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I.Xa2IndentedLeft-indented text?C ? A.` ` 2^a3IndentedLeft-indented textHP ? ` ` 1. a4IndentedLeft-indented textQp- ? ` `  a.` 'a5IndentedLeft-indented text[ܽ ? ` `  '(1) hh-a6IndentedLeft-indented textdK ? ` `  'hh-(a)42s}a7IndentedLeft-indented textl݇ ? ` `  'hh-4i)h:a8IndentedLeft-indented textu-b ? ` `  'hh-4:a)ppAa1InterrogatoresStarts with A. at margin, 1 at first indentUZZI.a1OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4$ 2:ka2OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4/ a3OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4: a4OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4E a5OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4P   2,Fa6OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4[   a7OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4f  a8OutlineE+O4*ÿUI. A. 1. a. (1) (a) i) a)4 =(O4WGl *O4q Leventhal6@6wwLeventhal, Senter & Lerman Doc Style*O4ÿUVGl.EQ    #XN\  PXP#2h^rjqa1DAKBt*3  S'1.` ` a3DAKa1for ordersenter, tab, parnum, two spaces5Q0 6"]J  1. a2InterrogatoroDStarts with A. at margin, 1 at first indentk*<KL2^qq q|qa3InterrogatoroDStarts with A. at margin, 1 at first indentk*<MNa4InterrogatoroDStarts with A. at margin, 1 at first indentk*<OPa5InterrogatoroDStarts with A. at margin, 1 at first indentk*<QRa6InterrogatoroDStarts with A. at margin, 1 at first indentk*<ST2@qqrrZa7InterrogatoroDStarts with A. at margin, 1 at first indentk*<UVa8InterrogatoroDStarts with A. at margin, 1 at first indentk*<WXa4DAKآy.X80,ɒX\  P6G;P2a=5,u&a\  P6G;&P2e=5,&e4  pG;&\0_=5,%&_*f9 xr G;&XP:% ,J:\  P6G;JPH5!,),5\  P6G;,P\{,W80,%BZW*f9 xr G;X&y.\80, [\4  pG;DDDpLpLpLNE7'@@LP@H;GTU4> H;G0FONTDIRFONTS$SY2\ry.X80,ɒX\  P6G;P2a=5,u&a\  P6G;&P2e=5,&e4  pG;&\0_=5,%&_*f9 xr G;&XP:% ,J:\  P6G;JPH5!,),5\  P6G;,P\{,W80,%BZW*f9 xr G;Xy.\80,>\4  pG;earning Guide   jH )^ `> Xi S'   S' #&I\  P6Qu&P# Federal Communications Commission DA 981585 Đ  S' 1` Before the pp  *xxX   FEDERAL COMMUNICATIONS COMMISSION 0Washington, D.C. 20554  S`'  S8' In the Matter of) ) Telmex/Sprint Communications, L.L.C.) )  S'Application for Authority under)ppFile No. ITC97127 Section 214 of the Communications) Act for Global Authority to Operate as an ) International Switched Resale Carrier) Between the United States and) International Points, Including Mexico) X\(#  S 'j ORDER ă  S0'` ` Adopted: August 7, 1998qReleased: %NH  August 7, 1998 %NH  xxX  I. A. 1. a.(1)(a) i) a) 1. 1. 1. a.(1)(a) i) a)  S'By the Chief, International Bureau:  S' ` ` A I. INTRODUCTION ă  S@'1.` ` In this Order, we find that Telmex/Sprint Communications, L.L.C. ("TSC") has  S'demonstrated that it has satisfied the conditions set forth in the October 30, 1997 TSC Order$Y yO'ԍXTSC Application for Authority under Section 214 of the Communications Act for Global Authority to Operate as an International Switched Resale Carrier Between the United States and International Points,  {O'including Mexico, Order, Authorization and Certificate, 12 FCC Rcd 17551 (1997), application for  {O'review pending (TSC Order).(#ƿ as conditions precedent to the effectiveness of TSC's Section 214 authorization. We accordingly authorize TSC to commence service consistent with the terms and conditions set forth in its authorization. The Commission will address the significant issues raised in opposition to this  Sz'authorization in a timely way in the pending application for review of the TSC Order.  S,'` ` A II. BACKGROUND ă  S'2.` ` On February 27, 1997, TSC filed an application to obtain Section 214LY yO0"'ԍX47 U.S.C.  214.(#L authority to provide international switched resale services between the United States and all international points,"D0*&&(("  S'including Mexico. TSC proposed to resell Sprint's facilitiesbased services.+XY yOh'ԍXTSC Application for Authority under Section 214 of the Communications Act for Global Authority to Operate as an International Switched Resale Carrier Between the United States and International Points, including Mexico (Feb. 27, 1997) at 8. (#+ On October 30, 1997,  S'the International Bureau conditionally granted TSC's authorization.AY {O`'ԍTSC Order.A More specifically, the Bureau found that in order for TSC's authorization to become effective, TSC's affiliate, Tel)fonos de M)xico, S.A. de C.V. ("Telmex") would be required to demonstrate that it had offered to amend its operating agreements with U.S. carriers to implement a monthly proportionate return methodology for the  S8'redistribution of southbound traffic.8zY {OR 'ԍXId. at  100. This methodology is sometimes referred to as "1/1/1," and is different from the current approach which operates on a quarterly basis ("4/4/4").(# In addition, the Order required Telmex to demonstrate that it had offered other U.S. carriers the onestop shopping and Paid 800 service agreements on the same terms  S'and conditions as it has made such agreements available to Sprint.GY {O\'ԍId. at  101.G  S'3.` ` On November 14, 1997, counsel for TSC filed a letter with the Commission stating  Sp'that Telmex had satisfied the conditions set forth in the TSC Order.pf Y yOv'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Gary Epstein, counsel for TSC (Nov. 14, 1997)  yO>'(TSC Nov. 14, 1997 letter).(# TSC attached copies of letters from Telmex to AT&T, MCI and WorldCom that purported to (a) offer to amend Telmex's operating agreements with each of those carriers to implement the 1/1/1 proportionate return methodology; and (b) offer those carriers onestop shopping and Paid 800 agreements on the same terms and conditions  S 'on which Telmex has made such agreements available to Sprint.S Y {O0'ԍId. at 12 and Attachment A.S On November 25, 1997 AT&T filed  S 'a letter objecting to Telmex's Paid 800 service agreement offer.  P Y yO'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Judy Simonson, AT&T (Nov. 25, 1997) (AT&T Nov. 25, 1997 letter).(#ƭ The International Bureau convened a status conference on December 1, 1997. On January 9, 1998, counsel for TSC filed a letter with the Commission stating that Telmex had amended its Paid 800 service offer to AT&T, MCI and  S2'WorldCom. 2Y yOz 'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Gary Epstein, counsel for TSC (Jan. 9, 1998) (TSC Jan. 9, 1998 letter).(#ƴ TSC attached to this letter copies of letters from Telmex to AT&T, MCI and  S 'WorldCom revising Telmex's previous offer of the Paid 800 service agreements.N Y {O#'ԍId. at 2 and Exhibit A.N In response, AT&T, MCI and Americatel Corporation ("Americatel") filed letters generally objecting to Telmex's" 0*&&(("  S'Paid 800 service offer as insufficient. Y yOh'ԍXLetter to Diane Cornell, Chief, Telecommunications Division, Int'l Bur., FCC, from Lawrence Lafaro, AT&T (Jan. 9, 1998) (AT&T Jan. 9, 1998 letter); letter to Magalie Roman Salas, Secretary, FCC, from John Scorce, MCI (Jan. 15, 1998) (MCI Jan. 15, 1998 letter); and letter to Magalie Roman Salas, Secretary, FCC, from Raul Rodriguez, counsel for Americatel (Jan. 22, 1998) (Americatel Jan. 22, 1998 letter).(# On May 26, 1998, TSC filed a letter clarifying Telmex's Paid  S'800 service offer and stating that all conditions for the 214 authorization had been met. xY yO'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Luis L;pez Rojo, Chief Executive Officer, TSC (May 26, 1998) (TSC May 26, 1998 letter).(# MCI, AT&T, Americatel, Westel International ("Westel") and IXC Communications, Inc. ("IXC") filed  S'letters opposing Telmex's claim that it had fulfilled the conditions.@Y yO 'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Michael J. Rowny, MCI (June 5, 1998) (MCI June 5, 1998 letter); letter to Magalie Roman Salas, Secretary, FCC, from Raul Rodriguez, counsel for Americatel (June 5, 1998) (Americatel June 5, 1998 letter); letter to Magalie Roman Salas, Secretary, FCC, from CathyAnn Martine, AT&T (June 5, 1998) (AT&T June 5, 1998 letter); letter to William E. Kennard, Chairman, FCC, from Rick D. Bailey, AT&T (June 17, 1998) (AT&T June 17 letter); letter to Magalie Roman Salas, Secretary, FCC, from Gwen M. Rowling, Westel (June 5, 1998) (Westel June 5, 1998 letter); letter to Magalie Roman Salas, Secretary, FCC, from Gary L. Mann, IXC (June 5, 1998) (IXC June 5, 1998 letter).(# Counsel for TSC filed a letter with the Commission on June 22, 1998, clarifying the record with respect to two points, which was  S8'opposed by MCI, AT&T and Americatel.+8Y yO'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Gary Epstein, counsel for TSC (June 22, 1998) (TSC June 22, 1998 letter); Letter to Magalie Roman Salas, Secretary, FCC, from John M. Scorce, MCI (June 29, 1998) (MCI June 29, 1998 letter); Letter to Magalie Roman Salas, Secretary, FCC, from Judy Simonson, AT&T (June 29, 1998) (AT&T June 29, 1998 letter); Letter to Magalie Roman Salas, Secretary, FCC, from Raul Rodriguez, counsel for Americatel (July 8, 1998) (Americatel July 8, 1998 letter).(#+ MCI and AT&T also subsequently made an ex parte  S'presentation to the Commission.PY {O'ԍXEx parte presentation by AT&T and MCI (Aug. 4, 1998) (Aug. 4, 1998 Ex Parte presentation).(#Ɵ  S'  S'F III. DISCUSSION ă  S'  Sr'4.` ` As noted above, pursuant to the TSC Order, TSC's Section 214 authorization can only become effective once Telmex demonstrates that it has offered: 1) to amend its operating agreements with U.S. carriers to implement a monthly proportionate return methodology for the redistribution of southbound traffic; 2) other U.S. carriers onestop shopping agreements under the same terms and conditions on which Telmex has made such agreement available to Sprint; and 3) other U.S. carriers Paid 800 service agreements on the same terms and conditions on which Telmex has made such  S 'agreement available to Sprint.U Y {O%'ԍTSC Order at  100101.U We will now consider whether Telmex has satisfied each of these" t0*&&((N " conditions in turn.  S'5.` ` Methodology for calculating proportionate return. In its November 14 letter, TSC states that Telmex offered to amend its operating agreements with AT&T, MCI and WorldCom to  S`'implement a monthly proportionate return methodology for the redistribution of southbound traffic.]`Y yO'ԍTSC Nov. 14, 1997 letter at 2 and Exhibit A.] None of the U.S.licensed carriers filed an objection to the sufficiency of Telmex's offer. At the December 1, 1997 status conference, there was general agreement among the U.S. carriers that Telmex had satisfied this condition of TSC's Section 214 authorization. We therefore conclude that Telmex has fulfilled its requirement to offer to amend its operating agreements with AT&T, MCI and WorldCom to implement a monthly proportionate return methodology for the redistribution of southbound traffic.  S '6.` ` Onestop shopping agreements. In its November 14, 1997 letter, TSC states that Telmex offered other U.S. carriers onestop shopping agreements on the same terms and conditions as  S 'it has made such agreement available to Sprint.: XY {O'ԍId.: At the December 1, 1997 status conference, there was general agreement among the U.S. carriers that Telmex had satisfied this condition of TSC's Section 214 authorization. AT&T, however, in its June 5, 1998 letter, states that Telmex has not yet  SX'agreed to the operating procedures requested by AT&T.WXY yO'ԍXAT&T June 5, 1998 letter at 1.(#W In its June 22, 1998 letter, Telmex informs the Commission that it has in fact reached agreement with AT&T on operating procedures and AT&T  S'will be able to commence service.WzY yO"'ԍXTSC June 22, 1998 letter at 1.(#W In that same letter, Telmex confirms that all issues relating to the  S'negotiation of onestop shopping agreements between it and AT&T and MCI have been resolved.B Y {O'ԍXId.(#B  S'MCI claims that Telmex has not yet documented necessary operating procedures and processes.OY yO'ԍMCI June 29, 1998 letter at 1.O While these operational procedures are certainly necessary to commence service, the underlying agreements with AT&T and MCI are sufficient to fulfill Telmex's obligation to offer all other U.S. carriers onestop shopping agreements on the same terms and conditions as it has made such agreement available to Sprint. Therefore, we conclude this condition is satisfied.  S'7.` ` Paid 800 service agreements. In its November 14, 1997 letter, TSC states that Telmex offered other U.S. carriers Paid 800 service agreements on the same terms and conditions as it has  Sx'made such agreement available to Sprint.Ux, Y yOD$'ԍTSC Nov. 14, 1997 letter at 2.U AT&T objected to Telmex's Paid 800 service offer in its"x 0*&&(("  S'November 25, 1997 letter.PY yOh'ԍAT&T Nov. 25, 1997 letter at 1.P At the status conference, Telmex agreed to amend its Paid  S'800 service to make it consistent with the Commission's International Settlements Policy (ISP).XY yO'ԍXThe ISP requires nondiscriminatory accounting rates, sharing of tolls, and settlement rates among U.S. carriers providing the same service to the same foreign point. The ISP also requires that U.S. carriers  {O`'accept only their proportionate share of return traffic. See Implementation of Uniform Settlements  {O*'Policy for Parallel International Communications Routes, 51 Fed. Reg. 4736 (1986); Reconsideration, 2  {O'FCC Rcd 1118 (1987); Further Reconsideration, 3 FCC Rcd 1614 (1988). In 1991, the Commission  {O'reformed the ISP to encourage and facilitate accounting rate reductions by U.S. carriers. See Regulation  {O 'of International Accounting Rates, 6 FCC Rcd 3553 (1991); Reconsideration, 7 FCC Rcd 8049 (1992);  {OR 'Regulation of International Accounting Rates, 7 FCC Rcd 8040 (1992). In 1996, the Commission  {O 'codified the proportionate return policy. See Fourth Report and Order on Regulation of International  {O 'Accounting Rates, 11 FCC Rcd 20063 (1996).(# More specifically, Telmex offered to include Paid 800 traffic in proportionate return calculations for international message telephone service traffic and to make the offer retroactive to January 1996, when Telmex initiated this service with Sprint. On January 9, 1998, counsel for Telmex filed a letter with the Commission indicating that it had amended its Paid 800 service offers to U.S. carriers  S'consistent with its representations at the December 1, 1997, status conference.Y Y yO'ԍXTSC Jan. 9, 1998 letter. (#Y Further, Sprint filed a  S'letter clarifying the nature of its service agreement with Telmex. Y yO'ԍXLetter to Magalie Roman Salas, Secretary, FCC, from Kent Nakamura, General Attorney, Sprint (Jan. 20, 1998) (Sprint Jan. 20, 1998 letter).(# AT&T, MCI and Americatel filed  S'letters with the Commission objecting to Telmex's amended Paid 800 service offer.Y yOH'ԍAT&T Jan. 9, 1998 letter; MCI Jan. 15, 1998 letter; and Americatel Jan. 22, 1998 letter.  Sp'8.` ` The U.S. carriers argue that Telmex attempted to place conditions or limitations on its offer that the International Bureau should find unacceptable. Specifically, they claim that Telmex's offer to include Paid 800 traffic in proportionate return calculations is conditioned on all U.S.  S 'correspondents reaching agreement with Telmex by February 1, 1998.x xY {O'ԍSee AT&T Jan. 9, 1998 letter at 1; MCI Jan. 15, 1998 letter at 2.x In its May 26, 1998 letter, TSC clarifies that Telmex's offer is not conditioned on its reaching such an agreement by February 1, 1998. Rather, Telmex's offer to provide Paid 800 traffic on a retroactive basis and subject to proportionate return will remain open until agreements are reached with U.S. carriers on the same  SX'terms and conditions as have been made available to Sprint. In their June 5, 1 998 letters, MCI and Westel contend that the Paid 800 offer is still conditioned on agreement by all U.S. carriers, pointing  S'to a letter from Telmex to MCI. Y yO#'ԍXMCI June 5, 1998 letter at 7; Westel June 5, 1998 letter at 2, citing letter from Domingo Asiain, Telmex, to Anthony Vettoretti, MCI (Apr. 30, 1998) (annexed to MCI June 5, 1998 letter).(# But that Telmex letter makes clear that it is only the truingup of"b0*&&((" traffic that is affected by the agreement or rejection of a Paid 800 agreement with all potential U.S.  S'carriers. Telmex's June 22, 1998, letter reaffirmed the Paid 800 arrangement was without conditions.Y Y {O@'ԍSee TSC June 22, 1998 letter at 2.Y In light of TSC's letters of clarification, we find that Telmex has indeed offered U.S. carriers Paid 800 service agreements on the same terms and conditions as it has made such an agreement available to Sprint.  S'9. Second, U.S. carriers object to Telmex's offer because it fails to lay out specifically  S'how Telmex will include Paid 800 traffic retroactively in proportionate return calculations.Q!ZY yO 'ԍMCI Jan. 15, 1998 letter at 12.Q In order for the offer to be complete, MCI claims that it "needs to know the amount of traffic that will be sent to it; how that amount is calculated; the time in which the trueup will be completed; and a timetable  Sp'that will enable MCI to determine when the processes will be completed."c"pY {O 'ԍId.; see also MCI June 5, 1998 letter.c AT&T argues that Telmex is willing to trueup traffic only after an extended period of time and that the Commission should require Telmex to compensate U.S. carriers before its 214 authorization goes into effect or, at  S 'most, no later than 60 days thereafter.W# |Y yO'ԍXAT&T June 5, 1998 letter at 2.(#W  S ' 10.` ` At the December 1, 1997 status conference, Telmex conceded that, consistent with the Commission's ISP, Telmex must include Paid 800 traffic in its proportionate return calculations retroactive to January 1996. Under the ISP, U.S. carriers must receive proportionate return traffic from foreign carriers in a nondiscriminatory manner. The ISP does not further specify how or when such traffic is allocated among U.S. carriers, or even which types of traffic must be included in proportionate return. Consistent with the ISP, Telmex is required to distribute Paid 800 traffic to U.S. carriers on a nondiscriminatory basis, retroactive to January 1996. Telmex agreed to do so in its January 9, 1998 letter and confirmed in its June 22, 1998 letter that it has made two proposals to  Sh'AT&T and MCI with respect to the methodology for truing up Paid 800 traffic.W$h Y yO'ԍXTSC June 22, 1998 letter at 2.(#W AT&T and MCI  S@'have not accepted Telmex's proposals.B%@Y {O|'ԍXId.(#B MCI argues that Telmex's trueup proposals are incomplete  S'and lack essential information.O&. Y yO 'ԍMCI June 29, 1998 letter at 1.O AT&T states that Telmex has provided inconsistent information  S'concerning the amount of money owed to AT&T and has failed to provide needed traffic data.Q' Y yON#'ԍAT&T June 29, 1998 letter at 1. Q  S' 11. ` ` We do not agree with AT&T or MCI that agreement on the method and timing for"N '0*&&((("  S'trueup of traffic is necessary in order to fulfill the Section 214 condition. The TSC Order required only that Telmex offer U.S. carriers Paid 800 service agreement on the same terms and conditions as it has made such agreement available to Sprint. That it has done. We do reiterate, however, that our ISP requires Telmex to trueup Paid 800 traffic retroactive to January 1996. We will continue to monitor this trueup process closely. We instruct the parties to report back to us within one month of the date of release of this Order on the trueup arrangements which have been negotiated.  S' 12.` ` U.S. carriers also object to Telmex's offer on the grounds that it is limited to  S'northbound traffic only.(Y yO* 'ԍXAT&T Jan. 9, 1998 letter at 2; MCI Jan. 15, 1998 letter at 2; AT&T June 5, 1998 letter; Americatel June 5, 1998 letter.(#ư They insist that they should be able to take advantage of this service for  S'southbound traffic also. For the following reasons, we disagree. The TSC Order required only that Telmex offer other U.S. carriers Paid 800 service agreements on the same terms and conditions as it has made such agreement available to Sprint. In its letters to U.S. carriers clarifying its Paid 800 service agreement offer, Telmex states that its agreement with Sprint governs only northbound  S 'traffic.) Y {O'ԍSee TSC Jan. 9, 1998 letter at Exhibit A; see also TSC May 26, 1998 letter. Additionally, Sprint states in its January 20, 1998 letter that its Paid 800 agreement with  S 'Telmex only covers northbound traffic.P* Y yO&'ԍSprint January 20, 1998 letter.P The TSC Order did not require Telmex to offer U.S. carriers a Paid 800 service agreement that exceeds in scope Telmex's agreement with Sprint. Because Telmex offered U.S. carriers the same agreement that it has with Sprint, we find that Telmex's offer satisfies  S^'the requirements of the TSC Order and the Commission's rules.+z^BY yO@'ԍXIn its letters to U.S. carriers clarifying its Paid 800 service agreement offer, Telmex appears willing to  {O'negotiate agreements with U.S. carriers covering future southbound Paid 800 service. See TSC Jan. 9, 1998 letter at Exhibit A ("Should U.S. carriers wish to negotiate an agreement relating to southbound Paid 800 traffic in the future, Telmex will be pleased to discuss such matters"). In the event that Telmex reaches such an agreement with any U.S. carrier, it must make the agreement available to all other U.S. carriers on the same terms and conditions, consistent with the Commission's ISP and "no special concessions" policies.(#  S' 13.` ` We note that a number of the issues raised by carriers regarding Paid 800 will be affected by our decision in a companion order today rejecting the settlement rate proposed by Sprint  S'for Paid 800 service.n,\ Y {O'ԍXSee Sprint Communications L.P., Petition for Waiver of the International Settlements Policy for  {O 'Establishment of a Settlement Rate for Paid 800 Service with Mexico, Order on Reconsideration, File  yOx!'No. ISP97M701, DA 98 1586 (rel. Aug. 7, 1998).(#n We found in that Order that Sprint had not established that lowering settlement rates for northbound Paid 800 traffic would benefit consumers through improved services, increased competition or lower rates.   S"' 14.` ` Finally, the U.S. carriers argue that Telmex impermissibly made its offer subject to"",0*&&(("  S'any contrary future rulings by the Commission or Cofetel, the Mexican telecommunications regulator.-Y yOh'ԍAT&T Jan. 9, 1998 letter at 2; MCI Jan. 15, 1998 letter at 2; MCI June 5, 1998 letter at 7. We disagree for the following reasons. First, there is no evidence to support a belief that Cofetel would insist that Telmex maintain exclusive arrangements with U.S. carriers in contravention of Commission rules. Second, were Cofetel to make such a ruling, it would not restrict our ability to ensure that U.S.licensed carriers in correspondence with Telmex comply with Commission rules, including our ISP and "no special concessions" rule. Third, should Telmex take actions in response to Commission rulings, we can always review those actions for consistency with the terms of TSC's license. We therefore conclude that this conditional language in Telmex's offer does not restrict our ability to ensure that U.S. carriers receive nondiscriminatory treatment by Telmex.  Sp'15.` ` We therefore find that Telmex has offered to all U.S. carriers Paid 800 service agreements on the same terms and conditions as it has made such agreement available to Sprint. In addition, we find that Telmex has agreed to include Paid 800 traffic in proportionate return calculations and has made its offer to U.S. carriers retroactive to January 1996, when it initiated this service with Sprint.  S '16.` ` U.S. carriers present a number of other reasons why the Commission should not allow  SX'TSC to commence service.d.ZXXY yOP'ԍXAT&T June 5, 1998 letter at 23; AT&T June 17, 1998 letter at 1; MCI June 5, 1998 letter at 24; Americatel June 5, 1998 letter at 3; Westel June 5, 1998 letter at 12; IXC June 5, 1998 letter at 12;  {O'Americatel July 8, 1998 letter at 2; Aug. 4, 1998 Ex Parte Presentation.(#d They argue that Mexico does not afford competitive conditions to U.S. carriers; Telmex's proposed settlement rates for 1998 and 1999 do not comply with the Commission's  S'Benchmarks Order and the surcharge imposed on international calls is discriminatory./zY {O"'ԍXInternational Settlement Rates, Report and Order, 12 FCC Rcd 19806 (1997) (Benchmarks Order).(#Ƣ Americatel urges the Commission to revoke the authorization because there are inadequate competitive safeguards  S'in Mexico.U0 Y yOf'ԍAmericatel July 8, 1998 letter at 2.U MCI points out that the Bureau relied on certain expectations in granting the 214  S'authorization and none of the Bureau's expectations have been met.N1Y yO'ԍMCI June 5, 1998 letter at 2.N  SB'17. ` ` We recognize that the issues raised in the responsive pleadings are extremely important. The Bureau did have certain expectations in issuing the 214 authorization regarding issuance of Mexican regulations on resale and accounting separation, as well as a quick end to the  S'discriminatory surcharge on international calls.\2, Y {O"'ԍSee TSC Order at  23, 36, 80.\ We acknowledge that these expectations have not yet been met and other issues have been raised that merit careful consideration. The Commission will  Sz'consider these expectations and issues in the pending application for review of the TSC Order and in"z 20*&&(("  S'the decision on Sprint's application for approval of a new settlement rate with Telmex.3Y yOh'ԍXApplication of Sprint for International Settlements Policy Modification for Change in Accounting Rates for International Switched Voice Service with Mexico, ISP97M708 (Oct. 28, 1997).(# This Order  S'addresses only the very narrow subject of whether the conditions set out in the TSC Order have been  S'met.4 Y yOt'ԍXTelmex argues that its application is subject to Commission rules implementing U.S. commitments in  {O<'the World Trade Organization.  See Telmex May 26, 1998 letter, citing Rules and Policies on Foreign  {O'Participation in the U.S. Telecommunications Market, Report and Order and Order on Reconsideration,  {O'12 FCC Rcd 23891 (1997), recon pending (Foreign Participation Order). According to Telmex, these  yO 'rules preclude the Commission from conditioning or denying Telmex's license on the basis of issues  {Ob 'such as settlement rates. MCI argues that the Foreign Participation Order does not apply to Telmex's  {O, 'current license because it was issued before the effective date of that Order. MCI June 5, 1998 letter at  {O '5. We need not address this issue in this Order, as we are authorizing Telmex to provide service here based on fulfillment of the conditions described above. But the Commission will consider the issue in  {O 'the pending application for review of the International Bureau's TSC Order.(#   Sd'18.` ` MCI and AT&T also allege that Telmex has entered into yet another exclusive cross S<'border service arrangement with Sprint in violation of the Commission's rules.15Z< Y {O'ԍXSee MCI Jan. 15, 1998 letter and Letter to Magalie Roman Salas, Secretary, FCC from Ellen Spano, Senior Attorney, AT&T (Jan. 29, 1998) (AT&T Jan. 29, 1998 letter) (alleging discriminatory arrangement for Telmex's LADA Collect Service). (#1 In addition, AT&T alleges that Telmex may be illegally diverting away from AT&T Telmexoperator handled O+ collect  S'traffic.S6Y yOt'ԍXAT&T Jan. 29, 1998 letter.(#S MCI alleges that Telmex is discriminating against MCI's Mexican affiliate in its Plan LADA  S'Operadores.V7xY yO'ԍXMCI June 5, 1998 letter at 3.(#V MCI and AT&T also indicate that Telmex is discriminating against its competitors in  S'private line provisioning in violation of its commitment made in the context of the TSC Order, and  Sv'that Telmex is discriminating in its provision of international payphone services.Z8vY {O'ԍAug. 4, 1998 Ex Parte Presentation.Z Finally, Westel  SN 'alleges that Mexico's proportionate return policy unfairly favors Telmex.Y9N Y yO'ԍXWestel June 5, 1998 letter at 1.(#Y We reiterate that all U.S.authorized carriers continue to be subject to our "no special concessions" rule and are forbidden to benefit from any exclusive or preferential arrangements with Telmex that have not been previously approved by the Commission. Should we determine that Sprint or any other U.S.authorized carrier is benefitting from a special concession or that TSC is violating any of the terms of this authorization, we will take appropriate enforcement action. We decline, however, to delay the effectiveness of TSC's authorization on the basis of these allegations. The scope of our analysis in this Order is the  S6'fulfillment of the narrow conditions specified in the TSC Order. As indicated previously, these allegations are more appropriately addressed in other proceedings. Moreover, any further delay would" *90*&&((" deprive consumers of the benefit of competition from TSC.  S'19. ` ` We emphasize that we are very concerned by allegations which have been raised with respect to anticompetitive activities by Telmex affecting competition in the U.S. international services market. We will continue to monitor conditions in this market closely to ensure that anticompetitive conduct by TSC or its affiliates does not adversely affect competition in this market. MCI and AT&T suggest that the Bureau impose a number of conditions as part of authorizing TSC to commence  S'service to address concerns with anticompetitive activities.Z:Y {OP'ԍAug. 4, 1998 Ex Parte Presentation.Z Many of the conditions proposed by AT&T and MCI relate to the original grant of authority and, as noted above, will be addressed by the Commission in other proceedings. We have decided, however, to condition grant of this authorization expressly on TSC or its affiliates not engaging in anticompetitive actions which will give TSC an unfair advantage in the U.S. international services market. If we find evidence of such anticompetitive conduct, we reserve the right to impose substantial forfeitures or suspend or terminate this  S 'authorization for failure to meet the conditions of the grant.; ZY {O'ԍSee also 47 C.F.R. 63.21(g) and Foreign Participation Order at  295.pp  S '20. ` ` AT&T asked that any order issued by the Bureau not become effective for a period of  S 'ten days in order to provide AT&T with an opportunity to seek a stay.< Y yO 'ԍXLetter to Regina Keeney, FCC, from Rick D. Bailey, AT&T (June 25, 1998) (AT&T June 25, 1998 letter).(#Ɲ We conclude that the public interest does not warrant further delaying TSC's commencement of service, which will benefit U.S. consumers by introducing additional competition in the international services market.   S'` ` B IV. CONCLUSION ă  S'21.` ` In conclusion, we find that TSC's affiliate, Telmex, has fulfilled all the conditions requisite to the effectiveness of TSC's Section 214 authorization. We remind TSC and Telmex that they remain subject to all the factors and conditions upon which we concluded in October 1997 that  S'grant of TSC's 214 application would serve the public interest.=DY {O'ԍXSee Letter of Regina M. Keeney, Chief, Int'l Bur., FCC, to Luis L;pez Rojo, TSC (June 2, 1998).(#ơ  S'- V. ORDERING CLAUSES ă  Sx'22. ` ` Accordingly, it is HEREBY ORDERED that TSC's Section 214 authorization IS EFFECTIVE, subject to compliance with this Order and those factors and conditions contained in the  S('TSC Order.  S'23.` ` IT IS FURTHERED ORDERED that this authorization is conditioned on TSC or its affiliates not engaging in anticompetitive actions which give TSC an unfair advantage in the U.S." =0*&&((" international services market.  S'24.` ` This order is effective upon adoption. Petitions for reconsideration under Section  S'1.106 of the Commission's rules may be filed within 30 days of the public notice of this order (see Section 1.4(b)(2) of the Commission's rules). ` `  hhCFEDERAL COMMUNICATIONS COMMISSION ` `  hhCRegina M. Keeney  SJ '` `  hhCChief, International Bureau Đ S" '