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A. 1. a.(1)(a) i) a) X #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)  Federal Communications Commission`<(#BDA 972715 ă yxdddy   Њ4& Before the Federal Communications Commission !Washington, D.C. 20554 ă In the Matter of )  ) CCBPol 9703 Ameritech's Comparably Efficient ) Interconnection Plan for ) Electronic Vaulting Service ) ' ORDER ă Adopted: December 31, 1997 Released: December 31, 1997 By the Chief, Common Carrier Bureau: ! TABLE OF CONTENTS ă Paragraph   I. INTRODUCTIONp`"(#I 1  II. BACKGROUNDp`"(#I 3 A.CEI Plansp`"(#I 3 ` ` ` B.The Telecommunications Act of 1996p`"(#I 7  III. SERVICE DESCRIPTIONp`"(#I 8  IV. COMPLIANCE ISSUESp!(#H 16 ` ` ` A.` ` ` CEI Plan Requirementsp!(#H 16 ` ` ` ` ` 1. Unbundling of Basic Servicesp!(#H 17 ` ` ` ` ` 2. Interface Functionalityp."(#H 23 ` ` ` 3. Resalep!(#H 25 ` ` ` 4. Technical Characteristicsp!(#H 27 ` ` ` 5. Installation, Maintenance, and Repair p."(#H 30` ` ` 6. EndUser Accessp!(#H 32 ` ` ` 7. CEI Availabilityp!(#H 34 ` ` ` 8. Minimization of Transport Costsp!(#H 36 ` ` ` 9. Recipients of CEIp!(#H 38 XXB.Other Nonstructural Safeguardsp."(#H 40 ` ` ` ` ` 1.Customer Proprietary Network Informationp."(#H 41 ` ` ` ` ` 2.Network Information Disclosurep!(#H 43 ` ` ` ` ` 3.Nondiscrimination Reportingp."(#H 45 C.` ` ` Accounting Safeguardsp!(#H 46  V. CONCLUSIONp!(#H 47 s# I. INTRODUCTION ă  On February 27, 1997, pursuant to the requirements of the Commission's decisions in the Computer III proceeding,#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmendment of Section 64.702 of the Commission's Rules and Regulations, CC Docket No. 85229, Phase I, 104 FCC 2d 958 (1986) (Computer III Phase I Order), recon., 2 FCC Rcd 3035 (1987) (Computer III Phase I Reconsideration Order), further recon., 3 FCC Rcd 1135 (1988) (Computer III Phase I Further Reconsideration Order), second further recon., 4 FCC Rcd 5927 (1989) (Computer III Phase I Second Further Reconsideration), Computer III Phase I Order and Phase I Reconsideration Order, vacated, California v. FCC, 905 F.2d 1217 (9th Cir. 1990) (California I); Phase II, 2 FCC Rcd 3072 (1987) (Computer III Phase II Order), recon., 3 FCC Rcd 1150 (1988) (Computer III Phase II Reconsideration Order), further recon., 4 FCC Rcd 5927 (1989) (Computer III Phase II Further Reconsideration Order), Computer III Phase II Order vacated, California I, 905 F.2d 1217 (9th Cir. 1990); Computer III Remand Proceedings, 5 FCC Rcd 7719 (1990) (ONA Remand Order), recon., 7 FCC Rcd 909 (1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993) (California II); Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier 1 Local Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards Order), vacated in part and remanded, California v. FCC, 39 F.3d 919 (9th Cir. 1994) (California III), cert. denied, 115 S.Ct. 1427 (1995) (referred to collectively as 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.#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech's Plan To Provide Comparably Efficient Interconnection To Providers of Electronic Vaulting Services, filed Feb. 27, 1997 (Ameritech EVS CEI Plan). 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).W#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  P G;P#эComputer III Phase I Order, 104 FCC 2d at 964965,  45.W Prior to offering an enhanced service, a BOC must obtain Commission approval of its CEI plan.  The Common Carrier Bureau (Bureau) issued a public notice concerning Ameritech's CEI plan on March 10, 1997.#Xj\  P G;XP# I. A. 1. a.(1)(a) i) a)#X\  P G;P#эSee Pleading Cycle Established for Comments on Ameritech's Plan for Comparably Efficient Interconnection to Providers of Electronic Vaulting Service, Public Notice, DA 97505 (Com. Car. Bur., rel. Mar. 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 ă A.` ` ` CEI Plans    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 crosssubsidization and discrimination.X0ÍX0Í#Xj\  P G;XP# I. A. 1. a.(1)(a) i) a)#X\  P G;P# ÍComputer III Remand Proceedings: Bell Operating Company Safeguards; and Tier 1 Local Exchange Company Safeguards, CC Docket No. 90623, Notice of Proposed Rulemaking and Order, 6 FCC Rcd 174, 175,  9 (1990). As a first step in implementing the Computer III framework, the Commission permitted the BOCs, which remained subject to various structural separation requirements, to offer individual enhanced services on an integrated basis following approval of servicespecific CEI plans.]#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase I Order, 104 FCC 2d at 10341059,  142200.] 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.  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 servicespecific CEI plans.X0ÍX0ÍX#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P# ÍId. at 10191021,  113115, & 10591068,  201222.X 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.  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 crosssubsidization 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.<#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эCalifornia III, 39 F.3d at 927, 929. < The court concluded that the costbenefit 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." #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эId. at 929." In response to the California III decision, the Commission initiated a rulemaking proceeding to review the existing nonstructural safeguards against BOC access discrimination. #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee Computer III Further Remand Proceedings: Bell Operating Company Provision of Enhanced Services, CC Docket No. 9520, Notice of Proposed Rulemaking, 10 FCC Rcd 8360, 837475,  1922 (1995) (Computer III Further Remand Proceedings). For a more detailed history of rules governing the BOCs' participation in the enhanced services market, see id. at  310.  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. #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee Bell Operating Companies' Joint Petition for Waiver of Computer II Rules, 10 FCC Rcd 1724, 23 (1995) (Bureau Interim Waiver Order). 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. #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эThe Bureau subsequently approved the BOCs' CEI plans for these other existing enhanced services. See Bell Operating Companies Joint Petition for Waiver of Computer II Rules, 10 FCC Rcd 13758 (1995) (BOC CEI Plan Approval 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. #Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee Bureau Interim Waiver Order, 10 FCC Rcd at 172829,  22; see also Filing and Review of Open Network Architecture Plans, 4 FCC Rcd 1 (1988) (BOC ONA Order), recon. 5 FCC Rcd 3084 (1990) (BOC ONA Reconsideration Order), 5 FCC Rcd 3103 (1990) (BOC ONA Amendment Order), Erratum, 5 FCC Rcd 4045, pets. for review denied, California II, 4 F.3d 1505 (9th Cir. 1993), recon., 8 FCC Rcd 97 (1993) (BOC ONA Amendment Reconsideration Order), 6 FCC Rcd 7646 (1991) (BOC ONA Further Amendment Order), 8 FCC Rcd 2602 (1993) (BOC ONA Second Further Amendment Order), pet. for review denied, California II, 4 F.3d 1505 (9th Cir. 1993) . In April 1994, the Commission decided to apply the Computer III and ONA requirements to GTE Corporation. Application of Open Network Architecture and Nondiscrimination Safeguards to GTE Corporation, 9 FCC Rcd 4922 (1994) (GTE ONA Application Order). 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.#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee Bureau Interim Waiver Order,10 FCC Rcd at 172829,  22; BOC ONA Order, 4 FCC Rcd at 116,  226. B.` ` ` The Telecommunications Act of 1996  On February 8, 1996, the Telecommunications Act of 1996 (1996 Act) became law.Z#Xj\  P G;XP# I. A. 1. a.(1)(a) i) a)#X\  P!G;P#эTelecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56 (1996 Act), codified at 47 U.S.C.  151 et seq. All citations to the 1996 Act in this Order are to the 1996 Act as it is codified in the United States Code. The 1996 Act amended the Communications Act of 1934 (Communications Act).Z Section 272 of the 1996 Act addresses the provision by BOCs of, inter alia, interLATA information services.#Xj\  P"G;XP# I. A. 1. a.(1)(a) i) a)#X\  P#G;P#э47 U.S.C.  272. The Commission defines the term "BOC" as that term is defined in 47 U.S.C. 153(4). The Commission defines the term "LATA" as that term is defined in 47 U.S.C. 153(25). #c P$7P#  On December 24, 1996, the Commission adopted rules to implement the nonaccounting separate affiliate and nondiscrimination safeguards of sections 271 and 272.E#Xj\  P%G;XP# I. A. 1. a.(1)(a) i) a)#X\  P&G;P#эImplementation of the Non-Accounting Safeguards of Sections 271 and 272 of the Communications Act of 1934, as amended, CC Docket No. 96-149, First Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd 21905 (1996) (Non-Accounting Safeguards Order), recon., Order on Reconsideration, 12 FCC Rcd 2297 (1997), petition for review pending sub nom., SBC Communications v. FCC, No. 97-1118 (D.C. Cir., filed Mar. 6, 1997), remanded in part sub nom. Bell Atlantic Telephone Companies v. FCC, No. 97-1067 (D.C. Cir., filed Mar. 31, 1997, on remand, Second Order on Reconsideration, FCC 97-222 (rel. June 24, 1997)), petition for review pending sub nom. Bell Atlantic Telephone Companies, No. 97-1423 (D.C. Cir., filed July 11, 1997).E In the NonAccounting 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.#Xj\  P'G;XP# I. A. 1. a.(1)(a) i) a)#X\  P(G;P#эNonAccounting Safeguards Order, 11 FCC Rcd at 2196970,  132. The Commission has determined that all of the services that the Commission has previously considered to be "enhanced services" are "information services." Id. at 2195556,  102. Since Ameritech uses the term enhanced services in its CEI plan, however, we use the term for purposes of this Order. The Commission's ONA rules provide a mechanism for competitors to obtain access to network elements and facilities used in the provision of information services. See Computer III Further Remand Proceedings, 10 FCC Rcd at 837475,  1922. The ONA requirements apply to the BOCs regardless of whether they provide information services on an integrated or separated basis. See ONA Remand Order, 5 FCC Rcd at 772021,  1115. 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.o#Xj\  P)G;XP# I. A. 1. a.(1)(a) i) a)#X\  P*G;P#эNonAccounting Safeguards Order, 11 FCC Rcd at 2196162,  115, & 2196970,  132.o Ameritech represents that it will offer EVS solely on an intraLATA basis.X0ÍX0Í#Xj\  P+G;XP# I. A. 1. a.(1)(a) i) a)#X\  P,G;P#X` hp x (#%'0*,.8135@8:G;P#эId. at 2, 4.# 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."#Xj\  P?G;XP# I. A. 1. a.(1)(a) i) a)#X\  P@G;P#эId. at 56." 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. #Xj\  PAG;XP# I. A. 1. a.(1)(a) i) a)#X\  PBG;P#эId.   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 "dialup" arrangement.  #Xj\  PCG;XP# I. A. 1. a.(1)(a) i) a)#X\  PDG;P#эId. at 6.  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.)!#Xj\  PEG;XP# I. A. 1. a.(1)(a) i) a)#X\  PFG;P#эId. at 34, 67. ) Ameritech acknowledges that customers using the dialup 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.h"#Xj\  PGG;XP# I. A. 1. a.(1)(a) i) a)#X\  PHG;P#эId. at 7. Ameritech notes that the Commission has concluded that where the necessary interLATA transmission component is separately provided by another carrier, an information service is not considered interLATA merely because it may be accessed on an interLATA basis by means independently chosen by the customer, such as a presubscribed interexchange carrier. Id. at 4 n.1 (citing NonAccounting Safeguards Order, 11 FCC Rcd at 2196263,  117118). The Commission held that when a BOC is neither providing nor reselling the interLATA transmission component of an information service that may be accessed across LATA boundaries, the statute does not require that service to be provided through a section 272 separate affiliate. NonAccounting Safeguards Order, 11 FCC Rcd at 2196263,  117.h  IV. COMPLIANCE ISSUES ă A. CEI Plan Requirements  In the Computer III proceeding, the Commission established nine specific CEI requirements, which are discussed below.]##Xj\  PIG;XP# I. A. 1. a.(1)(a) i) a)#X\  PJG;P#эComputer III Phase I Order, 104 FCC 2d at 10391043,  154166.] 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.^$#Xj\  PKG;XP# I. A. 1. a.(1)(a) i) a)#X\  PLG;P#эComputer III Phase I Reconsideration Order, 2 FCC Rcd at 3048,  91.^ 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  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.%#Xj\  PMG;XP# I. A. 1. a.(1)(a) i) a)#X\  PNG;P#эComputer III Phase I Order, 104 FCC 2d at 1040,  158. The BOCs and GTE must file state and federal tariffs for their ONA services. See BOC ONA Amendment Order, 5 FCC Rcd at 3105,  13 (1990); BOC Safeguards Order, 6 FCC Rcd at 7624 n.212; BOC ONA Order, 4 FCC Rcd at 11671,  224325; see also NYNEX Telephone Companies Offer of Comparably Efficient Interconnection to Providers of Enhanced Services, 11 FCC Rcd 2419 n.61 (1996); Pacific Bell and Nevada Bell Petition for Removal of the Structural Separation Requirement and Waiver of Certain Federal and State Tariffing Requirements, 8 FCC Rcd 3982, 398384, 1011 (1993). Nonproprietary information used by the carrier in providing the unbundled basic services must be made available as part of CEI.V&#Xj\  POG;XP# I. A. 1. a.(1)(a) i) a)#X\  PPG;P#эComputer III Phase I Order, 104 FCC 2d at 1040,  158.V In addition, any options available to a carrier in the provision of such basic services or functions must be included in the unbundled offerings.'#Xj\  PQG;XP# I. A. 1. a.(1)(a) i) a)#X\  PRG;P#эId.  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) OC48; and (9) Feature Group A.\(#Xj\  PSG;XP# I. A. 1. a.(1)(a) i) a)#X\  PTG;P#эAmeritech June 19 Letter at Attachment Y; Ameritech November 3 Letter at 1.\ 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.)#Xj\  PUG;XP# I. A. 1. a.(1)(a) i) a)#X\  PVG;P#эAmeritech June 19 Letter at 78, Attachments Y & Z; Ameritech EVS CEI Plan at Attachment B; Ameritech November 3 Letter at 1.  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.4*#Xj\  PWG;XP# I. A. 1. a.(1)(a) i) a)#X\  PXG;P#эAmeritech November 3 Letter at 12.4 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.X0ÍX0Í!+#Xj\  PYG;XP# I. A. 1. a.(1)(a) i) a)#X\  PZG;P# ÍId. at 34.! 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.",#Xj\  P[G;XP# I. A. 1. a.(1)(a) i) a)#X\  P\G;P#эId. at 45."  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.-#Xj\  P]G;XP# I. A. 1. a.(1)(a) i) a)#X\  P^G;P#эPursuant to section 1.3 of the Commission's rules, the Commission may grant a waiver of a provision of its rules upon a showing of "good cause." 47 C.F.R.  1.3. As construed by the U.S. Court of Appeals for the District of Columbia Circuit, section 1.3 allows the Commission to grant a waiver if special circumstances warrant a deviation from the general rule and such a deviation will serve the public interest. Northeast Cellular Telephone Co., L.P. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (citing WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972)); Industrial Broadcasting, Co. v. FCC, 437 F.2d (680, 683 (D.C. Cir. 1970). 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.  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.X0ÍX0Í.#Xj\  P_G;XP# I. A. 1. a.(1)(a) i) a)#Xj\  P`G;XP# Í#X\  PaG;P#See e.g., AT&T Tariff F.C.C. No. 9, Section for a Primary Rate Interface Offering. 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 dialup access to the EVS service for interstate, intraLATA configurations.X0ÍX0ÍO/#Xj\  PbG;XP# I. A. 1. a.(1)(a) i) a)#X\  PcG;P# ÍAmeritech November 3 Letter at 1; Feature Group A is federally tariffed. See Bell Atlantic Petition for Declaratory Ruling Concerning Application of the Commission's Access Charge Rules to Private Telecommunications Systems, Memorandum Opinion and Order, (Rel. Dec. 18, 1987) Mimeo FCC 87361.O As a result, the Bureau agrees that Centrex and ISDN do not need to be tariffed at the federal level.  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.Q0#Xj\  PdG;XP# I. A. 1. a.(1)(a) i) a)#X\  PeG;P#эAmeritech EVS CEI Plan at 56; Ameritech June 19 Letter at 78.Q 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.21#Xj\  PfG;XP# I. A. 1. a.(1)(a) i) a)#X\  PgG;P#эAmeritech November 3 Letter at 5.2 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  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."P2#Xj\  PhG;XP# I. A. 1. a.(1)(a) i) a)#X\  PiG;P#эComputer III Phase I Order, 104 FCC 2d at 1039,  157.P  Ameritech represents that its EVS offering and those of other ESPs will access Ameritech's network through existing, standard lineside and trunkside 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.X3#Xj\  PjG;XP# I. A. 1. a.(1)(a) i) a)#X\  PkG;P#эAmeritech EVS CEI Plan at 5, 10; Ameritech June 19 Letter at 56.X Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's interface functionality requirement.  3. Resale  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 costshifting to regulated operations and anticompetitive pricing in unregulated markets.P4#Xj\  PlG;XP# I. A. 1. a.(1)(a) i) a)#X\  PmG;P#эComputer III Phase I Order, 104 FCC 2d at 1040,  159.P֌ 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.Q5#Xj\  PnG;XP# I. A. 1. a.(1)(a) i) a)#X\  PoG;P#эAmeritech EVS CEI Plan at 56; Ameritech June 19 Letter at 78.Q 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.26#Xj\  PpG;XP# I. A. 1. a.(1)(a) i) a)#X\  PqG;P#эAmeritech November 3 Letter at 5.2 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  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.X0ÍX0ÍO7#Xj\  PrG;XP# I. A. 1. a.(1)(a) i) a)#X\  PsG;P# ÍComputer III Phase I Order, 104 FCC 2d at 1041,  160.O  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.8#Xj\  PtG;XP# I. A. 1. a.(1)(a) i) a)#X\  PuG;P#эAmeritech EVS CEI Plan at 6 (citing 47 C.F.R.  51.325 (1996)); Ameritech June 19 Letter at 56; Ameritech November 3 Letter at 2.  Ameritech represents that the same lineside and trunkside 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 OC48, at the same rates and under the same terms and conditions as are available to unaffiliated providers.m9#Xj\  PvG;XP# I. A. 1. a.(1)(a) i) a)#X\  PwG;P#эAmeritech EVS CEI Plan at 67 and Attachment B; Ameritech June 19 Letter at 7, Attachment Y.m 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./:#Xj\  PxG;XP# I. A. 1. a.(1)(a) i) a)#X\  PyG;P#эAmeritech EVS CEI Plan at 67./ 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  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.P;#Xj\  PzG;XP# I. A. 1. a.(1)(a) i) a)#X\  P{G;P#эComputer III Phase I Order, 104 FCC 2d at 1041,  161.P Carriers also must satisfy reporting and other requirements showing that they have met this requirement.<#Xj\  P|G;XP# I. A. 1. a.(1)(a) i) a)#X\  P}G;P#эId. Ameritech must provide quarterly reports on installation and maintenance of its basic services. Id. at 10551056,  192193.   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.=#Xj\  P~G;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 7 & n.10. See BOC CEI Plan Approval Order at  7779. Ameritech also represents that it will continue to file annual reports demonstrating that there has been no discrimination.->#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 7.- Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's installation, maintenance, and repair requirement.  6. EndUser Access  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.P?#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase I Order, 104 FCC 2d at 1041,  162.P  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 enduser 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.@#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee BOC CEI Plan Approval Order, 10 FCC Rcd at 13758; see also Computer III Phase I Order, 104 FCC 2d at 1041,  161; Ameritech EVS CEI Plan at 78; Ameritech June 19 Letter at 56. Based on Ameritech's representations, we find that Ameritech's CEI plan comports with the Commission's enduser access requirement.  7. CEI Availability  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.^A#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase I Order, 104 FCC 2d at 1041,  163. The testing period is necessary "to balance the conflicting interests of the carrier, which should have a reasonable period to develop, test, and 'debug' its CEI offerings before making them publicly available, and other CEI users, such as competitors, that might suffer an unfair competitive disadvantage if carriers were able to test and perfect their . . . services particularly, their interconnection with the basic underlying facilities while withholding those same basic facilities from others." Id.^ Consequently, the Commission has required the BOCs to notify unaffiliated ESPs in advance about the impending deployment of new basic services.B#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee id., 104 FCC 2d at 1068,  221222. Under the ONA regime, a BOC wishing to offer an enhanced service that uses a new Basic Service Element or otherwise uses different arrangements for underlying basic services than those set forth in its ONA plan must file an amendment to its plan with the Bureau at least 90 days prior to offering that enhanced service. See, e.g., Bell Operating Companies' Joint Petition for Waiver of Computer II Rules, Ameritech's Request for Waiver Related to Minor Amendment to Ameritech's Plan to Provide Comparably Efficient Interconnection to Providers of Voice Mail Messaging Service, Order, 11 FCC Rcd 14624 (Com. Car. Bur. 1996).  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.C#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эSee Southwestern Bell Telephone Company, Comparably Efficient Interconnection Plan for the Provision of Voice Messaging Services, 3 FCC Rcd 6912, at 6914,  19 (1988); see also Ameritech's Offer of Comparably Efficient Interconnection to Providers of Message Delivery Service, 11 FCC Rcd 5590, at 55975599,  2224 (1996).   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.2D#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech June 19 Letter at 2, 7.2 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.OE#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 8; Ameritech June 19 Letter at 2, 7.O 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.QF#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 56; Ameritech June 19 Letter at 78.Q 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  This requirement obligates carriers to provide other ESPs with interconnection facilities that minimize transport costs.PG#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase I Order, 104 FCC 2d at 1042,  164.P    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 OC48 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 distancebased 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.H#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 89, Attachment B; Ameritech June 19 Letter at 78, Attachment Y; Ameritech November 3 Letter at 3. 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  This requirement prohibits a carrier from restricting the availability of the CEI offering to any particular class of customer or enhanced service competitor.PI#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase I Order, 104 FCC 2d at 1042,  165.P  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.-J#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 9.- 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  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.XK#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase II Order, 2 FCC Rcd at 3082,  7375. X  1.Customer Proprietary Network Information  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.3L#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эId. at 3095,  156.3 In addition, section 222 of the 1996 Act contains CPNI requirements.$M#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#э47 U.S.C.  222.$ 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.N#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эImplementation of the Telecommunications Act of 1996, Telecommunications Carriers' Use of Customer Proprietary Network Information and other Customer Information, Notice of Proposed Rule Making, 11 FCC Rcd 12513, at  2 (1996) (CPNI NPRM). 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.O#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эCPNI NPRM, 11 FCC Rcd at 12515,  3 (noting that to the extent the 1996 Act requires more of a carrier, or imposes greater restrictions on a carrier's use of CPNI, the statute governs).  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.P#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 10 & nn.16, 17. Ameritech represents that detailed descriptions of Ameritech's practices were previously provided as attachments to the six CEI Plans filed by Ameritech with the Commission on March 13, 1995. Ameritech represents that no significant changes have been made to these practices since that time. See BOC CEI Plan Approval Order,10 FCC Rcd at 13770,  7779. Based on Ameritech's representations that it will comply with the Commission's preexisting 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  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.UQ#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эComputer III Phase II Order, 2 FCC Rcd at 3086,  102, 107.U 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.:R#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эId. at 30913093,  134140.: Ameritech also must publicly disclose technical information about a new or modified network service twelve months before that service is introduced.-S#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эId. at 3092,  136.- 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.AT#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эBOC ONA Order, 4 FCC Rcd at 252,  490.A  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..U#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эAmeritech EVS CEI Plan at 10.. 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  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.X0ÍX0ÍV#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P# ÍSee BOC ONA Reconsideration Order, 5 FCC Rcd 3084, 3096, app. B (1990), BOC ONA Amendment Order, 5 FCC Rcd 3103, 3120 (1990), Erratum, 5 FCC Rcd 4045, pets. for review denied, California II, 4 F.3d 1505, (9th Cir. 1993), recon., 8 FCC Rcd 7646, (1991), BOC ONA Second Further Amendment Order, 8 FCC Rcd 2606 (1993), pet. for review denied, California II, 4 F.3d 1505, (1993); Phase II Order, 2 FCC Rcd at 3082,  73.  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.<W#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#э  Ameritech EVS CEI Plan at 910. < 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 Č 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) onsite audits by Commission staff.HX#Xj\  PG;XP# I. A. 1. a.(1)(a) i) a)#X\  PG;P#эBOC Safeguards Order, 6 FCC Rcd at 7591,  46.H Ameritech must comply with these accounting safeguards. #V. CONCLUSION ă  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 ă  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