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First, we deny the petition for reconsideration of our Interim Waiver Order filed February 10, 1995 by the Information Technology Association of America (ITAA). The Interim Waiver Order granted a limited interim waiver of the Commission's Computer III rules to permit the regional Bell Operating Companies (BOCs) to continue offering certain existing enhanced services on an integrated basis after the Ninth Circuit vacated in part the BOC Safeguards Order in California III. 2. Second, we consider 12 new Comparably Efficient Interconnection (CEI) plans and 13 CEI plan amendments submitted by the BOCs regarding existing enhanced services. The BOCs filed these CEI plans and amendments on March 13, 1995 pursuant to the Interim Waiver Order, and subsequently supplemented their plans and amendments in response to discussions with Common Carrier Bureau (Bureau) staff. As discussed in greater detail below, in the Interim Waiver Order we required the BOCs to file CEI plans for enhanced services they were providing on an integrated basis for which a CEI plan had not been previously approved. Because we have determined that the CEI plans and amendments submitted by each of the BOCs, as clarified and amended by their ex parte filings, satisfy the CEI requirements set out in the Computer III Phase I Order, we hereby approve all of the referenced CEI plans and amendments. II. BACKGROUND A. Computer II and Computer III Regulatory Framework 3. Under Computer II, the BOCs were only permitted to provide enhanced services through a structurally separate subsidiary. In its Computer III decisions, the Commission permitted the BOCs to integrate their enhanced service and basic service offerings provided that they complied with certain nonstructural safeguards, including Comparably Efficient Interconnection (CEI) requirements. In the first stage of implementing Computer III, the Commission required the BOCs to obtain Commission approval for service-specific CEI plans prior to offering individual enhanced services on an integrated basis. In these CEI plans, the Commission required the BOCs to demonstrate how they would provide competing enhanced service providers (ESPs) with "equal access" to all basic underlying network services the BOCs used to provide their own enhanced services. During the second stage of Computer III, the BOCs developed and implemented Open Network Architecture (ONA) plans detailing the unbundling of basic network services; after the Commission approved these ONA plans and the BOCs filed tariffs for ONA services, they were permitted to provide integrated enhanced services without filing service-specific CEI plans. ONA incorporates and subsumes CEI "equal access" requirements and provides for the further unbundling of network service elements not limited to those associated with specific BOC enhanced services. After the implementation of ONA, the BOCs were still required to offer network services to competing ESPs on a CEI "equal access" basis, even though they were no longer required to file a CEI plan for each service they wished to offer. 4. Between 1988 and 1992, the BOCs collectively received approval for 29 CEI plans. The BOCs filed ONA plans and amendments between 1988 and 1992; in 1992 and 1993, the Common Carrier Bureau lifted structural separation requirements after each BOC demonstrated that its ONA plan complied with the BOC Safeguards Order. The Commission affirmed these decisions by the Bureau. B. The Ninth Circuit's California Decisions 5. The Computer III regime was first vacated in 1990 by the Ninth Circuit in the California I decision. The court concluded that the Commission had not explained why accounting safeguards would be effective in preventing the BOCs from cross-subsidizing of their enhanced service offerings with their regulated services, but approved the Commission's safeguards against access discrimination, including CEI and ONA requirements. Following California I, the Bureau recognized that the effect of California I was to reinstate the Computer II regulatory regime. The Bureau granted the BOCs a waiver of Computer II's separate subsidiary requirement in order to allow them to continue to provide enhanced services on an integrated basis. Subsequently, the Commission adopted the BOC Safeguards Order, which strengthened the accounting standards criticized in California I and again concluded that structural separation requirements should be fully eliminated once BOC ONA plans were approved and implemented. 6. In California II, the Ninth Circuit reviewed a series of Commission orders approving ONA plans. The court concluded that the orders under consideration constituted a retreat from the policy announced in Computer III because they advanced the view that structural separation could be lifted before implementation of a fully realized ONA. Because the orders under review did not themselves eliminate structural separation, however, the court upheld the Commission orders approving the BOC ONA plans and did not reach the question of whether the noted change in policy had been adequately explained. 7. This issue was presented in the Ninth Circuit's review of the BOC Safeguards Order. In California III, the court determined that although the Commission had adequately explained its decision to strengthen the protections against cross-subsidization at issue in California I, it had not justified its retreat from its position that "fundamental unbundling" was a prerequisite for eliminating structural separation. The court concluded that because the Commission had failed to explain its decision to lift structural separation without fundamental unbundling as a safeguard against access discrimination, the cost-benefit analysis adopted by the BOC Safeguards Order was flawed and must be set aside as arbitrary and capricious under the Administrative Procedures Act (APA). 8. Following the California III decision, the Bureau issued the Interim Waiver Order, the provisions of which are outlined in the next section. On February 21, 1995, the Commission issued a Notice of Proposed Rulemaking (NPRM) for the Computer III further remand proceedings. In that NPRM, the Commission noted that the Bureau had adopted the Interim Waiver Order and did not modify the interim structure specified by the Bureau. C. The Provisions of the Interim Waiver Order 9. On January 11, 1995, the Bureau released an order granting the BOCs, during the pendency of the Commission's Computer III remand proceedings, any waivers necessary to allow them to continue to provide certain existing enhanced services on an integrated basis, provided that they filed CEI plans pursuant to the regime in effect prior to the lifting of the structural separation requirements. Under the Interim Waiver Order, Computer III waivers are required only for enhanced services provided subject to approved CEI plans requiring amendments, new existing enhanced services being provided without approved CEI plans, and existing market trials provided without market trial notifications. Thus, the BOCs did not need Computer III waivers to continue to provide existing enhanced services for which a CEI plan had previously been approved. 10. If the basic services underlying the enhanced services had changed since the initial CEI plans were approved, or if there had been significant changes to the enhanced services themselves, we required the BOCs to file amendments to the affected CEI plans within 60 days of the January 11, 1995 release of the Interim Waiver Order. We also required the BOCs to file on the same date CEI plans for all existing enhanced services not covered by approved CEI plans (for example, enhanced services that the BOCs had begun providing after 1991, under ONA). These new CEI plans and CEI plan amendments are in part the subject of the current order. 11. The BOCs may not begin providing any new enhanced services after the effective date of the Interim Waiver Order without first receiving Commission approval for a corresponding CEI plan. In addition, we required BOCs to file market trial notifications pursuant to the BOC Market Trial Order for any market trials that were underway on the effective date of the Interim Waiver Order, as well as for all market trials to be conducted during the pendency of the Computer III Further Remand Proceedings. III. PETITION FOR RECONSIDERATION OF THE INTERIM WAIVER ORDER A. ITAA Petition 12. ITAA asserts that in issuing the Interim Waiver Order, the Bureau erred in continuing to rely on the Computer III rules, which it claims have been vacated by California III. Specifically, ITAA asserts that the Bureau erroneously reinstated the CEI regulatory regime for enhanced services, because in the remand proceedings following California I, the Commission specifically reinstated ONA, not CEI. 13. ITAA argues that California III expressly struck down the Commission's continued reliance on CEI and ONA in the BOC Safeguards Order. ITAA states that the court specifically found CEI to be ineffective because "competitors who otherwise would be able to compete effectively by offering more efficient packages of services had fundamental unbundling been accomplished might be excluded from the market entirely." ITAA also states that the court found that CEI "safeguards are not a substitute for ONA and, without ONA, are not adequate to prevent access discrimination." Thus, ITAA argues that CEI cannot be maintained as an interim measure for preventing access discrimination, because the California III decision has vacated the "better" ONA regime to which CEI was supposed to lead. ITAA further states that the court vacated the BOC Safeguards Order because of the Commission's "flawed" reliance on CEI and ONA to prevent access discrimination and to justify the lifting of structural separation. 14. ITAA argues that since the Commission did not reinstate either CEI or ONA subsequent to California III, the Bureau had no authority to grant the BOCs a waiver based on the Computer III regime reinstated by the BOC Safeguards Order. ITAA further argues that the Bureau improperly readopted the Computer III regime on delegated authority, without prior notice and comment. ITAA asserts that to permit the BOCs to continue to provide enhanced services on an integrated basis, the Bureau must grant them a waiver of Computer II. ITAA further states that the Bureau's incorporation of a limited waiver of Computer II within the Interim Waiver Order indicates that the Bureau recognized that it had exceeded its authority in basing the Interim Waiver Order on Computer III. 15. ITAA also claims that the Bureau should have restricted the scope of the Interim Waiver Order in several ways. First, ITAA states that the waiver should apply only to those enhanced services that the BOCs were offering on the date of the Ninth Circuit's decision (October 18, 1994). Second, ITAA states the waiver should not permit the BOCs to conduct enhanced service research, planning, development, technology tests or market trials inconsistent with Computer II rules. Third, ITAA asserts that the waiver should be limited in duration, lasting only until the BOCs file, and the Commission approves, service-specific waivers for each of the enhanced services currently offered on an unseparated basis. B. Pleadings 16. Prodigy Services Company (Prodigy) filed comments in support of ITAA's petition for reconsideration, and MCI Telecommunications Corporation (MCI) filed a reply in support of the petition. Prodigy argues that the Bureau erred in relying on CEI to grant structural separation relief, because CEI was never intended to be more than an interim measure pending implementation of full open network architecture (ONA). Prodigy further asserts that the Bureau's re-adoption of CEI in the Interim Waiver Order may prejudice the cost-benefit analysis conducted by the Bureau in conjunction with the Computer III Further Remand Proceedings. Specifically, Prodigy contends that the Computer III Remand Proceedings NPRM suggests that the Commission's cost-benefit analysis must include transition costs attributable to implementation of structural separation for BOCs now providing enhanced services on an unseparated basis. Prodigy argues that the BOCs' reliance on non-final orders of the Commission to remove or fail to implement structural separation represents a freely chosen business risk that should not affect the Commission's public interest analysis. 17. MCI argues that California III struck down all forms of structural relief granted to the BOCs by the BOC Safeguards Order, including service-specific relief based on CEI plans, and returned the industry to a Computer II regime. Specifically, MCI argues that CEI is an element of ONA, and therefore, no distinguishable "CEI plan regime" exists apart from the ONA regime vacated by the California III decision. Citing the Memory Call order, which involved a complaint of access discrimination related to an enhanced service provided pursuant to an approved CEI plan, MCI argues that the CEI plan regime failed to eliminate the BOCs' incentive to engage in anticompetitive behavior. MCI asserts that the only portions of the BOC Safeguards Order that survive California III are those implementing Customer Proprietary Network Information (CPNI) rules and preempting state regulations. 18. MCI contends that since California III reinstated the Computer II rules, the BOCs must provide their enhanced services on a fully structurally separated basis unless they meet the strict standard for a waiver of the Computer II structural separation requirements, which MCI asserts the BOCs have failed to do. To meet this standard, MCI argues, the BOCs must demonstrate that similar services are not available from other enhanced services providers (ESPs) and could not be made available by other ESPs even if these ESPs had reasonably priced, nondiscriminatory access to BOC network features. 19. The Bell Operating Companies jointly oppose ITAA's petition for reconsideration. The BOCs argue that ITAA is incorrect in arguing that the Bureau erred in failing to evaluate the BOCs' Joint Petition as a request for waiver of the Computer II rules. The BOCs point out that although the Bureau determined that California III had returned the regulation of BOC enhanced services to a Computer III service-specific CEI regime, it also granted the BOCs a limited waiver of Computer II, to the extent that such a waiver would be regarded as necessary to permit the BOCs to continue to provide enhanced services on an integrated basis. The BOCs further assert that they were entitled to the relief sought by their joint petition even under a Computer II waiver standard, and that their petition contained sufficient evidence of good cause and public interest to grant such a waiver. 20. The BOCs also argue that the California III decision focused only on the adequacy of ONA as a safeguard for full structural relief. The BOCs note that the BOC Safeguard Order, which specifically provided that BOCs may file CEI plans and CEI waivers prior to full removal of structural separation, reinstated the CEI plan regime. The BOCs state that the court recognized the interim nature of CEI and approved it as a service-specific safeguard. The BOCs go on to assert that the court viewed the CEI plan regime as more than adequate to guard against any potential BOC interconnection discrimination during the interim period prior to full structural relief. The BOCs state that the Interim Waiver Order did not reimplement full structural relief, but rather returned the BOCs to the earlier, interim CEI plan regulatory regime, which they argue the California III court looked upon with favor. 21. Further, the BOCs argue that adoption of the Interim Waiver Order was within the Bureau's delegated authority. Contrary to ITAA's assertions, the BOCs state that the Interim Waiver Order did not readopt the entire Computer III regime, without notice and comment, but rather constituted purely interim relief, pending the Commission's final action on remand. C. Discussion 22. Upon reconsideration, we decline to reverse the conclusions that we reached when we issued the Interim Waiver Order. In that order, we concluded that in California III, the court had remanded only the portion of the BOC Safeguards Order that lifted all structural separation requirements, based on its determination that the Commission had not adequately explained its reliance on ONA plans that did not provide for "fundamental unbundling" of the BOC networks, as contemplated by the Computer III Phase I Order. Neither ITAA nor the other commenters raise any significant new arguments in support of ITAA's reconsideration petition that we have not previously addressed in the Interim Waiver Order. Thus, we reaffirm our earlier conclusion that California III returned the regulation of enhanced services not to a Computer II structural separation regime, but rather to a Computer III service-specific CEI plan regime, whereby BOCs may provide specific enhanced services on an integrated basis, pursuant to approved CEI plans. 23. In the Interim Waiver Order, we determined that the Ninth Circuit had upheld much of the BOC Safeguards Order, including the Commission's findings that the strengthened cost accounting provisions contained within the nonstructural safeguards regime adequately prevented improper cross-subsidization of enhanced services by the BOCs. We noted that the court had reaffirmed its earlier determination that the Commission had justified the use of nonstructural safeguards such as ONA to prevent the BOCs from providing ESPs with inferior access to basic network services. The court acknowledged that as an interim measure until ONA was implemented, CEI plans "ensured that enhanced services competitors were provided with interconnections with the BOCs' own networks that were substantially equivalent to the interconnections that the BOCs provided for their own services." 24. Our conclusion in the Interim Waiver Order that California III returned integrated provision of enhanced services by the BOCs to a service-specific CEI plan regime contrasts with our determination, following California I, that the court's action had returned the Commission and the industry to a Computer II regime. This distinction stems from the different bases for the two decisions. In California I, the court determined that although the Commission had made a plausible showing that CEI and ONA in combination would be effective in reducing the risk of access discrimination, it had not shown adequate justification for its decision to abandon structural separation and rely exclusively on cost accounting regulations to protect against cross-subsidization. Because both the CEI plan and ONA regimes relied upon the cost accounting regulations criticized by the California I court, it followed that both regimes were vacated by that decision. In contrast, in California III the court determined that the Commission had first approved ONA plans which failed to provide for "fundamental unbundling" and then completely lifted structural separation requirements for the BOCs, without adequately justifying this change in policy. This determination did not implicate the interim, service-specific CEI regime, and accordingly it was appropriate for us to conclude that the decision's effect was to return regulation of enhanced services to the interim CEI plan regime. 25. We hereby reaffirm our Interim Waiver Order conclusion that the California III court did not vacate the service-specific CEI plan regime. According to the court, the Commission had found in the original Computer III Phase I Order that "fundamental unbundling" was necessary to protect against access discrimination in the absence of general structural separation requirements. The court recognized, however, that under the Commission's interim CEI regime, "the BOCs could provide integrated enhanced services pending the unbundling of the networks" pursuant to individually approved CEI plans that ensured that the interconnections provided to competitors were "substantially equivalent" to those the BOCs provided themselves. In contrast, ONA was supposed to give competing ESPs the ability to "pick and choose" network service elements not used by the BOCs in providing their own enhanced services. 26. ITAA and MCI have taken the court's statements out of context by arguing that the court found CEI to be inadequate to prevent access discrimination. The court did not indicate that CEI is an insufficient basis on which to lift structural separation requirements with respect to specific enhanced services, but rather that, standing alone, CEI is an insufficient basis for an across-the-board roll-back of the structural separation requirements. The Interim Waiver Order did not attempt to lift structural separation completely based solely on CEI plan requirements, but established a temporary mechanism that permitted BOCs to continue to provide certain existing enhanced services on an integrated basis pending a decision in the remand proceedings. Thus, not only must BOCs file CEI plans pertaining to all existing enhanced services, but they must also continue to comply with the procedures established in their approved ONA plans, because these ONA requirements continue to apply whether or not the BOCs have been relieved of structural separation requirements. The BOCs must also continue to comply with other safeguards against access discrimination, including CPNI rules, nondiscrimination reporting requirements, and network information disclosure rules. 27. The courts have upheld an agency's authority to adopt interim measures to prevent industry disruption after agency rules have been vacated, and have permitted these interim measures to remain in effect throughout the pendency of remand proceedings. Contrary to ITAA's assertions, we have authority to adopt such interim measures without notice and comment, especially when such measures are not new rules, but waivers of our existing rules. Because we conclude that California III's partial vacation of the BOC Safeguards Order generally reinstated the Computer III service-specific CEI plan regime, augmented by the implementation of ONA under the approved BOC ONA plans, our Interim Waiver Order properly required the BOCs to file CEI plans for the integrated provision of enhanced services. We note that during a previous vacation of the Computer III rules, after concluding that the regulatory framework had been returned to a Computer II regime, we required the BOCs to provide enhanced services on an interim basis pursuant to previously approved CEI plans. The California III court acknowledged our prior interim waiver order, and did not criticize the approach that we followed. 28. Because California III returned regulation of BOC-provided enhanced services to a service-specific CEI regime, we were correct in issuing the BOCs a waiver of Computer III, rather than Computer II, rules in order to continue to provide such services, and we employed the proper waiver standard in so doing. We determined that the BOCs had been providing some enhanced services on an integrated basis for more than six years, and that it would not be feasible for them to separate fully the provision of such services immediately. Further, we determined that grant of a waiver would avoid severe confusion and disruption, since, absent a waiver, the BOCs would be forced to suspend provision of services to more than five million existing subscribers, and to deny services to others who had made business plans contingent upon the availability of such services. We determined, moreover, that absent a waiver, the BOCs would be required to incur significant costs on an interim basis in connection with relocating enhanced equipment and other facilities, hiring new personnel, and duplicating certain operational systems. We conclude now, as we did then, that it makes little sense to mandate such significant expenditures and disruption in the context of an interim going-forward measure, especially because the remand proceedings may result in a readoption of structural relief. 29. We reject MCI's contention that we must employ a different standard in granting this waiver, or that the BOCs must demonstrate that customers would be unable to obtain similar enhanced services from competing ESPs. As we noted, the current Interim Waiver Order is similar to the BOC 1990 Interim Waiver Order, which was not challenged before the Commission or in court. Moreover, the arguments in favor of granting a waiver are stronger today than they were in 1990, in that the BOCs are now subject to both CEI and ONA requirements, as well as other safeguards against anticompetitive conduct, and the number of BOC-provided enhanced service subscribers has increased thirtyfold. Thus, in accordance with a prior Commission determination which had been affirmed by the Ninth Circuit, we concluded in the Interim Waiver Order that BOC provision of integrated enhanced services provides significant public interest benefits that outweigh the potential harm to competitors and ratepayers from continuing integrated provision of such services on an interim basis. 30. For the reasons outlined above, we reaffirm our conclusion that California III did not reinstate the Computer II regime. Thus, we were correct in rejecting the argument that a Computer II waiver is required in order to permit the BOCs to continue to provide enhanced services on an integrated basis. Despite this conclusion, in the alternative we granted the BOCs a limited waiver of the Computer II structural separation requirements, based on the same public interest determination that we made in granting the Computer III waiver contained in the order. To the extent that commenters argue that we are required to issue a waiver of Computer II to allow the BOCs to provide enhanced services on an integrated basis pending the remand proceedings, we have done precisely that. 31. We reject ITAA's claims that we should have restricted the scope of the Interim Waiver Order, applying it only to services offered as of October 18, 1994, and refusing to permit market or technical trials or research and development. The restrictions advocated by ITAA are based on restrictions associated with the BOC 1990 Interim Waiver Order, which followed the Ninth Circuit's determination that the existing cost accounting standards were insufficient protection against cross-subsidization. Since the California III court determined that the strengthened accounting safeguards adopted by the Commission in the BOC Safeguards Order provide adequate protection against improper cross-subsidization, it is unnecessary to limit the current Interim Waiver Order in exactly the same manner as its predecessor. Further, as we noted in the Interim Waiver Order, the possibility of access discrimination in integrated research and development activities is minimal. In addition, we recognized that failure to include research and development activities within the Interim Waiver Order would lead to significant delay and might halt the deployment of new services beneficial to the public. 32. We reject MCI's contention that the Memorycall case demonstrates that the service-specific CEI plan regime is an inadequate safeguard against access discrimination. The conduct complained of in Memorycall took place before ONA plans had been fully implemented by the BOCs. Under the framework established by the Interim Waiver Order, BOCs must not only file CEI plans for specific enhanced services they wish to provide, but must also comply with their ONA plans. We are convinced that this temporary framework is sufficient to deter conduct similar to the Memorycall situation until the Computer III Further Remand Proceedings are concluded. To the extent that MCI wishes to argue that our system of nonstructural safeguards is insufficient on a permanent basis to protect against Memorycall-type offenses, this is a matter to be considered in the rulemaking proceeding. 33. Finally, we reject Prodigy's contention that the issuance of the Interim Waiver Order may somehow prejudice the cost-benefit analysis we are conducting in conjunction with the Computer III Remand Proceedings. The Interim Waiver Order has no bearing on any final conclusions that the Commission may reach with respect to the propriety of structural relief or structural separation, but rather merely establishes the framework within which BOC provision of enhanced services will take place until such a decision is made. To the extent that Prodigy believes that transition costs for BOC implementation of structural separation are not an appropriate consideration for the Computer III remand cost-benefit analysis, that proceeding is the appropriate forum in which to raise this concern. 34. In sum, upon review of the petition and pleadings submitted in support thereof, we conclude that there is no basis upon which to grant a reconsideration of the Interim Waiver Order. Therefore, we deny ITAA's petition for reconsideration of the order. IV. BOC CEI PLANS AND AMENDMENTS We affirmed in the preceding section our Interim Waiver Order that provides for the return of regulation of BOC-provided enhanced services to a service-specific CEI plan regime. In the following section, we outline our CEI plan requirements, and then proceed to review and approve the 12 new CEI plans and 13 new CEI plan amendments filed by the BOCs pursuant to the Interim Waiver Order. A. CEI Plan Requirements 1. "Equal Access" Parameters 35. In a CEI plan, a BOC must describe how it intends to comply with the CEI "equal access" parameters for the specific enhanced service it intends to offer. The CEI equal access parameters, discussed in greater detail below, include: interface functionality; unbundling of basic services; resale; technical characteristics; installation, maintenance and repair; end user access; CEI availability; minimization of transport costs; and availability to all interested customers or ESPs. 36. Unbundling of Basic Services: This parameter requires the carrier to unbundle, and associate with a specific rate element in the tariff, the basic services and basic service functions that underlie the carrier's enhanced service offering. Nonproprietary information used by the carrier in providing the unbundled basic services must be made available as part of CEI. In addition, any options available to a carrier in the provision of such basic services or functions must be included in the unbundled offerings. 37. Interface Functionality: This parameter requires the carrier to "make available standardized hardware and software interfaces that are able to support transmission, switching, and signalling functions identical to those utilized in the enhanced service provided by the carrier." 38. Resale: This parameter requires the "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anti-competitive pricing in unregulated markets." 39. Technical Characteristics: This parameter requires a carrier to provide basic services with technical characteristics that are equal to the technical characteristics the carrier uses for its own enhanced services. 40. Installation, Maintenance and Repair: This parameter requires that the time periods for installation, maintenance and repair of the basic services and facilities included in a CEI offering must be the same as those the carrier provides to its own enhanced service operations. Carriers must satisfy reporting and other requirements showing that they have met this requirement. 41. End User Access: This parameter requires the carrier to provide to all end users the same capabilities to use abbreviated dialing or signalling to activate or obtain access to enhanced services that utilize the carrier's facilities. This parameter also requires the carrier to provide end users equal opportunities to obtain access to basic facilities through derived channels, whether they use the enhanced service offerings of the carrier or of a competing provider. 42. CEI Availability: This parameter requires a carrier's CEI offering to be available and fully operational on the date that it offers its corresponding enhanced service to the public. The parameter also requires the carrier to provide a reasonable time prior to that date when prospective users of the CEI offering can utilize the CEI facilities and services for purposes of testing their enhanced service offerings. 43. Minimization of Transport Costs: This parameter requires carriers to provide competitors with interconnection facilities that minimize transport costs. 44. Recipients of CEI: This parameter prevents carriers from restricting the availability of the CEI offering to any particular class of customer or enhanced service competitor. 2. Other Nonstructural Safeguards 45. In addition to the CEI requirements established in Computer III, a BOC proposing to provide enhanced services on a structurally integrated basis must demonstrate that it will comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination reporting, as outlined below. 46. Customer Proprietary Network Information: The Phase II Order established CPNI requirements for BOCs' enhanced service operations, requiring them, among other things, to (1) make CPNI available, upon customer request, to unaffiliated enhanced service vendors, on the same terms and conditions that are available to their own enhanced services personnel; (2) limit their enhanced services personnel from obtaining access to a customer's CPNI if the customer so requests; and (3) notify multi-line business customers annually of their CPNI rights. The Commission also requires BOCs to provide any nonproprietary aggregate CPNI to unaffiliated enhanced service vendors on the same terms and conditions that the BOCs provide that information to their own enhanced services personnel. 47. Network Information Disclosure: The BOC is also required to disclose to the enhanced services industry information about network changes and new network services that affect the interconnection of enhanced services with the network. The BOC must make that disclosure at the "make/buy" point, that is, when it decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface. The BOC must provide that information to members of the enhanced services industry that sign a nondisclosure agreement, within 30 days after the execution of such nondisclosure agreement. The BOC must also publicly disclose technical information about a new or modified network service twelve months before that service is introduced. 48. Nondiscrimination Reporting: The BOC is also required to file quarterly nondiscrimination reports with respect to its enhanced services, thereby ensuring that it provides the access promised in its CEI plan. B. Summary of CEI Plans and Amendments Filed 49. The BOC CEI plans and amendments filed pursuant to the Interim Waiver Order, discussed briefly below, are summarized in greater detail in Attachment A to this Order. In general, the enhanced services addressed by the plans fall into several categories: voicemail, protocol processing, electronic information services (including gateway, on-line data base, and Internet access services), enhanced facsimile services, and voice information services. 50. Ameritech filed a CEI plan for voicemail service. BellSouth, NYNEX, Pacific Bell, SWBT, and US West amended their existing CEI plans for voicemail, adding capabilities such as two-way messaging, shared mailboxes, various fax applications, delivery of messages outside the voicemail system, and outcall and paging notification. 51. Pacific Bell filed a CEI plan for protocol processing services, while Bell Atlantic, BellSouth, SWBT and US West amended their existing protocol processing CEI plans. In general, these amendments added basic underlying network services, including switched multi-megabit data service (SMDS), fiber-distributed data interface service (FDDI), frame relay, asynchronous transfer mode (ATM), integrated service digital network (ISDN), and others. 52. In connection with electronic information services, NYNEX filed a CEI plan for a service through which subscribers may obtain access to and interact with stand-alone databases or information gateways. US West filed separate CEI plans that propose an on-line database access service and an electronic messaging service. BellSouth amended its gateway service CEI plan, and Pacific Bell amended its gateway service and electronic messaging CEI plans to reflect the convergence of these service areas, and to provide for Internet access capability. 53. Ameritech, Pacific Bell and US West all filed CEI plans for enhanced facsimile services, which generally provide subscribers with the ability to receive fax messages in a fax "mailbox," to send and receive multiple faxes simultaneously, to store fax messages for retrieval on demand, and otherwise to direct the routing and processing of fax messages. 54. Ameritech and US West filed CEI plans for interactive voice information services, whereby the subscriber may obtain and interact with voice information (such as weather, time, news headlines or general information). Pacific Bell amended its CEI plan for voice store and forward services to add outcall capabilities, as well as underlying basic network services. 55. In addition, Ameritech filed a CEI plan for alarm monitoring services which covers installation, monitoring and maintenance of monitoring and control systems. SWBT filed a CEI plan for payment processing services covering electronic bill collection of other companies' customer bill payments by SWBT payment agents. C. Comments Filed Regarding CEI Plans and Amendments 56. Pursuant to the Interim Waiver Order, we placed the referenced CEI plans on comment cycles when received. One party filed comments asserting that the Bureau had no jurisdiction to review or approve the CEI plans. One party filed comments opposing Pacific Bell's CEI plan amendment for electronic messaging services. Another party filed comments opposing Ameritech's Alarm Monitoring Services CEI plan. We reviewed all 12 CEI plans and 13 amendments for compliance with the CEI parameters, and discuss below the issues raised by commenting parties. 1. Authority for the Proceeding a. Pleadings 57. ITAA argues that the Ninth Circuit's California III decision vacated the Computer III CEI rules, leaving the Bureau with no jurisdiction to review or approve the CEI plans at issue. ITAA concludes that the Bureau should withhold approval of the BOCs' CEI plans and amendments and reconsider the BOCs' waiver petition under the structural separation standard established by Computer II. In reply, the BOCs point out that ITAA's comments do not address the substance of their CEI plans, but only seek to reiterate arguments raised by ITAA in its petition for reconsideration of the Interim Waiver Order. Pacific Bell argues that ITAA has misinterpreted the reach of the California III decision, and notes that the Bureau has already concluded that the BOCs have made the necessary showing for a waiver of the Computer II rules, to the extent one is necessary. b. Discussion 58. We address the arguments raised by ITAA in Section III of this order, in which we deny ITAA's petition for reconsideration of the Interim Waiver Order. We conclude that we correctly interpreted the effect of the Ninth Circuit's California III decision, and that we were therefore within the scope of our authority in issuing the Interim Waiver Order. It follows that we have jurisdiction to review and approve the CEI plans and amendments that are in part the subject of this order. 2. Pacific Bell Electronic Messaging Services a. Pleadings 59. The Commercial Internet eXchange Association (CIX) opposes Pacific Bell's CEI plan amendment for electronic voice messaging services, alleging that it fails to provide the necessary "equal access" for competing Internet service providers. CIX asserts that Pacific Bell failed to disclose its intent to provide Internet access services, and notes that Internet access is not among the enhanced services covered by a previously approved Pacific Bell CEI plan. CIX argues that because Pacific Bell can provide Internet access via advanced transport services that can support a wide variety of basic and enhanced services, it enjoys the competitive advantage of "single line convenience" over other Internet access providers. CIX claims that Pacific Bell must be required to explain how competing Internet service providers can obtain access to these advanced transport facilities in a way that meets CEI equal access standards. CIX asserts that Pacific Bell must provide access to advanced transport facilities linking intracompany offices to competing enhanced service providers on the same terms and conditions that it provides access to these facilities to its affiliated enhanced service provider. 60. CIX further asserts that Pacific Bell's CEI plan amendment fails to disclose the basic network services used to provide Internet access services. CIX states that Pacific Bell did not show that these basic network services have been fully unbundled in accordance with Computer III "fundamental unbundling" standards which CIX argues are in effect following the California III decision. CIX also alleges that Pacific Bell failed to specify the areas in which it will offer integrated enhanced services and the network areas in which it will provide CEI. 61. In reply, Pacific Bell asserts that CIX fundamentally misunderstands CEI requirements and their relationship with ONA requirements. Pacific Bell states that its CEI obligation is satisfied as long its collocated enhanced services operations purchase the same tariffed services that are available to other ESPs and pay the same rates paid by other ESPs located two miles from its central offices, regardless of the type of enhanced service involved. 62. Pacific Bell asserts that the enhanced aspect of its Internet access service offering involves electronic messaging, which was covered by Pacific Bell's 1989 CEI plan. Thus, Pacific Bell states that it is not required to file a separate CEI plan for Internet access services, but rather must obtain approval for the use of new basic underlying network services not originally included in its electronic messaging CEI plan. 63. Pacific Bell acknowledges that it intends to provide Internet access. Further, Pacific Bell asserts that the use of advanced transport services to provide Internet access should be treated no differently than the use of plain old telephone service (POTS), in that both are tariffed basic network services. Pacific Bell argues that no access discrimination problems would arise in the context of the frame relay interoffice interconnection scenario posed by CIX, because the customer may use its frame relay channels however it wants, and may use some or all of its frame relay capacity to obtain Internet access from a competing Internet services provider. Further, Pacific Bell explains that other Internet access providers such as Prodigy currently use Pacific Bell's advanced transport services to provide their enhanced services. 64. Pacific Bell asserts that it has met the Commission's requirements regarding the amount of detail required in its description of its Internet access service. Pacific Bell asserts that it has both identified the underlying basic services it will use to provide Internet access and has attached those tariffs to its CEI plan amendment. Further, Pacific Bell maintains that it has fully complied with CEI unbundling requirements. With respect to CIX's claim that Pacific Bell failed to demonstrate fundamental unbundling of its underlying basic services, Pacific Bell maintains that fundamental unbundling is related to ONA, and is therefore not at issue with respect to its CEI plan. Pacific Bell notes that it intends to provide its electronic messaging services and CEI throughout its California and Nevada service areas. b. Discussion 65. We find no merit in CIX's primary argument that Pacific Bell's CEI plan does not adequately guard against potential access discrimination against other Internet access service providers. This argument rests on the unfounded assumption that Pacific Bell's Internet access service provider will have preferential access to advanced transport services provided by Pacific Bell to end user customers. Pacific Bell warrants that its Internet access provider will take all basic underlying network services, including advanced transport services, pursuant to tariff. This means that BOC-affiliated ESPs are in the same position regarding access to these advanced transport services as are non-affiliated Internet access providers. CEI is intended to prevent the BOCs from providing to competing ESPs network connections inferior to those that the BOCs themselves rely on. Thus, certification by Pacific Bell that its enhanced services operation will purchase the advanced transport services to be used to provide Internet access at the same tariffs available to all other ESPs satisfies CEI equal access requirements. Further, as Pacific Bell points out, end users control access to the advanced transport services they are purchasing from the BOCs, so they are free to use such advanced transport services to interconnect with any Internet access provider they desire, whether or not the provider is BOC-affiliated. 66. Regarding the propriety of Pacific Bell's classification of its Internet access service as a new application of electronic messaging services, we conclude that it was appropriate for Pacific Bell to file an amendment to its electronic messaging CEI plan addressing Internet access service. As Pacific Bell points out in the amendments to its videotex gateway service, videotex and electronic messaging services have converged to such a degree in recent years that there are no longer any clear distinctions between them, and Pacific Bell has amended its videotex gateway CEI plan consistent with its electronic messaging CEI plan. Pacific Bell's Internet access offering represents an application in which videotex gateway and electronic messaging services converge. Thus, it is appropriately addressed in an amendment to Pacific Bell's CEI plan for electronic messaging services. 67. Finally, we conclude that Pacific Bell adequately disclosed the basic network services that will be used to provide Internet access services and that it has met the CEI requirement for unbundling of basic services. In response to CIX's argument that Pacific Bell must demonstrate that it has "fully" unbundled the basic network services underlying its Internet access service, we agree with Pacific Bell that it is not required to do more than meet the CEI requirement for unbundling, which is discussed above in Section (IV)(A)(1). Pacific Bell has further specified that it intends to provide Internet access service and CEI throughout its California and Nevada service areas. 3. Ameritech Alarm Monitoring Services a. Pleadings 68. AICC contends that the Bureau should reject Ameritech's CEI plan for alarm monitoring services. Because central station alarm companies are dependent on telephone services, AICC expresses concern that Ameritech's own alarm operations will receive preferential treatment over competing alarm monitoring companies. AICC raises questions regarding Ameritech's practices with respect to SecurityLink, the central station alarm company Ameritech acquired in 1994. Specifically, AICC states that the Bureau should require Ameritech to warrant that it has no off-tariff pricing arrangements with SecurityLink for Applied Spectrum Technology (AST), a derived local channel service used for alarm monitoring devices. Further, AICC suggests that Ameritech's deployment of ScanAlert technology may have been discriminatory. AICC asserts that Ameritech should be required to warrant to the Commission that it will not funnel marketing leads to SecurityLink as it had done by agreement in the past with selected alarm companies that helped Ameritech to market ScanAlert. 69. AICC also asserts that Ameritech's CEI plan for alarm monitoring services lacks adequate information on the relationship between Ameritech and SecurityLink, such as the ONA services used by SecurityLink, the geographic location of SecurityLink's operations, and whether SecurityLink will share any common management or facilities with Ameritech. Further, AICC states that Ameritech's plan does not meet the CEI requirement that transport costs be minimized for ESP competitors. In addition, AICC states that Ameritech failed to include in its annual ONA filing a list of the Basic Service Elements used by SecurityLink. 70. In reply, Ameritech states that AICC is attempting to impose a new "strict scrutiny" review on Ameritech's CEI plan that goes beyond the standard for review set by the Interim Waiver Order. Ameritech asserts that its CEI plan provides sufficient detail on its acquisition of SecurityLink and the alarm monitoring services to be provided under the arrangement. Ameritech asserts that AICC's suspicions about possible "off-tariff" pricing arrangements for AST are unfounded, because Ameritech has tariffed the derived channel portions of its older-technology AST offerings. Further, Ameritech states that it will have no "off-tariff" pricing arrangements for AST with SecurityLink because SecurityLink does not, and will not, use the derived channel portion of AST technology. 71. Ameritech claims that it presently offers ScanAlert spread spectrum service in 194 central offices across its service area, and in those offices, the service is available to all alarm companies, with no minimum requirements. Ameritech represents that ScanAlert is provided to only 1% of Ameritech's current alarm service customers, and that there are 38 central offices where ScanAlert equipment has been deployed, but no customers have subscribed to the service. Ameritech acknowledges that, because of the scattered demand for ScanAlert, it has instituted a 32-port minimum commitment before it will install ScanAlert equipment in a new central office location. Ameritech adds that in Illinois, it has revised the ScanAlert tariff to permit new offices to be added with an eight-port minimum commitment, for any alarm company (or companies) agreeing to a minimum of 32 ports, state-wide. Ameritech states that it plans to revise the ScanAlert tariffs in the other states in its service region to reflect this eight-port minimum. Ameritech notes that once ScanAlert equipment has been deployed in a central office, whether that deployment was instigated by an affiliated or unaffiliated customer, all alarm companies will have access to the service. Ameritech denies that volume commitment requirements provide a competitive advantage to SecurityLink, to which they are equally applicable. b. Discussion 72. We conclude that Ameritech's Alarm Monitoring Service CEI plan, as clarified and supplemented by its Ex Parte filing, adequately demonstrates its compliance with the CEI parameters. Ameritech represents that it is not engaging in off-tariff price arrangements with SecurityLink for AST, and has warranted that SecurityLink is not using the tariffed portion of AST technology. 73. Further, we do not believe that Ameritech's policy of requiring volume commitments prior to additional deployment of ScanAlert technology will give rise to discriminatory deployment of the technology since these requirements apply equally to SecurityLink. We conclude that Ameritech's volume commitment policy is a reasonable method for ensuring that ScanAlert is provided from the central offices where there exists a reasonable level of demand for the service. Further, Ameritech has adopted an eight-port per central office/32-port statewide minimum commitment in Illinois and has indicated its intent to reduce the level of volume commitment required from 32 ports to eight throughout its service area, which lessens any economic burden imposed on competing alarm services providers. 74. We find that AICC is mistaken in its assertion that Ameritech's CEI plan for alarm monitoring services fails to satisfy the minimization of transport costs parameter. Ameritech notes that no equipment owned, maintained, operated or involved with SecurityLink is located in Ameritech's central office facilities. Ameritech adds that transport cost discrimination would be impossible with respect to three of SecurityLink's eight central monitoring stations, as they are located outside of Ameritech's service area. In addition, Ameritech has certified that interconnection to all facilities used to provide the underlying basic services is tariffed and available at the same rates, and on the same terms and conditions, to both affiliated and non-affiliated ESPs. In accordance with the Phase II Reconsideration Order, this certification satisfies the minimization of transport costs CEI parameter. 75. Further, we conclude that Ameritech's express representation that it will comply with all Commission rules regarding use of Customer Proprietary Network Information (CPNI) addresses AICC's expressed concerns regarding potential improper "funneling" of marketing leads on Ameritech's part. V. CONCLUSION 76. We conclude that neither ITAA's petition for reconsideration nor any of the comments filed in support thereof provide any basis for reconsideration of the Interim Waiver Order. Therefore, we deny the petition. 77. Based on our review of the 12 CEI plans and 13 CEI plan amendments filed by the BOCs, we conclude that these plans and amendments adequately demonstrate the BOCs' compliance with all requisite CEI plan requirements. Accordingly, we approve the referenced CEI plans and amendments. VI. ORDERING CLAUSES 78. Accordingly, IT IS ORDERED, pursuant to Section 1.106 of the Commission's rules, 47 C.F.R.  1.106, that the petition of ITAA for reconsideration of the Interim Waiver Order is DENIED. 79. IT IS FURTHER ORDERED, pursuant to Sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91 and 0.291, that the CEI plans and amendments listed in Appendix A are APPROVED. FEDERAL COMMUNICATIONS COMMISSION Kathleen M.H. Wallman Chief, Common Carrier Bureau Appendix A RBOC CEI Plans and Amendments I. Ameritech 1. Facsimile Store and Forward Service Ameritech's Facsimile Store and Forward Service provides a variety of fax capabilities to subscribers, including: (1) the ability to send fax messages; (2) the ability to send a fax message to multiple destinations with a single call; (3) the ability to receive fax messages when the subscriber's fax machine is unavailable; and (4) the ability to store fax messages for later retrieval on demand. 2. Interactive Voice Response Services Ameritech's interactive voice response services (IVRS) allow consumers to obtain access to voice information with their telephones, and may provide subscribers with switching and storage capabilities as well as interactive and passive information services. The IVRS system automates responses using a recorded voice in a predefined sequence, providing options and instructions to the caller. The caller responds to these prompts using the telephone's touchtone keys. IVRS are grouped into two categories: (1) IVRS involving playback of pre-recorded voice prompts and recordings (e.g. weather, time, sports and general information services) and (2) IVRS involving caller interaction with computer systems and databases. 3. Voice Mail Messaging Service Ameritech's Voice Mail Messaging Service is a centrally located computer-based telephone answering service which allows subscribers to leave, answer and retrieve voice messages. The service notifies subscribers of messages available for retrieval via stutter dial tone, message waiting lamp, or personal pager. Subscribers may perform various message handling functions including retrieval from any touchtone phone, review, store, scan, forward and message deletion. Additional capabilities provided by the service include two-way messaging, which allows subscribers on the same platform to send messages to one another without dialing a telephone number, and shared mailboxes, which allow multiple users to share one main mailbox. 4. Alarm Monitoring Services Through a subsidiary known as SecurityLink, Ameritech offers a range of alarm services to its customers including the sale, installation, monitoring and maintenance of intrusion and motion detection systems, fire detection systems, and other types of monitoring and control systems for residential, commercial and governmental customers. The typical monitoring scenario involves two phases. The first is the transmission of a non-voice message from the residential, commercial or governmental alarm system to a central monitoring station indicating that an alarm condition exists at the specific premises involved. The second phase involves a voice call placed by personnel at the monitoring station to the police or fire department, and to persons designated by the customer to be contacted in the event of an alarm. (In certain municipalities, direct monitoring of alarm systems by police and fire stations eliminates the need for the second phase call.) II. Bell Atlantic 1. Protocol Processing Services (Amendment) Bell Atlantic's original CEI plan for protocol conversion services was approved on March 31, 1989. See Bell Atlantic Telephone Companies Offer of Comparably Efficient Interconnection to Providers of Protocol Conversion Services, 4 FCC Rcd 2744 (1989). Under this plan, Bell Atlantic received authority to provide a variety of protocol conversions in connection with three different categories of basic services: private line network services (PLS); Public Data Network (PDN) packet switched data services; and central-office-based local area network services (CO-LAN). Bell Atlantic's amendment seeks to add new basic underlying services, including switched multi-megabit data service (SMDS), frame relay service, fiber distributed data interface network service (FDDI), and integrated digital network service (ISDN). III. BellSouth 1. Gateway Services (Amendment) BellSouth's original CEI plan for gateway services was approved May 25, 1989. See BellSouth Plan for Comparably Efficient Interconnection for Gateway Services, 4 FCC Rcd 4524 (1989). Under the previously approved plan, BellSouth's gateway services enabled users to use information storage, retrieval and delivery functions; document and file sharing and transfer; and other data communication functions. In its amendment, BellSouth indicates that it has eliminated the computer storage capabilities and electronic mail service features that were formerly associated with its gateway. BellSouth also deleted the previous requirement that gateway service providers subscribe to two-way measured service access arrangements in order to obtain calling party numbers. 2. Synchronous Protocol Processing Services (Amendment) BellSouth's original CEI plan for synchronous protocol processing services was approved February 15, 1989. See BellSouth Plan for Comparably Efficient Interconnection of Enhanced Services Providers for Synchronous Protocol Processing Services, 4 FCC Rcd 1560 (1989); amended 4 FCC Rcd 6825 (1989). In the previous CEI plans, BellSouth described a variety of synchronous protocol processing services and stated it would offer additional synchronous protocols as manufacturers developed new equipment or released new specifications. Since that time, BellSouth has added a multi-protocol routing service to provide connectivity between local data networks operating at disparate protocols, and its amendment seeks approval for associated new basic underlying network services, including packet network or private line services, including DS1, DS3, Frame Relay, Connectionless Data Service, and other data transport services. 3. Voice Messaging Services (Amendment) BellSouth's original CEI plan for voice messaging services was approved December 23, 1988. See BellSouth Plan for Comparably Efficient Interconnection for Voice Messaging Services, 3 FCC Rcd 7284 (1988). The plan provided for voice message service including functions such as storage, review, reply, retrieval, redirect, broadcast, scan and delete. In its amendment, BellSouth seeks approval for addition of two new features: (1) provision of informational messages to customers on a subscription or per-call basis; and (2) provision of information to customers via a voice grade facsimile capability associated with voice store-and-forward equipment. IV. NYNEX 1. Electronic Information Services (EIS) EIS are computer-based electronic information services that may be provided as stand- alone databases or information service gateways. Customers with a telecommunications capability obtain access to and interact with EIS through the use of a personal computer or suitably equipped terminal. NYNEX offers two EIS applications: Video text Information Services Gateway (VIG) and NYNEX Interactive Yellow Pages (NIYP). VIG allows end users (1) to obtain access to and interact with videotext information services provided by affiliated and non-affiliated ESPs; and (2) to create, store, obtain access to and send electronic mail messages. Customers may obtain access to VIG via dial-up access using the public switched network or through the use of private lines. NYNEX's Interactive Yellow Pages database contains classified business listings from the NYNEX Yellow Pages, as well as customer-sponsored advertising. NYNEX provides access to NIYP through selected third party on-line information service gateway providers, such as Prodigy. 2. Voice Messaging Services (Amendment) NYNEX's original CEI plan for voice messaging services covering two generic applications -- call answering and voice mail -- was filed in June 1988 and has been amended several times subsequently. See NYNEX Comparably Efficient Interconnection Plan for Voice Messaging Services, 3 FCC Rcd 4345 (1988). This amendment identifies two new applications -- Enhanced Messaging and Facsimile Messaging -- as well as additional associated underlying basic network services. Enhanced Messaging service provides the ability to create, send, receive, and retrieve messages for specific messaging applications, such as Reminder Call and Community Mailbox. (Reminder Call permits a subscriber to record a message and set a time and day for the message to be delivered. Community Mailbox allows a "group" sponsor to leave voice messages, either on an individual or broadcast basis, in a "group" member's voice mailbox specifically established for the user group.) Facsimile Messaging service allows subscribers to send, store, receive, and retrieve facsimile messages along with their voice messages using NYNEX's VMS platform. Generic applications of the service include: Facsimile Call Answering (redirects incoming facsimile calls to a VMS facsimile mailbox when a no-answer or busy condition is encountered); Facsimile Mail (ability to send, store, receive and retrieve facsimile messages); and Enhanced Facsimile Messaging (specially designed facsimile messaging applications). V. Pacific Bell 1. Enhanced Protocol, Code, and Format Conversion Service Pacific Bell's enhanced protocol conversion CEI plan covers all protocol conversion that qualifies under Commission precedent as an "enhanced service" and is: (1) performed between asynchronous and synchronous protocols, between different synchronous protocols, and between different applications protocols; (2) involved in address or domain-name translation between protocols in association with another enhanced service; or (3) to be developed in the future. End user customers can obtain access to Pacific Bell's protocol conversion service using tariffed Local Exchange Telephone or Private Line Services in conjunction with Pacific Bell's tariffed Public Packet Switching (PPS) service. Both end users and Pacific Bell's own enhanced service operation also can use the following tariffed basic network service options such as ISDN, High Capacity Services, Frame Relay, SMDS, and, once it is tariffed, Asynchronous Transfer Mode (ATM). 2. Facsimile (Fax) Store and Forward Service The fax services provided by Pacific Bell enable customers to send, receive and store facsimile messages. There are three primary applications of Pacific Bell's Fax Services technology: (1) Fax Mail, (2) Fax Overflow and (3) Fax On Demand. Fax Mail service provides a subscriber with a fax mailbox from which the subscriber retrieves messages and faxes; the fax sender can choose to leave a voice annotation, if desired. Subscribers may choose which fax machine to send the fax message to for printing, and may also set up group lists for delivery of fax documents to a group. Fax Overflow service forwards a fax call to a subscriber's fax mailbox when the subscriber's fax telephone line is busy or does not answer. The subscriber may choose to have the stored fax message automatically sent to the subscriber's fax machine when it becomes available or retained in the fax mailbox for later retrieval. Fax On Demand allows subscribers to store fax messages in a fax mailbox and make them available to one or more callers on demand. 3. Electronic Messaging Services (Amendment) Pacific Bell's original CEI plan for Electronic Messaging Services was approved February 21, 1989. See Pacific Bell and Nevada Bell Plan for the Provision of Electronic Messaging Services, 4 FCC Rcd 1640 (1989). The applications covered were electronic mail, electronic forms transfer, electronic document and data interchange, and format conversion. Pacific Bell's amendment describes new applications of electronic messaging enhanced services and identifies additional basic network services. New applications include Business Transaction Network (BT Net), which facilitates transport of business information among communities of interest, expanded healthcare-related service applications, and an education-related service application known as Knowledge Network Gateway. Other new applications pertain to Internet access, including: (1) Internet e-mail backup service, (2) store-and-forward e-mail and group messaging services and (3) backup and primary domain name services (DNS). Still other additional applications provide for distribution of news to service subscribers, digital distribution of movies to movie theaters, and distribution of digital information to multi-media developers. 4. Videotex Gateway Service (Amendment) Pacific Bell's original CEI plan for Videotext Gateway Services was approved April 7, 1989. See Pacific Bell and Nevada Bell Plan for Comparably Efficient Interconnection for Videotext Gateway Service, 4 FCC Rcd 2774 (1989). Users obtain access to the gateway via personal computer, and would be able to obtain access to a variety of ESPs through a centralized gateway facility. Because videotex and electronic mail have converged to the point that no clear distinctions exist between the services, Pacific Bell's Videotext Gateway Service CEI amendment essentially mirrors its Electronic Messaging Services amendment. 5. Voice Mail Service (Amendment) Pacific Bell's CEI plan for Voice Mail Services was originally approved in 1988 and an amendment to the plan was approved in 1992. See Pacific Bell and Nevada Bell Plan for the Provision of Voice Mail Services, conditionally approved 3 FCC Rcd 1095 (1989), finally approved 3 FCC Rcd 3552 (1989); amendment approved 7 FCC Rcd 3487 (1992). Under the original plan, Voice Mail service allowed voice communications by telephone to be stored, retrieved, deleted, replied to and redirected to other subscribers and non-subscribers. The 1992 amendment enabled Pacific Bell to provide informational messages (such as news, weather reports, stock quotes) to groups of VMS subscribers. Pacific Bell's current amendment describes new applications of voice mail services -- including Message Outcall, Outcall Notification, and Paging Notification -- and identifies additional basic network services. Message Outcall enables the subscriber to designate a third-party telephone number outside of the Voice Mail system to which the system will attempt to deliver the recorded messages intended for the subscriber. Through Outcall Notification, subscribers may designate a telephone number to which the Voice Mail system will attempt to deliver the messages waiting in their voice mailboxes. Paging Notification is a similar service which enables subscribers to designate that the Voice Mail system deliver messages to their pagers. 6. Voice Store and Forward Service (Amendment) Pacific Bell's original CEI plan for Voice Store and Forward Service was approved May 15, 1989. See Pacific Bell and Nevada Bell Plan for the Provision of Comparably Efficient Interconnection for Voice Store and Forward Service, 4 FCC Rcd 4491 (1989). Voice Store and Forward is a voice storage service which enables subscribers to deposit and obtain access to voice information. This amendment describes additional Voice Store and Forward Service applications -- including Message Outcall -- and identifies additional underlying basic network services. Message Outcall enables voice messages to be "outcalled" over the switched network to third persons who are not subscribers to the Voice Store and Forward Service. VI. SWBT 1. Payment Processing Services SWBT's PPS offering provides for the electronic collection of other companies' (e.g. electric utilities) customer bill payments by SWBT payment agents. SWBT payment agents, who are typically located in banks and grocery stores, accept payments and enter them via a SWBT-developed software program called Payment Agency Management System (PAMS), which resides on a SWBT-provided personal computer at the agent's location. On a scheduled basis, SWBT's central processor initiates a call to each such personal computer to signal that it is ready to receive the client company's bill payment file. Such calls are transmitted over Value Added Network (VAN) facilities, not SWBT facilities. In turn, the personal computer dials up to a VAN and transmits the client company's bill payment file to SWBT's central processor, which converts and stores the information for use by the client company. 2. Protocol Conversion Services (Amendment) SWBT's original CEI plan for Protocol Conversion Services was approved March 9, 1989. See Southwestern Bell Telephone Company Plan for Comparably Efficient Interconnection of Enhanced Service Providers for Protocol Conversion Services, 4 FCC Rcd 2236 (1989). Under that plan, SWBT provided protocol conversion services to facilitate data communications among customers whose terminals and host computers operate on different protocols. The plan proposed to add synchronous protocols as new equipment became available or as manufacturers released specifications for such new synchronous protocols. SWBT's amendment seeks to add the following new basic underlying services: (1) ATM, (2) DS 0, (3) DS 1, (4) DS 3, (5) Frame Relay, (6) ISDN, and (7) SMDS. 3. Voice Messaging Services (Amendment) SWBT's CEI plan for Voice Mail Services was originally approved on September 29, 1988. See Southwestern Bell Telephone Company Comparably Efficient Interconnection Plan for the Provision of Voice Mail Services, 3 FCC Rcd 6912 (1988). Voice Mail service allowed subscribers to receive messages and to originate and distribute messages using voice storage equipment. The amendment seeks to add a new basic service called Network Subscriber Information Interface (NSII), which is a local, state-tariffed telecommunications service that provides call origination information and the capability to activate and deactivate a message waiting indicator on patrons' lines in multiple offices. VII. US West 1. Audiotex Services Audiotex services permit customers to interact with audio information from a variety of sources (e.g. voice classified ads) stored within US West computers. US West's Audiotex Service offerings are similar to its Voice Messaging Services offerings and may be viewed as a voice companion to its Database Access Service offerings. To use the Audiotex Service, subscribers place a voice call which is answered by a computer; all information is delivered via voice telephony. 2. Enhanced Facsimile Services US West's enhanced facsimile services provide customers with fax capabilities beyond the traditional send/receive only mode, including the capability (1) to receive fax messages at a private "mail box;" (2) to receive multiple faxes at one number simultaneously; (3) to broadcast fax messages to multiple locations; (4) to hold "overflow" fax messages originally destined to a traditional fax machine for future delivery; (5) to permit interactions between fax machines and other computers; and (6) other applications which permit customer control of the manner and time of fax transmission and delivery. 3. Electronic Messaging Services US West's electronic messaging services provide customers with an array of services including electronic mail service, electronic message transfer service, and electronic data interchange. Electronic mail allows end users with electronic terminals or computers with modems the ability to lease/purchase mailbox functions on a public basis. Message transfer services provide message transfer capabilities between user agents. Electronic data interchange provides automated computer-to-computer exchange of structured business documents between an enterprise and its vendor, customers, or other trading partners. 4. On-line database access services US West's on-line database access services allow customers to store, retrieve and manipulate data stored in US West computers. Data includes information provided by US West as well as customer-provided data, and includes both image and data receipt of information by the customer. Current services include remote data processing services for customers, access to US West data within US West's computer, point of sale termination services, and electronic classified advertisements and similar services. 5. Protocol Processing Services (Amendment) US West's original CEI plan for Protocol Processing Services was approved July 13, 1989. See US West Plan for Comparably Efficient Interconnection to Enhanced Services Providers for Protocol Processing Services, 4 FCC Rcd 5512 (1989). The protocol processing services provided under the plan were to allow customers to use US West's network access services to transport data originated from customer premises equipment (CPE) even though the CPE may employ different communications protocols. US West's amendment seeks to add a new underlying basic network service, Frame Relay Service, which provides high speed access and throughput to and among local area networks as well as computers. 6. Voice Messaging Services (Amendment) US West's original CEI plan for Voice Messaging Services was approved January 13, 1989. See US West, Inc. Offer of Comparably Efficient Interconnection to Providers of Voice Messaging Services, 4 FCC Rcd 572 (1989). Under this plan, the service allows subscribers to record voice messages for retrieval by or delivery to individuals designated by the sender. Features include: storage, retrieval, redirect, group broadcast, future delivery, reply, skip back or ahead, message scan, and pause. The plan included four voice messaging applications: (1) call answering, (2) voice mail, (3) call delivery (an outbound message delivery service), and (4) message storage. The amendment seeks to add several underlying basic network services, including: (1) Voice Grade -- Line-Circuit Switched, (2) Voice Grade -- Trunk-Circuit Switched, (3) Message Delivery Service-Interoffice, and (4) Message Waiting Indication- Audible/Visual.