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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) CCBPol 97-03 Ameritech's Comparably Efficient ) Interconnection Plan for ) Electronic Vaulting Service ) ORDER Adopted: December 31, 1997 Released: December 31, 1997 By the Chief, Common Carrier Bureau: TABLE OF CONTENTS Paragraph I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . 1 II. BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . 3 A. CEI Plans. . . . . . . . . . . . . . . . . . . . . . 3 B. The Telecommunications Act of 1996 . . . . . . . . . 7 III. SERVICE DESCRIPTION . . . . . . . . . . . . . . . . . . 8 IV. COMPLIANCE ISSUES. . . . . . . . . . . . . . . . . . . 16 A. CEI Plan Requirements. . . . . . . . . . . . . . . 16 1. Unbundling of Basic Services. . . . . . . . . 17 2. Interface Functionality . . . . . . . . . . . . 23 3. Resale. . . . . . . . . . . . . . . . . . . . 25 4. Technical Characteristics . . . . . . . . . . 27 5. Installation, Maintenance, and Repair . . . . . 30 6. End-User Access . . . . . . . . . . . . . . . 32 7. CEI Availability. . . . . . . . . . . . . . . 34 8. Minimization of Transport Costs . . . . . . . 36 9. Recipients of CEI . . . . . . . . . . . . . . 38 B. Other Nonstructural Safeguards. . . . . . . . . 40 1. Customer Proprietary Network Information. . . . 41 2. Network Information Disclosure. . . . . . . . 43 3. Nondiscrimination Reporting . . . . . . . . . . 45 C. Accounting Safeguards. . . . . . . . . . . . . . . 46 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . 47 I. INTRODUCTION 1. On February 27, 1997, pursuant to the requirements of the Commission's decisions in the Computer III proceeding, Ameritech filed a comparably efficient interconnection (CEI) plan outlining the terms on which it proposed to offer Electronic Vaulting Service (EVS) as an enhanced service. Under the Computer III regulatory regime, a Bell Operating Company (BOC) is permitted to provide unregulated, enhanced services if it files a CEI plan demonstrating that the underlying regulated, basic services are available on an equivalent basis to unaffiliated enhanced service providers (ESPs). Prior to offering an enhanced service, a BOC must obtain Commission approval of its CEI plan. 2. The Common Carrier Bureau (Bureau) issued a public notice concerning Ameritech's CEI plan on March 10, 1997. No oppositions or comments were filed in connection with the proposed plan. For the reasons discussed below, we approve Ameritech's CEI plan for EVS, subject to the conditions set forth in this Order. II. BACKGROUND A. CEI Plans 3. The requirement to file a CEI plan was first established in the Computer III proceeding in which the Commission adopted a regulatory framework to govern the provision of integrated enhanced and basic services by the BOCs. CEI plans are one of the nonstructural safeguards the Commission adopted in lieu of structural separation, to prevent cross- subsidization and discrimination. As a first step in implementing the Computer III framework, the Commission permitted the BOCs, which remained subject to various structural separation requirements, to offer individual enhanced services on an integrated basis following approval of service-specific CEI plans. BOCs were required to describe in their CEI plans: (1) the enhanced service(s) to be offered; (2) how the underlying basic service(s) would be made available for use by competing ESPs; and (3) how the BOCs would comply with the other nonstructural safeguards imposed by Computer III. 4. The Computer III decision concluded that, in the longer term, with the implementation of Open Network Architecture (ONA), the BOCs should be allowed to provide integrated enhanced services without prior Commission approval of service-specific CEI plans. In orders adopted between 1988 and the end of 1992, the Commission approved a series of BOC ONA plans that described the unbundled basic services each BOC proposed to provide as ONA services, and the terms upon which they would be offered. During 1992 and 1993, the Bureau approved lifting structural separation requirements for individual BOCs that showed they had implemented all of the ONA services set forth in their ONA plans. 5. In California III, the United States Court of Appeals for the Ninth Circuit 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 initial position regarding the level of unbundling necessary for eliminating structural separation. The court concluded that the cost-benefit analysis associated with the Commission's decision to lift structural separation was flawed and must be set aside as arbitrary and capricious under the Administrative Procedure Act. In response to the California III decision, the Commission initiated a rulemaking proceeding to review the existing nonstructural safeguards against BOC access discrimination. 6. Following the California III decision, the Bureau issued an order allowing the BOCs to continue providing enhanced services and conducting market trials pursuant to CEI plans approved prior to the lifting of structural separation. The Bureau also granted waivers necessary to enable BOCs to continue providing other enhanced services and market trials, conditioned upon their filing CEI plans or market trial notifications for such services or trials within 60 days of the Bureau Interim Waiver Order. The Bureau required the BOCs to file CEI plans or market trial notifications prior to providing any new services or market trials. In addition, the Bureau Interim Waiver Order required the BOCs to continue to comply with the procedures established in approved ONA plans. For example, BOCs still must provide new ONA services that ESPs need to provide enhanced services and file federal and state tariffs for ONA services. B. The Telecommunications Act of 1996 7. On February 8, 1996, the Telecommunications Act of 1996 (1996 Act) became law. Section 272 of the 1996 Act addresses the provision by BOCs of, inter alia, interLATA information services. On December 24, 1996, the Commission adopted rules to implement the non-accounting separate affiliate and nondiscrimination safeguards of sections 271 and 272. In the Non-Accounting Safeguards Order, the Commission concluded that the Computer II, Computer III, and ONA requirements are consistent with the 1996 Act and continue to govern BOC provision of intraLATA information services. The Commission also concluded that, as used in section 272, the term "interLATA information service" refers to an information service that incorporates as a necessary, bundled element an interLATA telecommunications transmission component, provided to a customer for a single charge. Ameritech represents that it will offer EVS solely on an intraLATA basis. Accordingly, no issues arise involving the provision of interLATA information services pursuant to section 272. III. SERVICE DESCRIPTION 8. Ameritech represents that its proposed EVS offering is an electronic data backup service that allows customers to recover and restore critical data from a secure off-site data storage facility. Ameritech states that the proposed service will be provided through three major components: (1) equipment and software at the customer's location(s) which prepare customer data for transport over Ameritech's network facilities; (2) dedicated network facilities which carry data between customer location(s) and the vault facility; and (3) remote vault equipment and software located at Ameritech's facilities. 9. Ameritech states that data sent by an EVS customer for storage will be transmitted over transport facilities connected to EVS "controller" equipment in the vault facility. It explains that the controller will receive data in the format and protocol transmitted by the customer. The controller will then reformat the customer's data and convert the transmission protocol so that the data and transmission protocol are compatible with the application software operating at the data vault. Ameritech notes that, using statistical multiplexing algorithms, the controller also "interleaves" data sent from multiple customers into a single data stream which is forwarded over an internal connection to the data vault. Ameritech represents that standard network interfaces will be utilized to connect customer premises equipment to the underlying basic services and to the EVS equipment at the other end of the transmission path. 10. Ameritech represents that it will offer three variations of EVS. The first is archiving, in which the customer's information is stored for an agreed-upon period of time. The second variation of EVS is mirroring, in which a "real-time" duplicate of the customer's information is kept in the data vault and instantly updated each time the customer changes the original information on its system. The third type of EVS offered by Ameritech is remote journaling, in which a "real-time" copy is made of each change to the customer's database. The journalized changes are periodically put on tape as the allocated disk space is filled. 11. Ameritech states that connection to EVS is accomplished only through existing standard network interfaces. It represents that EVS interconnection does not rely on, or otherwise require, any change to previously disclosed standard network interfaces. Ameritech states that links will be purchased by Ameritech's EVS service at the same rates and under the same terms and conditions as are available to unaffiliated ESPs. Ameritech states that all features delivered by Ameritech's EVS will utilize underlying basic network services at the same rates and under the same terms and conditions as those services are available to unaffiliated providers of competing services. 12. Ameritech represents that an EVS vaulting facility will be located in each LATA in which the proposed EVS service will be offered, and that all underlying basic facilities, switched and dedicated, used to transport data between customers premises and the EVS facilities, will be intraLATA in nature. 13. Ameritech represents that to ensure data security and integrity, information concerning the customer, such as telephone number, storage capacity and password, will be stored in the vault facility. Ameritech further represents that the vaulting facilities may not be accessed from the Internet. 14. According to Ameritech, EVS is designed to serve three types of end users -- customers with mainframe, mid-range, and personal computers. Ameritech indicates that it will provide customers with channel extension hardware and local area network (LAN) interfaces necessary to run the required host/client software. Ameritech states that it will also provide transport facilities, with sufficient capacity to support a given customer's data volume, between the customer location and the central office serving the associated data vault. The customer may either purchase a standard facility, or request Ameritech to arrange for installation of the facility as part of the EVS service. 15. Ameritech also indicates that customers with personal computers, who typically need to move small quantities of data to and from the data vault, may connect to the vault through a "dial-up" arrangement. It explains that client/host software will prompt the customer's modem to dial a telephone number associated with the electronic vaulting facility; upon establishment of the connection, the customer's data will be encrypted and sent to the data vault. Ameritech acknowledges that customers using the dial-up option may also access the associated data vault from another LATA using, for example, a laptop computer and a modem while away from the office, or from a "satellite" location, such as a warehouse, located in a different LATA. Ameritech represents, however, that in such cases, customers must select a long distance carrier to transport the data across a LATA boundary, without any Ameritech involvement. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 16. In the Computer III proceeding, the Commission established nine specific CEI requirements, which are discussed below. The CEI requirements are designed to give ESPs equal and efficient access to the basic services that the BOCs use to provide their own enhanced services. Ameritech has described in its submissions how it will satisfy each of the nine requirements. No parties objected to Ameritech's CEI plan for EVS. We review below Ameritech's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 17. The unbundling requirement obligates a 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. 18. Ameritech represents that it uses the following types of channels to provide EVS: (1) Direct Analog; (2) Base Rate; (3) DS1; (4) Fractional DS1; (5) DS3; (6) OC-3; (7) OC-12; (8) OC-48; and (9) Feature Group A. Ameritech states that, with the exception of four services -- Ameritech LAN Interconnect Service (ALIS), Ameritech Fiber Distributed Data Interface (FDDI), Integrated Service Digital Network (ISDN), and Centrex, all of these services are basic underlying services offered pursuant to currently effective Federal tariffs. 19. The remaining four services are offered pursuant to state tariffs. Ameritech explains that ALIS and FDDI use dedicated facilities to connect customer premises directly with the data vault, and that no switched data services or switched data network components are used. Ameritech states that it offers ALIS and FDDI only on an intrastate basis and that it will only use ALIS and FDDI on an intrastate basis in its provision of EVS. It further represents that there has been no demand by customers to use ALIS or FDDI to connect locations that require transport across state boundaries, such as where a LATA boundary crosses state boundaries in a corridor arrangement. Ameritech asks the Commission not to require federal tariffing of ALIS and FDDI services as a condition precedent to the approval of the EVS CEI plan. 20. At present, we waive the federal tariffing requirement for ALIS and FDDI, which are services that Ameritech makes available to unaffiliated ESPs pursuant to state tariff. Importantly, no parties have objected to Ameritech's CEI plan for EVS. If, in the future, a customer requests ALIS or FDDI on an interstate basis, Ameritech must federally tariff the requested service or seek a further waiver. 21. Generally, Centrex and ISDN services are tariffed at the state level as local exchange services. Some variants of ISDN, however, have been tariffed at the interstate level by interexchange carriers. Ameritech states that it offers Centrex and ISDN services only on an intrastate basis and that it will only use Centrex and ISDN on an intrastate basis in its provision of EVS. It asserts that there is no demand for federal ONA tariffing of Centrex and ISDN services. Ameritech notes that as a practical matter, interstate, intraLATA Centrex and ISDN capabilities may be obtained by using Feature Group A as a basic underlying service. Ameritech has added Feature Group A as an additional underlying basic service that a customer may use in conjunction with Centrex and ISDN services to allow dial-up access to the EVS service for interstate, intraLATA configurations. As a result, the Bureau agrees that Centrex and ISDN do not need to be tariffed at the federal level. 22. Ameritech states that it will take under tariff all basic underlying services currently used in the provision of its EVS service offering at the same rates and under the same terms and conditions that it provides these basic services to unaffiliated ESPs. It asserts that any other basic service which may later be used to support Ameritech's EVS offerings will be added as an amendment to Ameritech's CEI plan prior to its use. Ameritech asserts that because both state and federal tariffs specify the rates, terms, conditions, technical characteristics, and other items relevant to the CEI parameters, and because Ameritech will take all basic services at the same rates and under the same terms and conditions as are available to competing ESPs, the CEI parameters for EVS are fully satisfied. Based on Ameritech's representations, and conditioned upon the waiver of certain federal tariffing requirements discussed in the preceding paragraphs, we find that Ameritech's CEI plan complies with the Commission's unbundling requirement. 2. Interface Functionality 23. The interface functionality requirement obligates a 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." 24. Ameritech represents that its EVS offering and those of other ESPs will access Ameritech's network through existing, standard line-side and trunk-side network interfaces. Ameritech states that interconnection between its proposed EVS service and the underlying basic services will be achieved through existing, previously published standard network interfaces. Ameritech specifically represents that no special interfaces, signaling, abbreviated dialing, derived channels, or other special interface capabilities will be used to provide end-user access to Ameritech's EVS, and that all access arrangements will be available to competing ESPs pursuant to tariff on the same terms and conditions available to Ameritech's EVS. Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's interface functionality requirement. 3. Resale 25. The resale requirement established in Computer III obligates a carrier's enhanced service operations to take basic services, used in its enhanced service offerings, at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anticompetitive pricing in unregulated markets. 26. As set forth above, Ameritech states that for the provision of EVS, it will take under tariff all basic underlying services currently used in the provision of its EVS service offering, at the same rates and under the same terms and conditions that it provides these basic services to unaffiliated ESPs. It asserts that any other basic service which may later be used to support Ameritech's EVS offerings will be added as an amendment to Ameritech's CEI plan prior to its use. Ameritech asserts that because both state and federal tariffs specify the rates, terms, conditions, technical characteristics, and other items relevant to the CEI parameters, and because Ameritech will take all basic services at the same rates and under the same terms and conditions as are available to competing ESPs, the CEI parameters for EVS are fully satisfied. Based on Ameritech's representations, and conditioned upon the waiver of certain federal tariffing requirements discussed in the preceding paragraphs, we find that Ameritech's CEI plan complies with the Commission's resale requirement. 4. Technical Characteristics 27. This requirement obligates a carrier to provide basic services with technical characteristics that are equal to the technical characteristics the carrier uses for its own enhanced services. 28. Ameritech states that connection to EVS is accomplished only through existing standard network interfaces. It represents that EVS interconnection does not rely on, or otherwise require, any change to previously disclosed standard network interfaces. Ameritech states that links will be purchased by Ameritech's EVS service at the same rates and under the same terms and conditions as they are available to unaffiliated ESPs. Because there are no new network changes to existing network interfaces required to provide EVS, Ameritech maintains that there is nothing additional to disclose under the Commission's network disclosure rules. 29. Ameritech represents that the same line-side and trunk-side network interfaces will be used to support transmission, switching, and signaling functions for Ameritech's EVS offering as for competing ESP services. Ameritech asserts that the interfaces will be identical in their transmission parameters, quality, reliability, and other relevant characteristics. Ameritech states further that its offering uses a broad spectrum of transport channels, ranging from analog to OC- 48, at the same rates and under the same terms and conditions as are available to unaffiliated providers. Ameritech further represents that it will continue to file annual affidavits attesting that appropriate procedures have been followed and that no discrimination with regard to technical characteristics has occurred. Based on Ameritech's representations, we conclude that Ameritech has met the requirement of parity with respect to the technical characteristics of its proposed offering. Accordingly, we find that Ameritech's CEI plan comports with the Commission's technical characteristics requirement. 5. Installation, Maintenance, and Repair 30. This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in a CEI offering are the same as those a carrier provides to its own enhanced service operations. Carriers also must satisfy reporting and other requirements showing that they have met this requirement. 31. Ameritech represents that its internal methods for installing, maintaining, and repairing all of its basic services are sufficiently automated that any systematic discrimination in installation and maintenance of services would be extremely difficult. Moreover, it asserts that any attempts to discriminate would be of such a widespread and obvious nature as to be immediately detectable to customers and to unaffiliated ESPs. Ameritech states that detailed descriptions of its installation, maintenance, and repair practices were previously provided as attachments to the six CEI plans filed with the Commission on March 13, 1995. It represents that no changes have been made to those practices since that time. Ameritech also represents that it will continue to file annual reports demonstrating that there has been no discrimination. Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's installation, maintenance, and repair requirement. 6. End-User Access 32. This requirement obligates a carrier to provide to all end users the same abbreviated dialing and signalling capabilities that are needed to activate or obtain access to enhanced services that use the carrier's facilities. This requirement provides 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. 33. Ameritech asserts that end users of the electronic vaulting services of unaffiliated ESPs will be able to obtain access to tariffed services at the same rates and under the same terms and conditions as are available to end users of EVS. It represents that the operational characteristics of end-user access to Ameritech's EVS and end-user access to the services of unaffiliated ESPs will be identical in all respects and that no abbreviated dialing, signaling arrangements, or special derived channel access arrangements are uniquely associated with Ameritech's offering. Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's end-user access requirement. 7. CEI Availability 34. This requirement obligates a carrier providing or marketing a CEI offering to make that CEI offering available and fully operational on the date that it offers its corresponding enhanced service to the public. The requirement also obligates a carrier to provide a reasonable period of time prior to that date when prospective users of the CEI offering can use the CEI facilities and services for purposes of testing their enhanced service offerings. Consequently, the Commission has required the BOCs to notify unaffiliated ESPs in advance about the impending deployment of new basic services. As noted above at paragraph six, the BOCs are required to file the appropriate state and federal tariffs for their ONA services. In addition, the Commission has separately stated that a carrier's CEI plan should contain a description of the geographic areas in which it will offer the enhanced service, as well as the network locations within those areas through which it will provide such service. 35. Ameritech represents that its EVS will utilize underlying basic network services at the same rates and under the same terms and conditions as those services are available to unaffiliated providers of competing services. Further, Ameritech indicates that it will take such basic underlying services under tariff. Ameritech states that in all cases, the basic underlying services have been available under tariff for more than 90 days. Ameritech asserts that, prior to using any new or additional basic services to support its EVS offering, it will file amendments to its EVS CEI plan, and will give unaffiliated ESPs adequate notice of its intentions. Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's CEI availability requirement. 8. Minimization of Transport Costs 36. This requirement obligates carriers to provide other ESPs with interconnection facilities that minimize transport costs. 37. Ameritech represents that interconnection to all facilities used to provide the underlying basic services supporting EVS will be offered under tariff. Ameritech states that its offering will use a broad spectrum of transport channels, ranging from analog to OC-48 channels, which will be available to any ESP at the same rates and under the same terms and conditions as are available to Ameritech's EVS. Ameritech represents that where it collocates its EVS equipment with basic network facilities, a distance-based transport component will be charged to its affiliate in order to maintain parity with unaffiliated ESPs which are not collocated and, therefore, must pay for transport. It further represents that if other access arrangements are made available to Ameritech's EVS customers in the future, they will also be made available to unaffiliated EVS providers at the same time, at the same rates and under the same terms and conditions. Based on Ameritech's representations that all underlying basic services are currently available under tariff to ESPs in all of the jurisdictions served by Ameritech, as required, we find that Ameritech's CEI plan comports with the Commission's minimization of transport costs requirement. 9. Recipients of CEI 38. This requirement prohibits a carrier from restricting the availability of the CEI offering to any particular class of customer or enhanced service competitor. 39. Ameritech represents that none of the basic underlying services used to provide EVS will be limited to any class of customer or service provider. According to Ameritech, all such services will be accessible by all users for any lawful purpose. Based on Ameritech's representations, we find that Ameritech has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 40. In addition to the CEI requirements established in the Computer III proceeding, a BOC proposing to provide enhanced services on a structurally integrated basis must comply with requirements regarding the use of customer proprietary network information (CPNI), disclosure of network information, and nondiscrimination reporting. 1. Customer Proprietary Network Information 41. Under the Commission's Computer III requirements, Ameritech is required to describe the procedures it intends to establish to comply with the Commission's CPNI safeguards. In addition, section 222 of the 1996 Act contains CPNI requirements. Although the requirements of section 222 became effective immediately upon enactment, the Commission has initiated a proceeding to consider regulations interpreting and specifying in more detail, a telecommunications carrier's obligations under this provision. In the Notice initiating this proceeding, the Commission tentatively concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent that they do not conflict with section 222. 42. Ameritech represents that it will continue to comply with the Commission rules and requirements regarding the use of CPNI. Ameritech states that when the Commission completes its pending CPNI rulemaking, it will update its practices and procedures in order to insure full compliance with any additional requirements imposed pursuant to the 1996 Act. Based on Ameritech's representations that it will comply with the Commission's pre-existing Computer III CPNI requirements to the extent that they are consistent with section 222 of the 1996 Act, as well as with any additional requirements that are imposed by the 1996 Act, we find that Ameritech's CEI plan comports with the Commission's CPNI requirements. 2. Network Information Disclosure 43. Ameritech 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. Ameritech must make that disclosure at the "make/buy" point, that is, when Ameritech decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface. Ameritech 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. Ameritech also must publicly disclose technical information about a new or modified network service twelve months before that service is introduced. If a BOC is able to introduce the service within twelve months of the make/buy point, however, it may make public disclosure at the make/buy point. It may not, however, introduce the service earlier than six months after the public disclosure. BOCs need not describe network disclosure procedures in their CEI plans, because they are obligated to obey those rules. 44. Ameritech represents that interconnection between its proposed EVS and the basic underlying services will be achieved through existing, previously published standard network interfaces. Consequently, Ameritech asserts that no changes to existing network interface specifications or publication of any new interfaces are required. In the context of this CEI plan, we interpret Ameritech's representations to mean, inter alia, that interconnection between unaffiliated ESPs and the underlying basic services will be achieved through existing, previously published standard network interfaces. Insofar as Ameritech changes any existing network interface specification or uses a new interface specification for basic underlying services, it must comply fully with the Commission's network disclosure rules, including any changes in those requirements. Based on Ameritech's representations, we find that this aspect of its CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 45. BOCs are required to file quarterly nondiscrimination reports with respect to their basic services, thereby ensuring that they provide the access promised in their CEI plans. Ameritech represents that it will continue to abide by the Commission's existing nondiscrimination reporting rules and that it will track and report on a quarterly basis the installation and maintenance intervals for basic services provided to its affiliated enhanced service operations (including Ameritech's EVS operations), compared to installation and maintenance intervals for basic services provided to unaffiliated ESPs. It asserts that these reports will continue to demonstrate that no discrimination with respect to these intervals has occurred. Based on our interpretation of Ameritech's representations, we find that this aspect of its CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 46. The BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These procedures consist of five principal elements: (1) the Commission's Part 32 Uniform System of Accounts requirements and cost allocation standards; (2) the requirement that BOCs file cost allocation manuals reflecting their accounting rules and cost allocation standards; (3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with its cost allocation manual; (4) development of an automated system to store and analyze data necessary to respond to the Commission's detailed reporting requirements; and (5) on-site audits by Commission staff. Ameritech must comply with these accounting safeguards. V. CONCLUSION 47. We conclude that Ameritech's CEI plan for EVS complies with the Commission's Computer III requirements. If Ameritech offers new enhanced services not described in this CEI plan, or if Ameritech uses additional, underlying basic services, it must file a CEI plan amendment. Accordingly, in this Order we approve Ameritech's CEI plan for EVS, as described herein. VI. ORDERING CLAUSES 48. IT IS HEREBY ORDERED that, pursuant to sections 1, 4(i) and 4(j), 201, 202, 203, 205, 218, and 222 of the Communications Act of 1934, as amended, 47 U.S.C.  1, 1.3, 4(i) and 4(j), 201, 202, 203, 205, 218, and 222, and authority delegated thereunder pursuant to sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91 and 0.291, Ameritech's Comparably Efficient Interconnection Plan for Electronic Vaulting Service hereby is APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger Jr. Chief Common Carrier Bureau