Coding Digit"%0*&&s%"  {O-Waiver Order at para. 2 n.9. #&S\  P@Qu&P#ѻ " Z0*&&99z "  S- xThe Bureau also clarified the requirement for federal tariffs that LECs must file pursuant to the Payphone  S- x\Orders.\Z  {O-  Ѝx#X\  P6G;ɒP#See id. at paras. 3443 (discussing tariffing requirements that LECs must file pursuant to the Payphone  {O- xOrders); see also Report and Order, 11 FCC Rcd at 20,591, paras. 9899; Order on Reconsideration, 11 FCC Rcd at 21,26566, para. 64, and 21,27880, paras. 9399. The Bureau also granted permissions and waivers under Part 69 of the Commission's rules  xMallowing LECs to establish rate elements to recover the costs of implementing FLEX ANI to provide  S- x payphonespecific coding digits for percall compensation.~  S -ԍx#X\  P6G;ɒP#47 C.F.R. Part 69.#&a\  P6G;u&P# #K\  P@QɒP#Ŀ In addition, the Bureau granted limited  xwaivers to LECs, PSPs, and IXCs to facilitate the transition to percall compensation and affirmed its  S<- x/grant, in the Bureau Waiver Order, of a limited waiver of five months, until March 9, 1998, to those  xyLECs and PSPs who asserted that they could not provide payphonespecific coding digits as required by  S-the Payphone Orders.  {O-ԍx#K\  P@QɒP#See Bureau Coding Digit Waiver Order at paras. 7071, 7678, 8082.#K\  P@QɒP#  S- ` nx 12. ` ` In the Bureau Coding Digit Waiver Order, the Bureau emphasized that the IXC obligation  Sz- xLto pay percall compensation established in the Payphone Orders remains in effect.F z  {O-ԍxId. at para. 4.F As required in the  ST - xBureau Waiver Order, payphones appearing on the LECprovided lists of payphones are eligible for per S. - x>call compensation even if they do not transmit payphonespecific coding digits.!. B  {O-ԍx#K\  P@QɒP#Bureau Waiver Order, 12 FCC Rcd 16,39091, paras. 914. As required in the  S - x[Payphone Orders and the Second Report and Order, absent a negotiated agreement, IXCs must pay per S - xcall compensation of $0.284, for all calls not otherwise compensated that they receive from payphones.>"  {OT-  [ԍx#K\  P@QɒP#See Bureau Coding Digit Waiver Order at paras. 1112 (discussing the payphone compensation requirements  {O-established in the Payphone Orders and the Second Report and Order). >  S - x=The Bureau Coding Digit Waiver Order required that payments must be remitted at least on a quarterly  xybasis. That order stated that the payment for the October 1997 through December 31, 1997 period must  xbe paid no later than April 1, 1998, and that LECs that have certified to the IXC that they comply with  SB- x-the requirements of the Payphone Orders must receive percall compensation.#B0  {O-ԍx#K\  P@QɒP#See Order on Reconsideration, 11 FCC Rcd at 21,293, paras. 13132.#&S\  P@Qu&P# That order also stated that  S- xthere are no state or federal certification requirements.a$  {O~!-ԍx#K\  P@QɒP#Id.a Additionally, that order recognized that there  xLlikely would be some disputes between IXCs and PSPs about the true number of compensable calls, and that these disputes should not be a basis for delay of payphone compensation payments. x  S|- ` ax 13. ` ` In the Bureau Coding Digit Waiver Order, the Bureau deferred addressing AT&T's "|T$0*&&99"  S- x!request that it and similarly situated IXCs receive a waiver to pay perphone rather than percall  S- xcompensation for payphones that do not provide payphonespecific coding digits.y%  {O@-ԍx#K\  P@QɒP#See AT&T Letter at 1.y The Bureau also  xdeferred addressing whether a retroactive adjustment or trueup would be necessary. These issues, therefore, are discussed herein. x S8- III. DISCUSSION TP  S-xA. ` ` AT&T Request for a Waiver to Pay Perphone Compensation  S-x` ` 1. Background  SJ - ` x 14. ` ` The Payphone Orders established a twophase interim compensation plan. Under the first  xjphase of interim compensation, which extended from November 7, 1996, through October 6, 1997, IXCs  xwith annual toll revenues in excess of $100 million were required to compensate PSPs on a flatrate per S - xphone compensation basis in proportion to that carrier's share of the annual toll revenues.z& Z  {O-ԍxSee Report and Order, 11 FCC Rcd at 20,578, 20,601, paras. 72, 119.z Beginning  xOctober 7, 1997, IXCs were required to pay compensation on a percall basis. AT&T states, however,  S - xthat it will be unable to pay percall compensation because of the waiver granted in the Bureau Waiver  S^- xKOrder, which provides LECs and PSPs an extended time period within which to provide payphonespecific  S8- xLcoding digits. Therefore, AT&T proposes an alternative method to enable it and other similarly situated  S- x[IXCs to comply with the Commission's payphone compensation requirements and the Bureau's Waiver  S-Order.'  {Ov-#X\  P6G;ɒP#э x#X\  P6G;ɒP#See AT&T Letter at 12.  S-  S- ` x15. ` ` AT&T contends that it cannot perform database matches of "07" coded calls to ensure that  St- x\PSPs are compensated for such calls.(t~  {O-  \ԍxSee id. AT&T states that its ability to perform its obligations under the Commission's Payphone Orders  xhis "severely prejudiced by the Bureau's waiver order" because AT&T "cannot track payphone calls on a percall basis  {O$- xfor the majority of payphone calls that require compensation during the waiver period." Id. at 2.  AT&T states that  xit currently is able to track and pay per-call compensation for dial-around operator service calls because those calls  x>are routed from its 4ESS switches to 5ESS switches within AT&T's network. AT&T's 5ESS switches can  xinterconnect with an ancillary Originating Line Number Screening database maintained by the LECs to identify  {OF- xwhether the dialaround call originated from a payphone. Id. at n.1. AT&T states, however, that it is not able, to  xtrack and compensate subscriber 800 calls from payphones that transmit a "07" coding digit because it would be  xprohibitively expensive for those calls to be rerouted to the 5ESS switches in order to use the line information  {O!-database (LIDB) to determine whether such calls originated from payphones. Id. at 2.#&a\  P6G;u&P#ѝ AT&T 3'Standard - Dup Short3'Standard - Dup ShortRS]\ 3'Standard - Dup Short3'Standard - Dup ShortRS]\ *   proposes, therefore, that the Commission modify the  SL- xBureau Waiver Order by allowing AT&T and other similarly situated carriers to comply with the  S&- xkCommission's payphone compensation requirements and the Bureau Waiver Order by allowing such  S- xcarriers to pay compensation on a perphone basis modeled on the formula that the Commission develops"(0*&&99"  S- x.for interim compensation.w)ڦ {Oh-Ѝx#X\  P6G;ɒP#See id. at 12.w AT&T proposes that the Commission permit carriers to use the perphone  xcompensation method to calculate a carrier's payment obligations during the waiver period for payphones  S- x[that do not deliver the necessary coding digits.*Zڦ {O-  >#X\  P6G;ɒP#э x#X\  P6G;ɒP#See id. at 1, 3. American Public Communications Council (APCC) argues that AT&T's claim that it can  yOt-track access code calls on a percall basis but not subscriber 800 calls is illogical.  APCC Comments at 9.  AT&T also requests that the Commission require each  S- xLEC to provide the Commission and carriers with a list of the offices that currently can deliver payphone  x{digits, and a schedule of dates by which the LECs other equal access end offices will be capable of  S8-delivering payphonespecific coding digits. The Public Notice sought comment on AT&T's request.a+8ڦ {O -ԍxPublic Notice, 12 FCC Rcd at 17,340.a  S-x` ` 2.  Discussion  S- ` 2x16. ` ` We grant, in part, AT&T's request that we waive the payphone compensation provisions  xjand permit IXCs to pay perphone"instead of percall"compensation when payphonespecific coding  SJ - xdigits are not provided with a payphone call's ANI.,DJ Fڦ yO0-  Ѝx#X\  P6G;ɒP#APCC argues that if the Commission decides to require percall compensation for those payphones that  xtransmit ANI then all IXCs should be required to pay percall compensation on those payphones. In the alternative,  x=APCC argues the Commission could mandate flatrate compensation for all dumb line payphones. The LEC  xCoalition (the Bell Operating Companies (BOCs), General Telephone Corporation (GTE) and Southern New England  xTelephone (SNET)) and APCC argue that the Commission should consider limiting the scope of an IXC waiver to  {O- xrequire compensation of access code calls on a percall basis and subscriber 800 calls on a flatrate basis. See APCC  xZReply at 9; LEC Coalition Reply at 68. Sprint Corporation (Sprint) supports AT&T's request to pay perphone  {O-compensation when payphonespecific coding digits are unavailable. See Sprint Reply at 6.#&a\  P6G;u&P#я In the Report and Order, the Commission  xjconcluded that the requisite technology exists for IXCs to track calls from payphones. The Commission  xrecognized, however, that tracking capabilities vary from carrier to carrier, and that it may be appropriate,  S - xfor an interim period, for some carriers to pay compensation for "each and every completed intrastate and  S - xLinterstate call" on a flatrate basis until percall tracking capabilities are in place.o- R ڦ {O-ԍxReport and Order, 11 FCC Rcd at 20,59091, paras. 9697.o In the Bureau Coding  S - xDigit Waiver Order, the Bureau explained that the record indicates that LECs, PSPs, and IXCs are  S`- xencountering problems with transitioning to percall compensation.m.`ڦ {O-ԍxSee Bureau Coding Digit Waiver Order at paras. 56, 58.m We conclude that AT&T has shown  xZspecial circumstances for IXCs to pay perphone instead of percall compensation when payphonespecific  S- xcoding digits are not available, particularly in light of the waivers granted within the Bureau Waiver Order  S-and the Bureau Coding Digit Waiver Order.  S- ` x17. ` ` Other IXCs also indicate a problem paying percall compensation during the waiver" v.0*&&99"  S- xperiod when payphonespecific coding digits are not available./Zڦ {Oh-  ԍxSee, e.g., Letter to Magalie Roman Salas, FCC from Richard S. Whitt, WorldCom, Inc. (WorldCom), (Mar.  xI 5, 1998) (stating that WorldCom cannot implement multiple treatment of ANI "07" calls and therefore, that it cannot pay percall compensation until payphonespecific coding digits are available). Moreover in certain circumstances, such  xjas payphones served by nonequal access switches, payphonespecific coding digits will not be available  xkuntil the switches are replaced. Therefore, we also conclude that based on these problems, it is in the  xpublic interest to grant this waiver conditioned upon an IXC's compliance with the methodology set forth  xMherein, which allows IXCs to pay perphone compensation until payphonespecific coding digits are  xavailable for a payphone. We find that it is in the public interest to grant this waiver conditioned upon  xan IXC's compliance with the methodology set forth herein, and allow IXCs to pay perphone  xcompensation where payphonespecific coding digits are unavailable from a payphone, so that there is no  S- xfurther delay in the payment of payphone compensation.0Zڦ {OJ -  Ѝx#K\  P@QɒP# Although the court in Illinois Public Telecomm. vacated the percall compensation amount for the interim  x period and the approach for allocation of the compensation amount, the court did not vacate the use of perpayphone  yO -versus percall compensation. 117 F.3d at 565. #&S\  P@Qu&P# This waiver is consistent with the  S- xCommission's conclusion in the Payphone Orders that it is appropriate for carriers to pay flatrate or per Sr- xphone compensation for an interim period until carriers fully implement tracking capabilities.1\r ڦ {O-  MЍx#K\  P@QɒP#See Report and Order, 11 FCC Rcd at 20,59697, paras. 11012; Order on Reconsideration, 11 FCC Rcd  xat 21,280, para. 99. We note that our rules currently permit perphone and other types of negotiated compensation  {O-agreements. See 47 C.F.R.  1300(a). #&S\  P@Qu&P# The  SJ - xwaiver granted herein does not apply if either the "27" coding digit or a FLEX ANI coding digit ("27,"  x"70," "29") is available from a LEC for that payphone and that payphone is able to provide payphone xspecific coding digits; where the payphonespecific coding digit is available, the percall compensation  S -requirements apply.2& 0 ڦ {O-  ԍxIn the Bureau Coding Digit Waiver Order, the Bureau noted that some LECs would need additional time  xKto implement FLEX ANI due, in part, to technical problems encountered in implementing FLEX ANI in certain  {O4- xswitch types, such as problems with NORTEL switches that do not provide payphonesspecific coding digits. See  {O-Bureau Coding Digit Waiver Order at paras. 55, 59.  S -xB.` ` Percall and Perphone Compensation Requirements  S4-x` ` 1. Compensation Requirements  S- ` x18. ` ` In the Bureau Waiver Order and the Bureau Coding Digit Waiver Order, we required  S- xIXCs to pay percall compensation.3ڦ {O|!-ԍx#X\  P6G;ɒP#Bureau Waiver Order, 12 FCC Rcd at 16,38990, paras. 89.#&a\  P6G;u&P#Ѿ Pursuant to the waiver we grant herein, beginning October 7, 1997,  xIXCs must either pay percall, or perphone compensation as described below, for payphones that do not  xprovide payphonespecific coding digits. IXCs must pay percall compensation for all payphones capable  xof providing a "27" ANI ii coding digit or FLEX ANI coding digits ("27," "70," "29") for compensable  xcalls. IXCs must compensate payphones that do not provide payphonespecific coding digits ("27," "70,"" 30*&&99D"  x"29") either on a percall basis or the perphone method described below. Therefore, IXCs who choose  xto pay perphone compensation pursuant to the waiver granted herein, must use payphone call volume  x.information that is already available to them to determine the call volumes for which a payphone should  S- x-be compensated when payphonespecific coding digits are not available for a specific payphone.4 4N ڦ {O-  >Ѝx#X\  P6G;ɒP#See Bureau Coding Digit Waiver Order at para. 36, which states that LECs must provide information on  {O- x;payphones that do and do not provide payphonespecific coding digits. As the Commission stated in the Payphone  {O- xwOrders, some PSPs also are entitled to compensation for 0+ calls and calls originated from inmate payphones, which  xare primarily 0+ calls. Specifically, we found that PSPs should be compensated for 0+ and inmate calls where not  xcompensated pursuant to contract due to legal impediments, thus, BOC payphones and other similarly situated  xYpayphones. Because we find that percall tracking exists for these call types, the compensation provisions set forth  x-herein are inapplicable to 0+ and inmate calls. To the extent that carriers do not track 0+ and inmate calls, the  x,compensation scheme set forth herein will apply. For example, if a carrier does not receive the proper coding digit  xfrom a payphone to enable that carrier to determine whether a 0+ call originated from that payphone, that carrier  xwill compensate that particular payphone for 0+ calls on a perphone basis. If the carrier is not receiving the proper  xcoding digit from a LEC payphone, such as GTE, then that carrier will compensate the LEC payphone for 0+ calls  xoriginated from LEC payphones based on the compensation scheme described herein for compensation for subscriber  x800 and access code calls. We note, however, that the carriers should not include 0+ call counts in call counts with  xsubscriber 800 and access code calls. Compensation for 0+ and inmate calls is in addition to compensation for  xsubscriber 800 and access code calls. We further note that perphone compensation for 0+ calls will be limited  x[because compensation for such calls is limited to those PSPs who were legally precluded from contracting for compensation for such calls, and further, that most carriers have the ability to track 0+ calls. 4 An IXC  xjmay choose to compensate those payphones that are not capable of providing payphonespecific coding  x0digits on a percall basis where the IXC maintains a percall tracking mechanism, such as tracking  S- xpayphone calls from payphones that transmit an "07" digit and then comparing those calls to ANI lists.85@ڦ yO-  ԍx#K\  P@QɒP#MCI Telecommunications Corporation (MCI) supports the ability of IXCs to have a choice of paying per xcall or perphone compensation depending on their capabilities to track payphone calls. MCI Reply at 6. APCC  xargues that this approach would lead to IXCs using either approach when it was financially most advantageous.  x;APCC Reply at 9. MCI opposes APCC's argument that if the Commission grants AT&T's waiver request to enable  xcarriers to pay compensation on a perphone basis during the waiver period, that all carriers must pay on a perphone  x<basis. MCI argues that carriers that are able should be allowed to pay on a percall basis. MCI Reply at 6. Sprint  xrequests that the Commission give IXCs the choice of paying perphone or percall until the waiver ends or coding  yO-digits are provided.#&S\  P@Qu&P#8  xWe note, however, that an IXC may not compensate some payphones that do not provide payphone xspecific coding digits (but do provide an "07" ANI ii coding digit) on a percall basis and other payphones  xthat do not provide payphonespecific coding digits (but do provide an "07" ANI ii coding digit) on a per xphone basis, except for those payphones that are in the process of changing from perphone to percall  SH - xcompensation.e6H ڦ {O -ԍxSee infra paras. 19 & note 57; 24 & note 65. e We note that the default rate established in the Second Report and Order, $0.284, which  xterminates at the conclusion of percall compensation"October 7, 1999"will continue to remain in effect  x=as a default compensation rate, absent a negotiated agreement, for calls originated from those payphones  S -that are not able to provide payphonespecific coding digits.7 xڦ {O$-ԍx#X\  P6G;ɒP#See Bureau Coding Digit Waiver Order at para. 12 & n.47.#&a\  P6G;u&P#ѽ " 70*&&99{ "Ԍ S- ` Pԙx19. ` ` As we discussed in the Bureau Coding Digit Waiver Order, LECs must provide ANI lists  xand lists of end offices that are not providing payphonespecific coding digits that specifically identify  S- xsmart and dumb payphones to IXCs.8ڦ {O-ԍx#K\  P@QɒP#Bureau Coding Digit Waiver Order at para. 36. #&S\  P@Qu&P#Ѻ In accordance with the compensation mechanism described below,  xIXCs must pay percall compensation, not perphone compensation, once FLEX ANI is available in an  Sb- xend office.9bZڦ yO\-  ЍxIXCs are responsible for requesting FLEX ANI. Once FLEX ANI is available for payphones served by a  x LEC, the IXC must pay percall compensation instead of perphone compensation for the first day of the next quarter  xand thereon so long as the IXC has had 30 days prior to the quarter when payment is due to implement FLEX ANI  xafter payphonespecific coding digits are available for payphones that were not previously capable of providing  xpayphonespecific coding digits. For example, if a payphone is able to provide payphonespecific coding digits on  xJuly 17, 1998, that payphone must be compensated on a percall basis for the quarter beginning October 1998. On  xthe other hand, if a payphone does not become capable of providing payphonespecific coding digits until September  x15, 1998, then that payphone could continue to receive perphone compensation and would not have to be  xYcompensated on a percall basis until January 1999. We note, however, that IXCs are free to pay on a percall basis earlier if they are able.  We note that if payphonespecificcoding digits are available for a payphone in an end  x[office, the fact that an IXC may decide not to take FLEX ANI from the LEC for that end office does not  xyrelieve the IXC of paying percall compensation for that payphone once payphonespecific coding digits are available. The waiver to pay perphone compensation does not apply in this case.  S- ` x20. ` ` We also clarify the requirements set forth in the Bureau Coding Digit Waiver Order, that  St- xLECs must provide IXCs and PSPs with certain information on request.M:d t ڦ {O-  ԍx In the Bureau Coding Digit Waiver Order, we required that beginning March 27, 1998, until a LEC has  ximplemented FLEX ANI for all payphones it serves, it must provide monthly to IXCs and PSPs, upon request,  xinformation on: (1) end offices where FLEX ANI is available; and (2) proposed dates for the availability of FLEX  xANI by end office for all areas where it is not yet available. Beginning March 27, 1998, all LECs must provide on  xa monthly basis to IXCs, upon request: (1) the number of smart and the number of dumb payphones that are owned  xYby the LEC, PSP, and independent PSPs in the LEC service area; and (2) the ANI for smart payphones and the ANI  xxfor dumb payphones owned by the LEC and independent PSPs that are providing payphonespecific coding digits  x;and those that are not providing payphonespecific coding digits in the LEC service area. We required that in these  xtwo reports, LECs indicate which end offices and payphone ANI's are codingdigitcapable and which payphone  xANIs are not codingdigitcapable. A payphone is "codingdigitcapable" when it is able to transmit payphone xspecific coding digits that are capable of reaching an IXC point of presence (POP) for subscriber 800 and access code  {O-calls from payphones using 10XXX and 101XXXX. See Bureau Coding Digit Waiver Order at para. 36.M Because IXCs choosing to pay  xLpercall compensation for smart payphones even when payphonespecific coding digits are not available  xwill have to compare calls with an "07" ANI ii digit with a LEC ANI list, we require that the LEC ANI  S - xlists provided to the IXCs as required in the Bureau Coding Digit Waiver Order also indicate whether the  x{smart payphones are transmitting the "07" digit. LECs also must provide FLEX ANI and ANI ii  xpayphonespecific coding digits as soon as they are available on a switch to each IXC once the IXC requests the service for payphone compensation.  S6-x` ` 2. Compensation Methodology " :0*&&99"Ԍ S- ` }x21.` ` IXCs must pay percall compensation for a payphone if ANI ii payphonespecific coding  xdigits ("27") or FLEX ANI payphonespecific coding digits ("27," "70," "29") are available to the IXC.  xWe grant a waiver to IXCs and allow them to compensate PSPs on a perphone basis for those payphones  xthat are not able to provide payphonespecific coding digits conditioned upon the IXCs' compliance with  xthe methodology set forth in this order. IXCs electing to pay perphone compensation in accordance with  x the waiver we grant herein must calculate the average number of subscriber 800 and access code calls  xbased on information obtained from BOC dumb payphones transmitting the "27" coding digit. We divide  x-payphones into five categories for determining the methodology used to calculate perphone compensation:  S- x(1) payphones able to provide payphonespecific coding digits; (2) LEC payphones that are not able to  xprovide payphonespecific coding digits served by equal access switches (except those payphones subject  xto category (5)); (3) independent PSP payphones that are not able to provide payphonespecific coding  x.digits served by equal access switches (except those payphones subject to category (5)); (4) payphones  xserved by nonequal access switches; and (5) payphones on equal access switches owned by small and  xmidsized LECs granted a waiver from the implementation of FLEX ANI because they are unable to  xrecover the cost of FLEX ANI implementation over a reasonable period ("small and midsized LEC  S -waiver") pursuant to paragraph 76 of the Bureau Coding Digit Waiver Order.  SZ- ` Px22. ` ` Although we describe the compensation method for these categories individually, with the  xexception of the compensation method for those payphones that are able to provide payphonespecific  x coding digits, pursuant to the methodology set forth for other categories, IXCs must use call volume  xMinformation obtained from October 1997 through March 31, 1998 (the "sample period"), to establish  xaverage subscriber 800 and access code call volumes perphone to compensate PSPs for calls originated  S- xfrom their payphones during the fourth quarter of 1997 and the first quarter of 1998 (from October 7,  Sj- xy1997 through March 31, 1998).F;jڦ yO-  >ԍxTo establish monthly call volumes for the entire month of October, if a payor did not track calls for the  xperiod October 1 through October 6, a payor must determine the average daily call volumes for the month of October  xand then add the call volumes for the first six days to the call volumes for the rest of the month to get a monthly  xJtotal for October that can be used with the call volumes for the other months to establish an average for the sample period.F Thereafter, IXCs electing to pay perphone compensation pursuant to  xthe waiver granted herein will base compensation owed to PSPs for payphones that are not able to provide  xpayphonespecific coding digits on call volumes obtained from BOC dumb payphones that are able to  S- xprovide payphonespecific coding digits during the quarter for which compensation is owed.<xڦ yO -  zԍxFor example, if compensation is due to PSPs for the second quarter of 1998, IXCs will pay PSPs based on call volumes collected from BOC dumb payphones during AprilJune 1998. Regardless  S- xwhether a payor pays percall or perphone compensation, each payor must compensate PSPs $0.284 per  xcall, adjusted for interest where appropriate. In addition, although the compensation mechanism described  x=below calculates compensation on a monthly basis, we note that compensation must be remitted at least  SR- x>on a quarterly basis absent alternative arrangements between the PSP and the IXC.= Rڦ yO"-  ԍx When paying perphone compensation as described herein, payphone compensation payors should note that  xhpayments by each payor for each payphone being compensated by that payor on a perphone basis will be the same,  xwalthough different payors will vary in the number of calls for which they must compensate payphones receiving perphone compensation.  We emphasize,"R =0*&&99|"  S-however, that payphones can receive compensation only for those months that they were in service.>ڦ {Oh-  ԍxMoreover, the Bureau Coding Digit Waiver Order clarified that within 30 days of the release of that order,  xPSP payphones must be on LEC payphones lines to continue to be eligible for payphone compensation. The waiver  xwe grant in this orders for certain payphones to receive perphone compensation does not apply to those payphones  {O- xwthat are not on LEC payphone lines as required in the Bureau Coding Digit Waiver Order. See Bureau Coding Digit  {O-Waiver Order at para. 33.   S- ` x23. ` ` IXCs must maintain the information they use to develop percall and perphone  S- x[compensation payments to PSPs. In the Report and Order, the Commission required that IXCs initiate  xLan annual verification of their percall tracking functions to be made available for Commission inspection  xupon request, for the 1998 calendar year to ensure that IXCs are tracking all of the calls for which they  S- xare obligated to pay compensation.i?~ڦ {O0 -ԍxReport and Order, 11 FCC Rcd at 20,592, para. 101.i The Report and Order requires that payors file a report with the  x=Bureau on the number of compensable calls and compensation paid for the 1998 calendar year within 90  S- xdays after the 1998 calendar year.j@ڦ {Ot-ԍxId. See 47 C.F.R.  64.1320(a). hhj Nothing in this waiver order relieves IXCs of the responsibility of  xmaintaining this information. Payors must be prepared to submit their compensation calculations and payment records if requested by the Bureau.  S$ -x` ` a. Payphones capable of providing payphonespecific coding digits x  S - ` 2x24. ` ` The first category, payphones capable of providing payphonespecific coding digits must  xbe compensated on a percall basis. Compensation must be remitted at least on a quarterly basis absent  xNalternative arrangements between the PSP and the IXC. If a payphone that is not able to provide  xpayphonespecific coding digits becomes capable of providing payphonespecific coding digits in the first  x\60 days of a quarter, then the IXC will be responsible for compensating that particular PSP on a per S- xcall"instead of perphone"basis beginning the next quarter.A ڦ yOP-  =ЍxFor example, if a payphone becomes able to provide payphonespecific coding digits during the first 60 days  xof the third quarter 1998 (i.e., July 17, 1998), that payphone will receive perphone compensation for the remainder  xof the quarter. The payphone will receive percall compensation beginning the following quarter. The IXC must  xpay percall compensation for the entire fourth quarter and thereafter for that payphone. We note, however, that if  x<an IXC chooses, it may pay percall compensation immediately upon taking FLEX ANI. We decline to require,  xX however, that IXCs pay percall rather than perphone compensation for a payphone the same quarter that a particular  x.payphone is capable of transmitting payphonespecific coding digits because we recognize that there may be  xconfusion in calculating appropriate payments and the IXC and LEC may need time to test and provision FLEX ANI  {O -for that IXC. See supra note 57.  The payor will multiply the number of  xcalls received from each PSP's payphone capable of providing payphonespecific coding digits by $0.284 to compute compensation owed to that PSP. x  Sn-x` ` b. LEC payphones that are not capable of providing payphonespecific coding digits  x"HtA0*&&99T"Ԍ S- ` x25. ` ` The second category, LEC payphones that are not able to provide payphonespecific  S- xcoding digits will be compensated on a perphone basis. We base compensation for LEC payphones that  xare not capable of providing payphonespecific coding digits on the average number of subscriber 800 and  x[access code calls realized from BOC dumb payphones that are able to provide payphonespecific coding  xdigits. There is insufficient information on the record to suggest that LEC payphones that are not able  x<to provide payphonespecific coding digits realize different call volumes than BOC payphones that are able  xto provide payphonespecific coding digits. Therefore, we find that it is appropriate to base compensation  xjfor LEC payphones that are not able to provide payphonespecific coding digits on call volumes realized by BOC payphones that are able to provide payphonespecific coding digits. #&a\  P6G;u&P#  Sp- ` $x26. ` ` To determine the amount of compensation due to LEC payphones that are not able to  SH - xLprovide payphonespecific coding digits,BH ڦ yO -Ѝx#X\  P6G;ɒP#We note that this compensation method is for those payphones that are located on equal access switches.#&a\  P6G;u&P# the payor will calculate the average number of subscriber 800  x=and access code calls it received from BOC dumb payphones that are able to provide payphonespecific  S - xcoding digits (the "27" coding digit) from October 1, 1997 through March 31, 1998 (the sample period).[CX Xڦ yO-  >ԍxWe require payors to compute compensation owed to LEC PSPs and independent PSPs based on data for  x six months, instead of merely the first quarter of percall compensation, to account for the potential seasonality issues that cause payphone call volumes to fluctuate.[  xFirst, the IXC will sum the number of completed subscriber 800 and access code calls it received from  xkall BOC dumb payphones that were capable of providing payphonespecific coding digits during this  xperiod and divide by six. This results in the average number of subscriber 800 and access code calls  SX- xLreceived from all BOC dumb payphones per month.DXxڦ yOp-  Ѝx#X\  P6G;ɒP#We recognize that for access code calls made from dumb payphones using 10XXX, the coding digit will  {O8- xbe passed to the IXC, even if the payphone does not otherwise provide payphonespecific coding digits. See Letter  xfrom Marie Breslin, Bell Atlantic to Magalie Roman Salas, Secretary, FCC (Mar. 3, 1998). Therefore, when IXCs  xsum the total number of subscriber 800 and access code calls that its records show were received from all BOC dumb  xZpayphones, that sum would be slightly greater than if the IXC summed those calls received from only BOC dumb  x<payphones that generally provide the payphonespecific coding digits. Since most access code calls are made by  xdialing an 800 number, however, the difference should be minor relative to either sum. IXCs are free, however, to  xsum the calls from only BOC dumb payphones that generally do provide payphonespecific coding digits. To the  xjextent that determining the number of calls from all BOC dumb payphones overstates the average number of  xpayphone calls from the IXC, it would tend to offset concerns of payphone owners that smart payphones deserve  {OB-a higher call volume than dumb payphones.  See infra para. 29.  Second, the payor will obtain from the BOCs the  xnumber of BOC dumb payphones that were capable of providing payphonespecific coding digits as of  xthe first of each month for the sample period. The payor will sum the figures and divide by six. This  xis the average number of BOC dumb payphones able to provide payphonespecific coding digits during  S- xthe sample period.E$ڦ yO4"-  ?Ѝx#X\  P6G;ɒP#We emphasize that the divisor consists only of those payphones that are capable of transmitting the  xjappropriate coding digits. The BOCs and other LECs have reported some technical problems in transmitting  {O#- xpayphonespecific coding digits in certain cases even when FLEX ANI is available for a payphone. In the Bureau  {O$- xCoding Digit Waiver Order we required that LECs indicate which end offices and payphone ANI's are "codingdigit"$D0*&&$"ԫ xxcapable" because of these temporary technical problems. A payphone is "codingdigitcapable" when it is able to  xYtransmit payphonespecific coding digits that are capable of reaching an IXC point of presence (POP) for subscriber  {O - xx800 and access code calls from payphones using 10XXX and 101XXXX. See Bureau Coding Digit Waiver Order  xZat para. 36. For example, according to Bell Atlantic, some tandem switches strip out the FLEX ANI digits when  xtransferring 800/888 calls to the IXCs. Access code calls utilizing the 10XXX access code that are routed through  {Oz- x,this type of tandem would retain the proper coding digit. See Letter to Magalie Roman Salas, Secretary, FCC from  xMarie Breslin, Bell Atlantic (Mar. 3, 1998). Payphones such as those on Nortel switches and those encountering a  xproblem with the tandem should not be included in the divisor. Therefore, it is incumbent on the BOCs to identify  xaccurately the number of payphones that are capable of transmitting the appropriate coding digits to IXCs in the  xdivisor they provide to IXCs for the purpose of calculating the average number of calls per month for BOC dumb payphones. Third, the payor will divide the average number of calls calculated above in step one", E0*&&99"  x(1) by the average number of payphones calculated in step two (2). This division results in the average  xjcall volume per month for BOC dumb payphones that are providing the "27" coding digit (either through  xANI ii, or FLEX ANI). This average number will be the number of calls for which compensation is due  S- x\per month to each LEC payphone that is not capable of providing payphonespecific coding digits.:FX, ڦ yOT-  ԍxIn calculating the amount owed to PSPs perphone for the month of October, the payor may divide the  xmonthly average perphone rate for the month by 31 days and subtract for six days to begin perphone compensation on October 7, 1998.:  S`- x<Lastly, the payor will multiply the average monthly call volume by $0.284 to compute compensation owed  S8- x<per phone per month.G 8L ڦ yO$-  ]ЍxBecause payphone compensation is generally paid quarterly, not monthly, to compute the amount of  x,compensation owed per quarter, the payor needs to multiply the compensation owed per month for each payphone  yO- xby three.#X\  P6G;ɒP# For the sample period, which includes two quarters, the compensation owed per month perphone would be multiplied by six. As discussed above,PH84ڦ {O -ԍxSee supra para. 22.P this data will be used to compensate payphones for the last  xquarter of 1997 and the first quarter of 1998. Thereafter, LEC dumb payphones will be compensated  xkusing this same methodology based on call volume information obtained from BOC dumb payphones  S-during the applicable quarter using three months of data rather than six months of data.TIڦ yO&-  ԍxFor example, compensation due to LEC payphones that are not able to provide payphonespecific coding  xdigits for the second quarter will be based on call volume information obtained from BOC dumb payphones during  xthe second quarter. Therefore, if the BOC PSP received on average 35 calls from a particular payor perphone per  xmonth during the second quarter, then the LEC PSP will receive 35 calls perphone per month for calls originated from its payphones for that quarter.T  0  S-#&a\  P6G;u&P#  Sp- ` ox27. ` ` The LEC Coalition requests that BellSouth dumb payphones be excluded from any call  SH - xvolume calculation, because BellSouth locates dumb payphones in only the lowest call volume locations.JXH vڦ yO^"-  MԍxLetter to Rose M. Crellin, FCC from Michael K. Kellogg, Coalition (Mar. 30, 1998). The LEC Coalition  xYfurther asserts that US West smart payphones have higher volumes than its dumb payphones and that it also locates dumb payphones in areas with lower call volumes and smart payphones in areas with higher call volumes.  xWe decline to adjust call volume calculations to account for the possibility that BellSouth may place dumb" J0*&&99 "  xpayphones only in the lowest call volume locations. We find that different BOCs created different  S- xplacement strategies for their payphones. While BellSouth may have placed dumb payphones in areas  xwith low call volumes, other BOCs likely have placed dumb payphones in high call volume areas, such  xas airports and truckstops. Additionally, the proportion of dumb BOC payphones to smart BOC  xpayphones varies among BOCs. Due to the different placement strategies and the variance among  xypayphone types, call volumes will vary among BOCs. Therefore, omitting what might be the lowest call  xzvolume data from the sample would not lead to an unbiased estimate of BOC payphone call volumes,  xbecause it would artificially leave in the highest remaining data. Also, the LEC Coalition reported that  xja large proportion of the payphones served by LEC Coalition members are already providing payphone x=specific coding digits and that number continues to increase as BOCs continue to implement FLEX ANI  Sp- x[and overcome temporary problems they reported in implementing FLEX ANI.dKpڦ {O -ԍxBureau Coding Digit Waiver Order at para. 65.d Moreover, many other  xpayphones will be paid percall compensation by IXCs. Thus, any negative effect of including BellSouth payphones in the call volume calculations will be temporary and small.  S - pqx` ` c. Independent PSP payphones that are not capable of providing payphonespecific  Q -coding digits(# x` `  SZ- ` x28. ` ` The third category, independent PSP payphones that are not capable of providing  S2- x[payphonespecific coding digits,Lh2Zڦ yO,-  Ѝx#X\  P6G;ɒP#To clarify, payphones that will receive compensation under the mechanism described in this section are  xxindependent payphones that are not capable of providing payphonespecific coding digits and are served by equal  S-access switches#&a\  P6G;u&P#. also will be compensated on a perphone basis as calculated above for  xLLEC payphones that are not capable of providing payphonespecific coding digits. The record indicates  S- xthat many independent PSP payphones cannot transmit the appropriate coding digits at this time.lMڦ {O -ԍxSee Bureau Coding Digit Waiver Order at paras. 5759.l  xZNonetheless, independent PSP payphones should be compensated for calls originated from their payphones  xMin a timely manner. Therefore, perphone compensation for independent PSPs must be based on call  x volumes from BOC dumb payphones that are capable of providing payphonespecific coding digits,  x\because such call volume information is available to each IXC and provides a reasonable surrogate for independent payphone call volumes during the waiver period.  S- ` ` x29. ` ` APCC argues that independent PSPs generate higher call volumes than BOC PSPs, and  S- xtherefore, suggests that the Commission require that independent PSPs be compensated by IXCs based on  xkBOC call volumes multiplied by a factor to reflect the higher call volumes received by independent as  SR- xopposed to LEC payphones.NRڦ {O"-ԍxSee Letter to Mary Beth Richards, FCC from Albert H. Kramer, APCC at 4 (Mar. 5, 1998). MCI argues, however, that independent PSPs should not be compensated  S*- xfor higher call volumes perphone than BOC or LEC payphones.O*ڦ {Ox$-ԍxSee Letter to Magalie Roman Salas, Secretary, FCC from Leonard Sawicki, MCI (Mar. 19, 1998). We decline to increase the average"*@ O0*&&99{"  x=call volumes calculated above from BOC payphone call volumes for independent PSPs' payphones. We  S- xfind that data on the record indicates that the call volumes may be similar.Pڦ {O@-  ЍxSee Report and Order, 11 FCC Rcd at 20,60304, para. 124 (citing ex parte Letter to William Caton, FCC from Michael Kellogg, LEC Coalition (Aug. 23, 1996)). In the Report and Order,  x/the Coalition reported an average of 132 calls per payphone per month. Independent PSPs reported  xvarying call volumes ranging from 124 to 140 compensable calls per payphone per month; the average  Sb- xof which was 131 calls per payphone per month.Q$b"ڦ {O$-  ЍxSee id. The following independent PSPs reported call volumes: Peoples Telephone Company, Inc. (Peoples):  x129 calls; Communications Central, Inc. (Communications Central): 130 calls; Telaleasing Enterprises, Inc.  x(Telaleasing): 124 calls; and APCC: 140 calls. The average of these numbers results in 131 calls perphone per  {O~ -month. Id.  Despite these differences, the Commission established  xone call volume for independent and LEC PSPs, declining to establish the different call volume amounts  xpresented by parties. In adopting a uniform compensation rate, the Commission noted that some  xdifferences may exist among various PSPs, but found that each PSP should receive the same compensation  xamount for subscriber 800 and access code calls. The Commission also sought to allow all competitors  S- x=equal opportunity to compete for essential aspects of the payphone business.NRڦ {OH-ԍxId. at 20,544, para. 3.N We similarly decline to  xestablish separate call volume amounts for the purpose of this limited waiver, and conclude instead that  xwe should not treat the call volumes differently based on ownership characteristics. Although the number  x.of compensable calls may vary over time due to seasonality, location, and other issues, more recent data  S - xon the record still indicates that call volumes from independent PSPs and BOC payphones are similar.S ڦ yO:-  >ԍxMoreover, other independent PSPs, such as Peoples, submitted call volumes in the range of 139 calls per  {O- xpayphone per month, which is less than call volumes realized by some of the BOCs. See Peoples Comments at 6.  {O- xZSome independent PSPs submitted data indicating slightly higher call volumes than some of the BOCs. See, e.g.,  yO- xCommunications Central, Inc. Comments (Aug. 26, 1997) at 8 (157 calls); Telaleasing Comments (Aug. 26, 1997)  xat 2 (163 calls). With regard to the APCC data, MCI argues that APCC's call volumes lack "evidence of statistical  xvalidity." MCI argues that APCC does not discuss how call volume samples were drawn and further how the  xhsamples are representative of all independent PSPs. In addition, MCI argues that there is no explanation of why the  {O- xZnumber of payphones in the sample vary from month to month.  See Letter to Magalie Roman Salas, FCC from  xLeonard Sawicki, MCI (Mar. 19, 1998). We note that although MCI has been tracking calls from independent  xpayphones during the relevant period through the use of LEC ANI lists, MCI declined to place in the record any such information concerning the average number of compensable calls from such payphones.   xFor example, call volume data submitted by the LEC Coalition for three BOCs indicates that call volumes  xranged from 132 to 146 calls per payphone per month during the last quarter of 1997 and part of the first  S - xmquarter of 1998.T ڦ {O(!-ԍxSee Letter to Rose Crellin, FCC from Michael Kellogg, Counsel, Coalition (Mar. 24, 1998). In comparison, independent PSPs submitted data indicating call volumes of  xapproximately 149 calls per payphone per month for approximately the same time period, which indicates  S2- xthat the call volumes are not substantially dissimilar.U2ڦ {Oj$-ԍxSee Letter to Mary Beth Richards, FCC from Albert Kramer, APCC (Mar. 5, 1998). Thus, we decline to adjust BOC perphone average"2*U0*&&99"  xcall volumes IXCs calculate pursuant to the methodology in this waiver order to reflect a multiplier to  S-increase the number of calls perphone paid to independent PSPs.IVf ڦ yO@-  ԍxWe tested whether the call volumes reported by the LEC Coalition were significantly different from the  xindependent payphone providers. In an ex parte letter, the Coalition provided call volumes for three different BOCs.  {O- xSee Letter to Rose M. Crellin, FCC from Michael K. Kellogg (Mar. 27, 1998) (providing the following average call  xvolumes: BOC A: 146.15; BOC B: 131.88; and BOC C: 140.75 calls perphone per month). Four different  {Ob- x-independent PSPs also provided updated call volumes. See Letter to Magalie Roman Salas, Secretary, FCC from  xRobert F. Aldrich, APCC at Attachment (Mar. 26, 1998) (reporting 159 calls); Communications Central (Aug. 1997)   Comments at 8 (reported 157 calls); Peoples (Aug. 1997) Comments at 6 (reporting 139 calls); and Telaleasing (Aug.   K1997) Comments at 2 (reporting 163 calls). We used a standard statistical ttest with a 95% confidence level to   determine if the mean from the LEC Coalition sample of call volumes was different from the sample of call volumes  {OL -  9!provided by independent PSPs. See, e.g., Snedecor & Cochran, Statistical Methods 115 (6th ed. 1976). Given the   variability of the data, we could not conclude that the average number of calls for independent PSPs is significantly different from the average number of calls for BOC PSPs. I  S-x` ` d. Payphone on nonequal access switches x` `  S:- ` Ax30. ` ` The fourth category involves payphones on nonequal access switches. Nonequal access  x<switches do not provide payphonespecific coding digits; therefore, these payphones must be compensated  xon a perphone basis until they are able to provide payphonespecific coding digits. Both IXCs and LECs  xhave indicated that payphones served by nonequal access switches receive lower call volumes than other  S- xpayphones.W  ڦ {O0-  0ЍxSee, e.g., #X\  P6G;ɒP#Letter to Magalie Roman Salas, Secretary, FCC from L. Marie Guillory and R. Scott Reiter,  yO- xNational Telephone Cooperative Association (NTCA) (Jan. 27, 1998; Apr. 3, 1998) (providing call volumes for one  yO- xsmall company in Iowa, with 11 payphones on an equal access switch, averaged 65 calls perphone per month; Letter  xYto Magalie Roman Salas, Secretary, FCC from Keith Townsend, United States Telephone Association (USTA) (Dec.  yOR- xw2, 1997) (stating that small and midsize LECs have an average of 5.6 payphones per switch); MCI Comments at 34  x& n.9 (arguing that most payphones with nonequal access switches are in rural areas and therefore should receive  xwless compensation than other payphones); Letter to Rose M. Crellin, FCC from Michael K. Kellogg, Coalition (Apr.  x2, 1998) (stating that GTE has 289 payphones on 38 nonequal access switches that carry, on average, 14.35 subscriber 800 and access code calls per payphone per month). The data on the record regarding these payphones is limited. GTE indicates that it has a  x?total of 289 payphones on nonequal access switches, which receive an average of 14.35 calls per  SJ - xpayphone per month,VXXJ ڦ yO-  ԍxWe also note that the number of payphones on nonequal access switches is small in comparison to  xpayphones on equal access switches, and moreover, none of the RBOCs continue to use nonequal access switches. Thus, data pertaining to these payphones is limited.V and a small company in Iowa, Heart of Iowa Telecommunications Cooperative,  xwhich maintains 11 payphones, receives an average of 65 calls per payphone per month. Based on this  xMlimited data submitted on the record illustrating that call volumes for payphones on nonequal access  xswitches and switches in rural areas receive substantially less calls than BOC dumb payphones, we  x=conclude that payphones on nonequal access switches cannot be compensated based on the average call  x=volumes for BOC dumb payphones. Accordingly, payors must compensate payphones served by non xequal access switches based on the weighted average of call volumes submitted in this record for  xpayphones served by nonequal access switches and payphones served by rural switches, 16 calls per"2X0*&&99"ԫ S-phone per month.Y ڦ yOh-  zԍxThe weighted average is derived as follows: 289 GTE payphones x 14.35 calls per payphone per month =  x4147.15 total calls. We then determined the total number of calls for the small payphone company in Iowa: 11 x  x65 = 715 calls. Finally, we found the total number of calls to be 4862.15 (4147.15 + 715) and divided that by the total number of payphones (300), which results in an average call volume of 16 calls perphone per month.   S- ` x31. ` ` We expect that parties will submit additional information on the record regarding call  S- x/volumes for nonequal access areas.qZZڦ {O-  ԍxSee, e.g., Letter to Rose Crellin, FCC from Keith Townsend, USTA (Apr. 2, 1998) (stating that within  xYninety (90) days, USTA will develop sufficient data to support development of a compensation scheme under which payphones served by nonequal access end offices can be compensated).q If we receive additional record information on call volumes for  xnonequal access payphones that suggests that call volumes are different than the data upon which we rely  xLherein, we will consider revisions to the compensation methodology for payphones served by nonequal access switches.  S-x` ` e. Payphones served by LECs granted small and midsize LEC waiver  Sr- ` Px32. ` ` In the Bureau Coding Digit Order, we granted a limited waiver to midsize and small LECs  xfor equal access switches where a LEC is unable to recover its costs of implementing FLEX ANI, through  S$ - xa monthly charge for no longer than a 10 year period, from all payphones in its serving area.[Z$ ڦ yO-  Ѝx#X\  P6G;ɒP##K\  P@QɒP#This limited waiver for small and midsize LECs that are not able to recover their costs of implementing  xJFLEX ANI over up to a 10 year period is not available to price cap, CLASS A, and Tier 1 LECs. In 1996, the Class  {O&-A LECs included all price cap LECs. See Bureau Coding Digit Waiver Order at para. 76.  This  xwaiver was specifically granted for small and midsize LECs for which the cost of implementing FLEX  S - xANI would be unreasonably burdensome, despite provisions in the  Bureau Coding Digit Waiver Order  S - xfor cost recovery.\ ڦ {OB-  ԍxFor determining whether a small or midsize LEC qualifies for this waiver, the Bureau Coding Digit Waiver  {O - xOrder provides an analysis that must be performed annually by the LEC. The LEC may assume that the payphone  xYrate element established to recover the cost from all payphones in its serving area over a period not greater than 10  xyears would not be greater than 20% of the national average payphone line cost of $38.90, or $7.78, per line per  {Of-month. #X\  P6G;ɒP#Id.ĕ This waiver was provided for small and midsize LECs with a small number of  xjpayphones per switch. We conclude that payphones served by LECs that would qualify for this waiver  xwill be located predominantly in rural areas and would have lower call volumes than BOC dumb  xypayphones. We conclude that the call volumes for payphones served by these LECs would be similar to  xthose evaluated above for determining the call volume for payphones served by nonequal access switches.  xyIf we receive additional information on the record that indicates different call volumes for LECs that have  xdeferred FLEX ANI implementation pursuant to the small and midsize LEC waiver, we may subsequently  x.require different call volumes for these two categories. Therefore, if payphonespecific coding digits are  xnot available for payphones served by these LECs, IXCs choosing to pay perphone compensation instead  xof percall compensation pursuant to the waiver granted herein for these payphones must pay perphone  xcompensation as described above for payphones served by nonequal access switches until payphone"\0*&&995"ԫspecific coding digits are available for these small and midsized LEC payphones.  S-x3.` ` Alternative Compensation Methodologies  S`- ` x 33. ` ` We decline to adopt, as some parties recommend, the flatrate interim compensation  S8- xapproach set forth in the Payphone Orders, which required IXCs with annual toll revenues in excess of  x$100 million to pay, collectively, a flatrate interim compensation amount of $45.85 per payphone per  S- xmonth, in shares proportionate to their share of total market long distance revenues.] ڦ {OR-  Ѝx#X\  P6G;ɒP##X\  P6G;ɒP#See id. AT&T argues that the number of calls established for the interim flatrate period should be applied  xwfor determining compensation for the waiver period. Thus, AT&T opposes APCC's and the LEC Coalition's request  {O - xthat the Commission use the number of calls adopted in the Second Report and Order to determine the number of  {O - xcalls for which compensation is due during the waiver period.  See AT&T Reply at 8. AT&T also opposes the  x;following: requiring that payments be made monthly; that there be provisional payments and two trueups; and that  {O@ - x,perphone compensation during the waiver period be limited to subscriber 800 calls.  See AT&T Reply at 9. APCC  xsupports a waiver to allow IXCs to continue paying compensation on a flatrate basis. APCC argues, however, that  xwthe Commission should condition the IXC waivers on monthly compensation payments. APCC argues that the flat xrate should be provisional subject to trueup and based on the current estimate of 159 average calls. APCC argues  xthat payors should be IXCs over $100 million annual revenue. As an alternative APCC suggests that the Commission  xrequire IXCs as a condition of waivers to report their annual service revenue to the Commission to be the basis of  x,the provisional compensation allocation. APCC recommends that the flatrate waiver apply to all dumb payphone  {O- xwlines that do not transmit payphonespecific coding digits. See Letter to Magalie Roman Salas, Secretary, FCC from  yO-Albert Kramer, APCC (Mar. 26, 1998).#&a\  P6G;u&P# In Illinois Public  S- x 3'Standard - Dup Short3'Standard - Dup ShortRS]\ 3'Standard - Dup Short3'Standard - Dup ShortRS]\ *   Telecomm., the court vacated the Commission's flatrate interim compensation plan stating that the  x Commission did not justify basing flatrate compensation on total toll revenues, and therefore, acted  x.arbitrarily and capriciously by only requiring payments from the largest IXCs. The court further stated  xthat the Commission had not shown a nexus between toll revenues and the number of access code and  S& - xsubscriber 800 calls a particular carrier carries.^&  {OP-ԍx#K\  P@QɒP#Illinois Public Telecomm., 117 F.3d at 565.#&a\  P6G;u&P#Ѷ Moreover, even if we were to base payphone  S - x=compensation on toll revenues, we note that we cannot address the court's concern that the Commission  xacted arbitrarily by only requiring payments from the largest IXCs, because the Commission does not  S -maintain adequate data for those carriers with annual toll revenues under $100 million._  {Oj-ԍx#K\  P@QɒP#Remand Notice at 4.#&S\  P@Qu&P#ј  S^- ` x!34. ` ` We also decline to adopt the method for perphone compensation suggested by the LEC  xCoalition. The LEC Coalition provided the Commission with aggregated call volume and distribution data  xfor subscriber 800 and access code calls transmitted from dumb and smart payphones owned by three  xBOCs"US West, Bell Atlantic South, and Pacific Bell"that the LEC Coalition states comprise  S- xapproximately 20 percent of the nation's total payphones.` {O #-ԍxSee Letter to Rose Crellin, FCC from Michael K. Kellogg, LEC Coalition at 2 (Mar. 27, 1998). The LEC Coalition argues that those carriers  xunable to pay per-call compensation and who have filed timely waivers with the Commission should pay  xper-phone compensation based on the call volume and distribution data supplied by the LEC Coalition. "n@`0*&&99s"  xAlternatively, the LEC Coalition argues that the Commission could use the call volume data to allocate  xthe shares of, for example, the ten to fifteen largest carriers, and require the remainder of the carriers to  x0pay per-call compensation. The LEC Coalition recognizes, however, that the data may not be as  xappropriate for smaller carriers, who could face "disproportionate burdens because the data submitted are  S`- x/not comprehensive."Ha`` yO-   ԍxThe call volumes and distribution for the top ten carriers by call volumes reported by the LEC Coalition  xare as follows: (1) AT&T: average calls per station per month 52.32; percentage of average calls per month total:  x37.08%; (2) MCI: average calls per station per month 35.74; percentage of average calls per month total 25.33%;  x;(3) WorldCom: average calls per station per month 17.17; percentage of average calls per month total 12.17%; (4)  xKSprint: average calls per station per month 15.18; percentage of average calls per month total 10.76%; (6) LCI:  xaverage calls per station per month 3.99; percentage of average calls per month 2.83%; (7) Frontier: average calls  xper station per month 3.89; percentage of average calls per month 2.83%; (8) BOC weighted average: average calls  xper station per month 3.09; percentage of average calls per month 2.75%; (9) Allnet Dial 1 Service: average calls  x,per station per month 1.60; percentage of average calls per month 1.14%; and (10) Cable & Wireless: average calls  {O -per station per month 1.33; percentage of average calls per month 0.95%. Id. at 3.H We decline to use this information as an approach for determining perphone  xcompensation because it may not be representative of all BOCs, may reflect regional variations, and  xprovides insufficient information to establish perphone call volumes for small carriers, one of the grounds  S- x=identified by the court for vacating the allocation method used in the Report and Order that was vacated  xby the court. For the above reasons, we find that allowing IXCs to pay compensation in accordance with  xthe methodology set forth in the waiver is preferable and more closely approximates the real obligations  xof individual IXCs to pay percall compensation. We note, however, that the information provided by the  x LEC Coalition may be useful to IXCs and PSPs in considering mutually agreeable alternate payment amounts or arrangements.  S - ` x"35. ` ` We also conclude that a retroactive adjustment of payphone compensation for the period  S - xcovered by the Bureau Waiver Order and the Bureau Coding Digit Waiver Order is not necessary. In the  S - xBureau Coding Digit Waiver Order, the Bureau stated that because LECs and IXCs have identified  xproblems in transmitting and receiving payphonespecific coding digits, a retroactive adjustment of  S6- xpayphone compensation may be necessary for the waiver periods granted in the Bureau Waiver Order and  S- xthe Bureau Coding Digit Waiver Order.&bb ` {O-  ԍx#K\  P@QP#See Natural Gas Clearinghouse v. FERC, 965 F.2d 1066, 107375 (D.C. Cir. 1992); Public Utils. Comm'n  {O-of California v. FERC, 988 F.2d 154, 16263 (D.C. Cir. 1993).& In this order we do not provide for a retroactive adjustment  xjbecause we conclude that the methodology we have adopted to provide fair compensation through a per x[phone mechanism reasonably approximates call volumes for PSP payphones. Because the court vacated  S- xour approach set forth in the Report and Order for setting perphone compensation, and parties in this  xproceeding have not provided more specific information on the record that we could use to develop an  xMalternative method of estimating average call volumes, we have reasonably concluded that on average,  x-BOC dumb payphone call volumes calculated as described herein provide fair compensation for payphones  xthat are unable to provide payphonespecific coding digits to enable IXCs to track calls on a percall basis.  x/Moreover, we do not provide for a retroactive adjustment because the alternative proposed methods  xsuggested by parties for a retroactive adjustment are not based on actual information from the relevant  xperiods, and thus, would not provide a more valid call volume surrogate than the method we adopt herein.  xWe note that there is wide variation in payphone call volumes due to such factors as location of the"\ b0*&&99|"  xpayphone and the month for which volumes are counted. Percall compensation, once it is totally in place,  xwill respond to those variations. In the meantime, while PSPs, IXCs, and LECs are transitioning to the  x!new percall environment, and finding temporary problems in transitioning, we conclude that the  x[methodology we describe herein is equitable and will ensure that payphone compensation to PSPs is not further delayed.  S-x4.` ` Miscellaneous x  S- ` x#36. ` ` We decline to require, as USTA requests, that LECs be compensated for all blocked calls  xbecause blocked calls are the result of IXCs using FLEX ANI or LIDB for fraud detection, pursuant to  Sp- xiCC Docket No. 9135.cp` yO -ԍx#X\  P6G;P#USTA Reply at 78.#&a\  P6G;&P#ё In the Report and Order, the Commission concluded that payphone compensation  SJ - xwas due for completed calls.dJ X` {OB -ԍx#X\  P6G;P#Report and Order, 11 FCC Rcd at 20,573, para. 63.#&a\  P6G;&P#Ѷ The Commission defined a completed call as a call answered by the called  S" - xparty. Because a blocked call is by definition not a completed call, the Payphone Orders do not require such compensation.  S - ` Qx$37. ` ` The LEC Coalition and USTA request that any waiver granted in response to AT&T's  xNrequest should be granted only after IXCs have paid interim compensation and only to IXCs that  S\- xdemonstrate that they cannot track compensable calls using LEC ANI lists.e\` {O-ԍx#X\  P6G;P#See USTA Reply at 8; see also LEC Coalition Comments at 4. We decline to adopt this  xapproach. Interim compensation requirements will be addressed in a separate, subsequent Commission  x.order. In this order, we grant a waiver to AT&T and other similarly situated carriers, conditioned upon  xcomplying with the compensation methodology set forth herein, which provides perphone payphone  xcompensation for payphones unable to provide payphonespecific coding digits. We grant this waiver to  S- xensure that PSPs receive payphone compensation during the waiver periods we granted in the Bureau  Sn- x[Waiver Order and Bureau Coding Digit Waiver Order. Moreover, we allow IXCs to pay either percall  xor perphone compensation when payphonespecific coding digits are not available because of the different  S -tracking capabilities and network configurations described by the IXCs.f |` {O<-  ЍxSee e.g., AT&T Letter at 13; Letter to Magalie Roman Salas, Secretary, FCC from Richard S. Whitt, WorldCom (Mar. 5, 1998).  S- ` x%38.` ` APCC requests that we clarify the obligations of facilitiesbased IXCs who provide 800  xjservice to disclose information about switchbased resellers who provide 800 number service resold from  xthe facilities based carriers so that PSPs can identify who they should bill for payphone compensation.  xzAPCC indicates that its members are unable to identify the switchbased reseller to bill for payphone  xLcompensation. The Telecommunications Resellers Association (TRA) opposes APCC's request arguing  S- xthat it is unnecessary and burdens IXCs.g` {O~$-ԍxSee Letter to Magalie Roman Salas, Secretary, FCC from Charles C. Hunter, TRA (Mar. 31, 1998). In the Report and Order, the Commission acknowledged that"h g0*&&99\"  xtelecommunications services are sold in advance, particularly in the debit card context, and resold to other  xycarriers, thus making it difficult in those situations to identify the carrier liable for percall compensation.  xThe Commission also stated that facilitiesbased carriers may recover the expense of payphone percall  S- xcompensation from their reseller customers. As clarified in the Order on Reconsideration, switchedbased  Sb- xresellers are responsible for paying percall compensation.phb` {O-ԍxOrder on Reconsideration, 11 FCC Rcd at 21,277, para. 92.p When facilitiesbased IXCs providing 800  xservice have determined that they are not required to pay compensation on particular 800 number calls  x/because their switchbased resale customers have identified themselves as responsible for paying the  xcompensation, the facilitiesbased carriers must cooperate with PSPs seeking to bill for resold services.  xThus, a facilitiesbased carrier must indicate, on request by the billing PSP, whether it is paying percall  x\compensation for a particular 800 number. If it is not, then it must identify the switchbased reseller  xresponsible for paying payphone compensation for that particular 800 number. Facilitiesbased IXCs and  xswitchedbased resellers may not avoid compensating PSPs by withholding the name of the carrier  S" - xresponsible for paying percall compensation, thereby avoiding the requirements of the Payphone Orders and Section 276.  S -  IV. CONCLUSION AND ORDERING CLAUSES ĐTP  S\- ` x&39. ` ` For the foregoing reasons, we grant in part AT&T's letter request to pay perphone  xcompensation to PSPs where payphonespecific coding digits are not available. We find that allowing  xAT&T and other similarly situated IXCs to pay perphone instead of percall compensation based on the  xmethodology set forth above, is in the public interest, because it will further the goals of Section 276 of  x=the Act, that PSPs be compensated for each and every completed call and will ease the transition to percall compensation.  SD- ` Px'40. ` ` Accordingly, pursuant to authority contained in Sections 1, 4, 201205, 218, 226, and 276  xzof the Communications Act of 1934, as amended, 47 U.S.C.  151, 154, 201205, 218, 226, and 276, that the policies and requirements set forth herein ARE ADOPTED.  S- ` Rx(41. ` ` IT IS FURTHER ORDERED that this Order is effective immediately upon release  S|-thereof.i|Z` {Ov-ԍxWe find that good cause exists for these waivers to be effective immediately.  See supra para. 4.  S,- ` x)42. ` ` IT IS FURTHER ORDERED that AT&T's letter request to pay on a perphone instead  S-of a percall basis IS GRANTED to the extent described herein and is otherwise DENIED. 0 x` `  hh@hA. Richard Metzger, Jr.  S -x` `  hh@hChief, Common Carrier Bureau #&a\  P6G;&P#