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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 ) ) Southwestern Bell Telephone Company's) Comparably Efficient Interconnection ) Plan for the Provision of Basic Payphone) Services ) CC Docket No. 96-128 ) Implementation of the Pay Telephone ) Reclassification and Compensation ) Provisions of the Telecommunications ) Act of 1996 ) ORDER Adopted: April 15, 1997 Released: April 15, 1997 By the Deputy Chief, Common Carrier Bureau: TABLE OF CONTENTS Paragraph I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. SERVICE DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . 6 IV. COMPLIANCE ISSUES . . . . . . . . . . . . . . . . . . . . . . . 10 A. CEI Plan Requirements . . . . . . . . . . . . . . . . . 10 B. Other Nonstructural Safeguards. . . . . . . . . . . . . . 49 C. Accounting Safeguards . . . . . . . . . . . . . . . . . . 59 D. Other Issues. . . . . . . . . . . . . . . . . . . . . . . 60 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 VI. ORDERING CLAUSE . . . . . . . . . . . . . . . . . . . . . . . . . 89 I. INTRODUCTION 1. On December 30, 1996, pursuant to the requirements of the Commission's orders in the payphone rulemaking proceeding, Southwestern Bell Telephone Company (SWBT) filed a comparably efficient interconnection (CEI) plan for payphone service. In that proceeding, the Commission directed each Bell Operating Company (BOC) to file an initial CEI plan describing how it will comply with the Commission's Computer III CEI equal access requirements and nonstructural safeguards for the provision of payphone services. BOCs must make available on a nondiscriminatory basis the regulated basic services they provide to independent payphone service providers (PSPs) and to the BOCs' own payphone operations to provide payphone services. 2. The Commission issued a public notice of SWBT's CEI plan on January 8, 1997. On February 7, 1997, six parties filed comments opposing the plan. SWBT submitted reply comments on February 24, 1997. For the reasons discussed below, we approve SWBT's CEI plan. II. BACKGROUND 3. The payphone rulemaking proceeding implemented section 276 of the Communications Act of 1934, as amended. Section 276 directed the Commission to prescribe a set of nonstructural safeguards for BOC payphone service to implement the statute's requirements that any BOC: (1) shall not subsidize its payphone service directly or indirectly from its telephone exchange or exchange access service operations; and (2) shall not prefer or discriminate in favor of its payphone service. The Act provided that such safeguards must, at a minimum, include the nonstructural safeguards adopted in the Computer III proceeding. 4. In the Payphone Order, the Commission determined that the Computer III and Open Network Architecture (ONA) nonstructural safeguards would "provide an appropriate regulatory framework to ensure that BOCs do not discriminate or cross-subsidize in their provision of payphone service." Accordingly, the Commission required the BOCs to file "CEI plans describing how they will comply with the Computer III unbundling, CEI parameters, accounting requirements, CPNI requirements as modified by [s]ection 222 of the 1996 Act, network disclosure requirements, and installation, maintenance, and quality nondiscrimination requirements." Obtaining approval of their CEI plans is one of the criteria BOCs must meet before their payphone operations may receive compensation for completed intrastate and interstate calls using a payphone under the new compensation plan established in the payphone proceeding. 5. The Payphone Order required BOCs to "provide tariffed, nondiscriminatory basic payphone services that enable independent [payphone service] providers to offer payphone services using either instrument-implemented 'smart payphones' or 'dumb' payphones that utilize central office coin services, or some combination of the two in a manner similar to the LECs." Those tariffs must be filed with the applicable state regulatory commission. Additionally, BOCs must file with the Commission tariffs for unbundled features or functions that are either used by a BOC's payphone operations to provide payphone service or offered by the BOC to unaffiliated PSPs on an unbundled basis. III. SERVICE DESCRIPTION 6. SWBT's basic payphone service is comprised of two separate and distinct services which are tariffed at the state level, pursuant to the Reconsideration Order, and several unbundled features which are tariffed at both the state and federal level. Both services permit the subscriber to elect either two-way or one-way originating only business exchange access service. These lines are provided and maintained by SWBT and provide access to and from the public switched telecommunications network for long distance service and local calling. SWBT asserts that its basic payphone service offering will be available to PSPs including SWBT's own nonstructurally separate payphone service operations. 7. SWBT offers a standard Customer Owned Pay Telephone Service (COPTS or COPT service) which is intended to be used by payphone providers that deploy "smart" payphones, where the CPE is programmed to collect coins, return coins and rate calls. COPTS is essentially identical to SWBT's typical business exchange access service and involves the provision of central office line equipment, all outside plant facilities needed to connect the serving central office with the customers premises, and the network interface. This service also includes automatic number identification (ANI) and 900/976 call blocking. SWBT explains that because most independent PSPs use "smart sets," they use COPTS lines to interconnect to SWBT's network. 8. SWBT also offers "SmartCoin" service which is generally used by payphone providers that deploy "dumb" or "network-controlled" payphones, where payphone functions are provided from a SWBT central office. SWBT maintains that SmartCoin service will offer the existing central office functionality of SWBT's basic payphone service to other PSPs, enabling them to utilize network-controlled sets, instead of "smart" sets. In addition to the features provided with the standard COPTS offering, SmartCoin service includes SWBT's operator services, outside plant facilities, and the following central office capabilities: Dial Tone First, Originating Line Screening, Coin Supervision, Coin Administration, Answer Supervision, Sent Paid Quotation, Automatic Rate Table, Automatic NPA-NXX. SWBT asserts that it will provide PSPs with the same toll detail reporting that is provided to subscribers of other SWBT local exchange services. PSPs may also request a "Customer Billing Report" which will provide additional information regarding SWBT recorded sent-paid calls originating from the SmartCoin access line. SWBT states that its payphone operations will primarily use SmartCoin service. 9. In addition to these payphone line services, SWBT will offer the following features on an unbundled basis to PSPs that subscribe to either of its basic payphone service offerings: 1. Selective Class of Call Screening Service (SCOCS). This service restricts outgoing operator handled calls placed over SWBT's network. SWBT will offer Basic SCOCS, Collect Only-Inmate Calls, and Coinless Only SCOCS. SWBT notes that SCOCS is not needed with the SmartCoin line and therefore is not available when a customer subscribes to its SmartCoin service offering. 2. Billed Number Screening. This service prevents callers from billing collect calls or bill-to-third number calls placed over SWBT's network to the number associated with the payphone line. 3. International Toll Blocking. This service arrangement provides central office blocking of direct-dialed international calls from coin-operated telephones to telephone numbers outside the North American Dialing Plan. 4. Answer Supervision-Line Side. This service provides "off-hook" supervisory signals to CPE that allows billing to begin when the called party answers. These signals originate from the "called" party's service central office to a line interface at the "calling" party's serving central office. IV. COMPLIANCE ISSUES A. CEI Plan Requirements 10. The Commission's CEI requirements were originally 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. As applied to the payphone context, the CEI requirements are designed to give independent PSPs equal and efficient access to the regulated basic payphone services that the BOCs use to provide their own payphone services. BOCs must also provide payphone services to independent PSPs on a nondiscriminatory basis as a required in the payphone rulemaking proceeding. The Commission, in its Computer III proceeding, established nine specific CEI requirements, which are discussed below. SWBT has described in its submissions how its will satisfy each of these nine CEI requirements. We review below SWBT's CEI plan with respect to each of these requirements. 1. Unbundling of Basic Services 11. The Payphone Order deregulated LEC payphones and classified those payphones as CPE. In addition to providing tariffed coin service so competitive payphone providers can offer payphone services using either "smart" payphones or "dumb" payphones that utilize central office coin services, a LEC must also tariff unbundled payphone features used by the LEC's operations to provide payphone services. Moreover, BOCs, but not other LECs, must unbundle additional network elements when requested by payphone providers based on the specific criteria established in the Computer III and ONA proceedings. 12. The Payphone Order requires BOCs to file CEI plans that explain how they will unbundle basic payphone services. Specifically, a BOC must indicate how it plans to unbundle, and associate with a specific rate element in the tariff, the basic services and basic service functions that underlie its provision of payphone service. Nonproprietary information used by the BOC in providing the unbundled basic services must be made available as part of CEI. In addition, any options available to the BOC in the provision of such basic services or functions must be included in the unbundled offerings. 13. SWBT asserts that the COPT and SmartCoin services, together with the various optional services described above, comprise its basic payphone offerings and will be available to any PSP, including its own payphone service operations at the same rates, and under the same terms and conditions, pursuant to state or federal tariffs in all jurisdictions currently served by SWBT. SWBT also states that any interLATA services offered to PSPs will be provided by carriers other than SWBT (and any affiliate) until SWBT or an affiliate become authorized to provide such services. Any additional intraLATA basic services that may be used to support SWBT's basic payphone service offering in the future will be added to its CEI plan by way of an amendment prior to their use by SWBT, in accordance with prior Commission rulings. Further, SWBT asserts that it will unbundle additional network elements when requested by PSPs, provided that the request meets the requirements set forth in Computer III and ONA. 14. APCC argues that SWBT's CEI plan must be rejected because SWBT's payphone service is not sufficiently unbundled. APCC contends that SWBT is required to offer the basic payphone lines for its COPT and SmartCoin services, and to offer separately the features and functionalities that SWBT provides as part of those basic payphone offerings. Specifically, as to SWBT's SmartCoin service offering, APCC maintains that PSPs must be able to subscribe to this coin line service without being required to take and pay for all of the "coin line-specific features," such as call screening, coin supervision, coin administration, and operator services, that SWBT proposes to provide as part of this service. APCC argues that such unbundling and separate tariffing are necessary to ensure that SWBT's payphone offerings are nondiscriminatory and free from improper cost allocation. 15. SWBT responds that its COPT and SmartCoin service offerings comply with the CEI unbundling requirement. SWBT claims that, contrary to APCC's assertion, the Commission did not require the unbundling of its SmartCoin service. It contends that BOCs are only obligated to unbundle in their state tariffs payphone features and functions that they provide to their own payphone operations. SWBT asserts that its tariffed offerings satisfy this requirement. If APCC members or other customers wish additional unbundling, SWBT states, the proper procedure is to submit a request to SWBT pursuant to established ONA procedures, not to object to its CEI plan. 16. We find that SWBT's plan satisfies the CEI unbundling requirement contained in the payphone rulemaking proceeding. The payphone rulemaking proceeding requires BOCs to offer transmission services that enable unaffiliated PSPs to offer payphone services using either a "smart"or "dumb" payphone or to offer inmate calling services. In addition, consistent with the payphone rulemaking proceeding requirements, BOCs must provide, on a tariffed basis, the unbundled features and functions they provide to unaffiliated PSPs or to their own payphone operations. SWBT's plan satisfies those requirements. We note, however, that SWBT may choose to unbundle additional functions and features, states may require further unbundling, and independent PSPs may request additional unbundled features and functions through the ONA 120-day service request process. Any other unbundled features and functions provided by SWBT must comply with the tariffing and CEI requirements of the payphone rulemaking proceeding, Computer III, and ONA. 17. We reject APCC's contention that SWBT must further unbundle its payphone services. As noted in the Clarification Order, the Commission's payphone orders "do not require that LECs unbundle more features and functions from the basic payphone line . . . than the LEC provides on an unbundled basis." In the Clarification Order, we stated that, for example, if a BOC provides answer supervision bundled with the basic payphone line, the BOC is not required either to unbundle that service from its state tariff for payphone service, or to tariff that feature at the federal level. If the LEC, however, provides answer supervision separately, on an unbundled basis, either to affiliated or unaffiliated PSPs, the LEC must tariff that feature in both the state and federal jurisdictions. Because SWBT offers, and will use, its SmartCoin service on a bundled basis, it need not unbundle the individual features that comprise that service in its CEI plan. Moreover, SWBT has unbundled the basic services and features that its own or other payphone operations will use and represents that these services and features will be available to all PSPs, including its own payphone operations, at the same tariffed rates, and under the same terms and conditions. SWBT is not required to unbundle from its basic payphone service offerings individual features or functions that are included in those offerings unless it is offering such features and functions on an unbundled basis to any PSP. Independent PSPs may seek further unbundling of SWBT's basic services by making a request pursuant to the ONA process. 2. Interface Functionality 18. The interface functionality requirement obligates a BOC to make available standardized hardware and software interfaces that are able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. 19. SWBT claims that it disclosed on January 15, 1997, the interface that it will use to provide access to its SmartCoin line service and that no new network disclosure is required for the existing standard line-side interface for the COPTS line. Further, SWBT asserts that if special interfaces, signaling, abbreviated dialing, or other unique capabilities are made available to SWBT's payphone service operations, they will be made available to other PSPs at the same time, in the same jurisdictions, and on the same terms and conditions. 20. According to Telco, "rather than explaining how it intends to provide interface functionality, [SWBT] fails to provide any technical details as to how PSPs will connect to the network interfaces." Although SWBT does not specifically respond to this assertion in its reply, it maintains that absent specific objections based on Computer III requirements, the Commission must approve its plan. 21. As stated above, the interface functionality requirement only obligates the BOC to make available standardized hardware and software interfaces that will be able to support transmission, switching, and signaling functions identical to those used by the BOC's payphone service. SWBT represents, and Telco does not deny, that it has done so. Beyond the filing of network disclosure, which SWBT claims that it has filed, this obligation does not require SWBT to provide technical details explaining how PSPs will connect to SWBT's network interfaces. We, therefore, reject Telco's objection and find that SWBT's CEI plan comports with the interface functionality requirement established by the Commission. 3. Resale 22. The resale requirement established in Computer III obligates a "carrier's enhanced service operations to take the basic services used in its enhanced service offerings at their unbundled tariffed rates as a means of preventing improper cost-shifting to regulated operations and anticompetitive pricing in unregulated markets." Based on the requirement in the Payphone Order and the Reconsideration Order, any basic services provided by a BOC to its payphone service operations, as well as any payphone service provided to others, must be available on a nondiscriminatory basis to other payphone providers. 23. SWBT represents that its payphone operations will subscribe to the underlying basic services at tariffed rates. We disagree with Telco's argument that this description is "too conclusory and vague to allow the Commission to understand exactly how [SWBT] will comply with this requirement." We find that SWBT's CEI plan, which states that SWBT's basic payphone services will be available on a nondiscriminatory basis to all PSPs, comports with the resale requirement established by the Commission. To the extent that Telco's objections are based on concerns that SWBT's tariffed payphone offerings unlawfully discriminate against unaffiliated PSPs, contrary to SWBT's express representation in this proceeding, such specific, fact-based claims should be addressed in federal or state tariff proceedings, or in a formal complaint action against SWBT. 4. Technical Characteristics 24. This requirement obligates a BOC to provide basic services with technical characteristics that are equal to the technical characteristics the BOC uses for its own payphone services. 25. SWBT represents that the technical characteristics of the underlying interfaces that will be used by SWBT to provide basic payphone service will be the same as those available to unaffiliated competitors that wish to use them in providing their own payphone offerings. Further, SWBT claims that its procedures for processing and assigning access lines will ensure that there will be no systematic discrimination in access line assignment based upon the identity of the customer or the proposed use. Telco does not challenge these representations, but asserts that SWBT should provide further detail to enable the Commission to determine that there will be no discrimination between affiliated and unaffiliated PSPs. We find that SWBT is not required by our CEI rules to furnish the additional information requested by Telco in order to satisfy the technical characteristics requirement. We therefore conclude that SWBT's CEI plan comports with the technical characteristics requirement established by the Commission. To the extent that Telco obtains credible evidence that SWBT has unlawfully discriminated against unaffiliated PSPs in the assignment of access lines, Telco may initiate a formal complaint action against SWBT. 5. Installation, Maintenance, and Repair 26. The Payphone Order requires that BOCs describe in their CEI plans how they will comply with the nondiscrimination requirements in Computer III and ONA regarding the quality of service, installation, and maintenance. This requirement ensures that the time periods for installation, maintenance, and repair of the basic services and facilities included in a CEI offering to unaffiliated PSPs are the same as those the BOC provides to its own or its affiliated payphone service operations. BOCs also must satisfy reporting and other requirements showing that they have met this requirement. 27. In its CEI plan, SWBT asserts that service ordering, installation, maintenance, and repair service used by its own payphone service operations will be performed in the same manner as they are for basic services purchased by unaffiliated PSPs. Further, SWBT maintains those services will be subject to the same scheduling procedures and time periods as for other PSPs. SWBT indicates that its internal methods for installing, maintaining, and repairing all of its basic services are sufficiently mechanized to prevent discrimination. Thus, SWBT asserts, its payphone operations will not be given any preference or priority over other PSPs, nor will its payphone operations have access to systems supporting basic service order entry, installation, maintenance, or repair functions unless such access is also available to other PSPs on nondiscriminatory terms. 28. APCC and Telco argue that SWBT's CEI plan must provide further detail regarding how it will provide installation and repair on a nondiscriminatory basis to unaffiliated PSPs in order to be able to evaluate whether nondiscriminatory procedures will in fact be in place. For instance, APCC contends that SWBT's plan must discuss the service ordering procedures that apply when a location provider changes from a SWBT payphone to an independent PSP or vice versa. APCC asserts that these procedures must be specified to ensure that conflicts that arise in this context are resolved in a nondiscriminatory fashion. APCC also argues that SWBT must specify the procedures that it will use to ensure that SWBT will not engage in unfair marketing practices when its payphones are replaced by independent payphones. 29. APCC further asserts that SWBT is required to explain whether it intends to share personnel between its operating company and payphone operations and, if so, the measures it will implement to ensure that the use of shared personnel will not lead to discrimination in the provision of installation, maintenance, and repair. In addition, APCC contends that SWBT should identify for its payphone offerings the demarcation point between the switched network and a payphone provider's inside wire. 30. In its reply, SWBT asserts that no preference will be given to orders from any particular providers and that it will process orders from its own payphone operation in the same manner as it processes orders from other PSPs. Similarly, SWBT represents that it will not notify its payphone operations when a new service order is placed for an independent PSP payphone, nor will its own payphone operations have any method of ascertaining this information. With respect to the location of the demarcation point, SWBT maintains that the demarcation point established for payphone services will be consistent with the minimum point-of-entry demarcation point standards applicable to all wireline services. Further, SWBT contends that it will comply fully with the Payphone Order which requires LECs to treat independent PSPs in a nondiscriminatory manner. 31. We find that SWBT has met the installation, maintenance, and repair requirement. We conclude that SWBT's CEI plan, together with the representations that SWBT has made in this proceeding, provides sufficient detail on the procedures it will employ to ensure that the installation, maintenance, and repair functions are performed on a nondiscriminatory basis. For example, SWBT maintains that the ordering mechanisms that SWBT will use to provide these functions will be the same for both unaffiliated and affiliated PSPs. Moreover, SWBT represents that the scheduling procedures and time periods for providing installation, maintenance and repair will be the same for all PSPs. We conclude, therefore, that the record evidence with respect to SWBT's installation, maintenance, and repair procedures for PSPs satisfies our CEI requirements. 32. We reject APCC's argument that SWBT must provide further explanation about personnel sharing in order to ensure that there will be no discrimination against unaffiliated PSPs. As stated above, SWBT represents that no preferences in ordering, installation, maintenance, and repair will be given to its own payphone operations. We find that SWBT's CEI plan sufficiently describes the procedures it has in place to address concerns about discrimination, including concerns raised by APCC with respect to shared personnel. Moreover, we note that the Commission's rules require BOCs to allocate properly their costs, including costs associated with the use of personnel, between regulated and nonregulated operations. We further conclude that SWBT's representation regarding the location of the demarcation point complies with the requirements established in the Payphone Order. Finally, we find that APCC's request that SWBT's service procedures address potential unfair marketing practices is beyond the scope of the installation, maintenance and repair requirement. To the extent that APCC's concern about unfair marketing practices raises issues about access to CPNI of unaffiliated PSPs, we conclude below that SWBT's plan complies with the applicable CPNI requirements. 6. End User Access 33. With regard to payphone services, this parameter requires the BOC to provide to all end users the same network capabilities to activate or obtain access to payphone services that utilize the BOC's facilities. This parameter also requires the BOC to provide all end users equal opportunities to obtain access to basic network facilities, whether they use the payphone services of the BOC's payphone operations or those of an independent PSP. 34. SWBT represents that end users will be able to obtain access to SWBT's basic payphone service via the same tariffed services that end users can use to obtain access to the services of other PSPs. SWBT maintains that no abbreviated dialing, signaling arrangements, or any special derived channel access arrangements are uniquely associated with SWBT's basic payphone service offering. We find that SWBT's CEI plan comports with the end user access requirement established by the Commission. 7. CEI Availability 35. This requirement obligates a BOC's CEI offering to be available and fully operational on the date that it offers its corresponding payphone service to the public. It also requires the BOC to provide a reasonable time prior to that date when prospective users of the CEI offering can use the CEI facilities and services for purposes of testing their payphone service offerings. 36. The payphone rulemaking proceeding established the following tariffing requirements for LECs. LECs must file tariffs in the states for basic payphone services that enable independent PSPs to offer payphone services using either smart or dumb payphones and for any unbundled features that the LECs provide to their payphone operations or to others. LECs are not required to file tariffs for the basic payphone line for smart and dumb payphones with the Commission. As stated in the Clarification Order, LECs are required to file federal tariffs for payphone-specific, network-based features and functions "only if the LEC provides them separately and on an unbundled basis from the basic payphone line, either to its payphone operations or to others. . . ." 37. SWBT asserts that all underlying basic services used by SWBT in the provision of basic payphone service are currently offered under tariff in all jurisdictions served by SWBT. Specifically, SWBT has filed state tariffs for payphone services used with "smart" and "dumb" payphones as well as state and federal tariffs for all of its unbundled features and functions. As discussed above, SWBT further represents that all underlying basic services available to SWBT's payphone service operations will be made available to other PSPs on the same terms and conditions. In jurisdictions where access arrangements are not currently available, SWBT maintains that it will make testing capability available to PSPs at the same time that such capability is made available to SWBT's own payphone operations. 38. APCC contends that the CEI plan must be rejected because SWBT did not file tariffs for its "coin line-specific" features. It contends that, pursuant to the Reconsideration Order, SWBT must file tariffs for unbundled features at both the state and federal levels, and that the only service for which a federal tariff is not required is for the "basic payphone line." Thus, APCC asserts that although SWBT has filed federal tariffs for some of the features provided with its COPT service, SWBT's plan cannot be approved until it files federal tariffs for the features and functionalities of its SmartCoin service. 39. In addition, APCC asserts that SWBT must be required to disclose the areas in which its SmartCoin service is not available and whether it has any payphones installed in these areas. Similarly, AT&T contends that SWBT should clarify that its SmartCoin service will be available on a nondiscriminatory basis to all PSPs at every central office where such service is provided to SWBT's payphone operation. 40. SWBT responds that a BOC is only obligated to file state tariffs for payphone services used with "smart" and "dumb" payphones and to file state and federal tariffs for "basic network services or unbundled features;" it is not required to file federal tariffs for coin line-specific features. SWBT reiterates that it has already filed state and federal tariffs for its unbundled features and that APCC has identified no specific unbundled features which SWBT has failed to include in its interstate tariff. Thus, SWBT contends that APCC is wrong in asserting that federal tariffs must be filed for coin line-specific features. 41. In response to APCC and AT&T's concern over the availability of its SmartCoin service, SWBT contends that because its "dumb" payphones require coin line functions, its payphone operations that use such payphones must be served by central offices that offer SmartCoin service. This availability, SWBT asserts, is expressly stated in its January 15, 1997, network disclosure which states that its SmartCoin service "will be available in any wire center where SWBT is the incumbent LEC." 42. We find that SWBT's plan complies with the CEI availability requirement. We reject APCC's argument that SWBT must file a federal tariff for all payphone service features and functions except for the basic access line for COPTS and SmartCoin service. As stated in the Clarification Order, BOCs need only submit federal tariffs for payphone- specific, network-based features and functions if the BOC provides them separately and on an unbundled basis from the basic payphone line, either to its own payphone operations or to others. We find that SWBT has filed both state and federal tariffs for the unbundled features that its payphone operations will use or offer in conjunction with its use of its COPTS line. Moreover, because SWBT will use, and offer, the features and functions of its SmartCoin service on a bundled basis, it need not either unbundle those features or file a separate federal tariff for them. 43. We also conclude that SWBT is not required to identify in its CEI plan specific geographic areas where its SmartCoin service is not available or to state whether SWBT has any payphones in such areas or what type of service, SmartCoin or COPT, is provided. SWBT's illustrative state tariff for SmartCoin service states that this service will be "offered, at the customer's option, where the necessary facilities are available." Further, SWBT represents that all underlying basic services available to SWBT's payphone service operations will be made available to other PSPs on the same terms and conditions. We find that the state tariff together with this representation provides adequate information concerning the availability of its SmartCoin service for the purposes of our CEI plan requirements. We also find nothing in our CEI rules or our payphone orders that would require SWBT to identify how many of its payphones are SmartCoin and how many are COPTS for the purpose of satisfying the CEI availability requirement. 44. Finally, on our own motion, we waive the 90-day notice requirement for SWBT's provision of SmartCoin service. Therefore, SWBT may continue to provide SmartCoin service through the use of the CEI offering described herein for such service without first providing ninety days for unaffiliated PSPs to test such service. This waiver is reasonable in this context because, unlike the provision of a new enhanced service, SWBT has been offering payphone service using SmartCoin service for many years. To bar SWBT from continuing to use SmartCoin service to provide payphone service for a period of 90 days could result in a suspension of service. SWBT is not, however, relieved of its obligation to permit unaffiliated PSPs upon request to conduct testing of the SmartCoin CEI offering. For purposes of approving this CEI plan, we simply waive the requirement that SWBT may not offer SmartCoin service before such testing is accomplished. If and when other basic payphone services are deployed, SWBT must make testing capability available to unaffiliated PSPs at the same time that such capability is available to SWBT's payphone operations. 8. Minimization of Transport Costs 45. This requirement obligates BOCs to provide competitors with interconnection facilities that minimize transport costs. 46. SWBT contends that interconnection to all facilities used to provide the underlying basic services supporting its basic payphone service will be offered under tariff, and will therefore be made available under the same rates, terms, and conditions to both affiliated and unaffiliated PSPs. As other configurations and serving arrangements are requested by end users and/or become technically feasible, SWBT asserts that it will work in good faith with customers to develop and implement new techniques that minimize transport costs. To the extent that it may plan to collocate its payphone equipment with its central office equipment, SWBT maintains that it will abide by the Commission's pricing parity rules and any applicable nondiscrimination requirements. We find that SWBT's CEI plan comports with the minimization of transport costs requirement established by the Commission. 9. Recipients of CEI 47. This requirement prohibits a BOC from restricting the availability of the CEI offering to any particular class of customer or unaffiliated PSP. 48. SWBT represents that the basic underlying services that comprise its basic payphone service offering will be available on a tariffed basis and will be accessible by all PSPs that are properly licensed/certified by the applicable state commission to provide payphone service. If any new arrangements are made available to SWBT's payphone service operations, such arrangements will be made available to other PSPs at the same time, in the same jurisdictions, and on the same terms and conditions, including prior notification to the Commission and the payphone industry. We find that SWBT has proposed to provide service to CEI recipients in compliance with the Commission's requirements. B. Other Nonstructural Safeguards 49. In addition to the CEI requirements established in Computer III, and applied to BOC provision of payphone services in the Payphone Order, a BOC that provides payphone services must comply with requirements regarding the use of CPNI, disclosure of network information, and nondiscrimination reporting. 1. Customer Proprietary Network Information 50. The Payphone Order requires SWBT to explain how it will comply with the Computer III CPNI safeguards, to the extent they are not inconsistent with section 222 of the Communications Act. Although the requirements of section 222 became effective immediately upon enactment, the Commission initiated a proceeding to consider regulations interpreting and specifying in more detail a telecommunications carrier's obligations under this provision. The Commission has concluded that its existing CPNI regulations remain in effect, pending completion of the CPNI rulemaking, to the extent they do not conflict with section 222. 51. In its CEI plan, SWBT represents that it will continue to comply with the Commission's existing rules and requirements regarding the use of CPNI to the extent that the requirements of section 222 are not inconsistent with them and pending the outcome of the Commission's CPNI rulemaking proceeding. SWBT also contends that CPNI related to the basic telecommunications services to which any PSP subscribes will be treated as restricted and will not be made available to, or accessible by, any other PSP, including its own payphone service operations, absent affirmative direction by the subscribing PSP. SWBT further maintains that aggregate CPNI will be made available, if at all, in accordance with the requirements of section 222(c)(3). 52. APCC contends that SWBT should explain how it will protect, under nondiscriminatory conditions, the CPNI of PSPs, as well as the CPNI of SWBT's existing customers, including current customers of semi-public payphone service. For example, according to APCC, SWBT does not indicate to what extent it has modified its security procedures to ensure that its payphone service personnel who may have direct access to SWBT's automated service order system will not also have access to CPNI of PSPs. Further, APCC argues that, because the existing tariffed semi-public service is being terminated pursuant to section 276, SWBT's payphone personnel have no more right to obtain access to and use the CPNI of semi-public service customers than any other PSP. Thus, APCC maintains that SWBT should be required to disclose how it will provide, in a neutral fashion, notice of the imminent changes to semi-public customers and how it will provide those customers an opportunity to authorize disclosure of CPNI on a nondiscriminatory basis to interested PSPs, without preference to SWBT's own payphone division. In reply, SWBT maintains that its payphone personnel will not have access to the CPNI of independent PSP payphone customers. 53. In providing payphone services, SWBT must comply with the Commission's pre-existing Computer III CPNI requirements, to the extent that they are consistent with section 222 of the Communications Act, and any regulations adopted by the Commission pursuant to section 222. In its CEI plan, SWBT represents that it will comply with section 222 and all CPNI requirements adopted in the Commission's CPNI rulemaking proceeding. Accordingly, we find that SWBT's plan comports with CPNI requirements. In reaching this conclusion, we do not address the various issues raised by APCC relating to the current customers of semi-public payphone service. Issues relating to the interpretation of section 222, and how it relates to the Computer III CPNI rules, are being addressed in the CPNI rulemaking, and therefore will not be considered here. We do, however, reject APCC's request that we require SWBT to inform site owners about competitive options for semi- public payphone service, because no such requirement was adopted in the Payphone Order or in the Reconsideration Order or is otherwise required by our CEI rules. 2. Network Information Disclosure 54. The Payphone Order requires SWBT to disclose to the payphone services industry information about network changes and new network services that affect the interconnection of payphone services with its network. SWBT must make that disclosure at the "make/buy" point, that is, when SWBT decides whether to make or to procure from an unaffiliated entity any product whose design affects or relies on the network interface through which a PSP interconnects with SWBT public switched network. SWBT must provide that information to members of the payphone services industry that sign a nondisclosure agreement, within 30 days after the execution of such nondisclosure agreement. SWBT also must publicly disclose technical information about a new or modified network service twelve months prior to the introduction of that service. 55. In the Payphone Order, the Commission waived the notice period for disclosure of network information relating to "basic network payphone services" in order to ensure that payphone services are provided on a timely basis consistent with the other deregulatory requirements of that order. Pursuant to this waiver, network information disclosure on the basic network payphone services must have been made by the BOCs no later than January 15, 1997. 56. SWBT maintains that the interconnection between PSPs and the underlying basic services supporting SWBT's basic payphone service offering will be achieved through an existing network interface (COPTS line) and a new network interface (SmartCoin line). As described above, consistent with the requirements of the Payphone Order, SWBT made the necessary network disclosure for its new network interface on January 15, 1997. We find therefore that SWBT's CEI plan comports with the Commission's network information disclosure requirements. 3. Nondiscrimination Reporting 57. The Payphone Order requires BOCs to comply with the Computer III and ONA requirements regarding nondiscrimination in the quality of service, installation, and maintenance. Specifically, BOCs are required to file the same quarterly nondiscrimination reports, and annual and semi-annual ONA reports, with respect to their basic payphone services that they file for other basic services to ensure that the BOCs fulfill the commitments made in their CEI plans with respect to the nondiscriminatory provision of covered service offerings, installation, and maintenance. 58. SWBT contends that its payphone service operations will not be given any preference or priority treatment nor will its payphone operations have access to systems supporting basic service order entry, installation, maintenance, or repair functions unless such access is also made available to other PSPs on nondiscriminatory terms and conditions. SWBT asserts that it will continue to abide by the Commission's existing nondiscrimination reporting rules which require BOCs to file quarterly installation and maintenance and nondiscrimination reports. Further, SWBT represents that it will incorporate into such reports data regarding SWBT's provision of basic payphone services. We find that SWBT's CEI plan comports with the Commission's nondiscrimination reporting requirements. C. Accounting Safeguards 59. In the Payphone Order and the Accounting Safeguards Order, the Commission concluded that it should apply accounting safeguards identical to those adopted in Computer III to BOCs providing payphone service on an integrated basis. Pursuant to Computer III, the BOCs must adhere to certain accounting procedures to protect ratepayers from bearing misallocated costs. These safeguards consist of five principal elements: 1) the establishment of effective accounting procedures, in accordance with the Commission's Part 32 Uniform System of Accounts requirements and affiliate transactions rules, as well as the Commission's Part 64 cost allocation standards; 2) the filing of CAMs reflecting the accounting rules and cost allocation standards adopted by the BOC; 3) mandatory audits of carrier cost allocations by independent auditors, who must state affirmatively whether the audited carriers' allocations comply with their cost allocation manuals; 4) the establishment of detailed reporting requirements and the development of an automated system to store and analyze the data; and 5) the performance of on-site audits by Commission staff. We note that the approval granted to SWBT in this Order is contingent upon the CAM amendments associated with SWBT's provision of payphone service going into effect. D. Other Issues 1. Sufficiency 60. APCC and Telco generally assert that SWBT's CEI plan insufficiently describes how SWBT intends to comply with the CEI requirements; therefore, these parties request that the Commission require SWBT either to amend or refile its plan. As discussed above, however, we find that SWBT adequately complies with each of the required parameters. 2. Tariffing Issues 61. APCC alleges that SWBT is not pricing its COPTS and SmartCoin features at cost-based rates as the Payphone Order requires and, therefore, that SWBT must be required to disclose the cost methodologies used to develop its COPTS and SmartCoin services. In reply, SWBT claims that complaints about its tariffed rates and costing methodologies are not relevant to a determination of whether SWBT's CEI plan should be approved. State rate and costing issues, SWBT maintains, will be decided before the various state commissions and federal tariff rates and costing methodologies will be decided by the Commission. 62. We agree with SWBT that the state and federal payphone tariff proceedings are the appropriate fora to address whether tariffed rates are cost-based and non- discriminatory. The Commission stated in the Reconsideration Order, that it would "rely on the states to ensure that the basic payphone line is tariffed by the LECs in accordance with the requirements of [s]ection 276." That order required that the tariffs for these LEC services must be: (1) cost based; (2) consistent with the requirements of section 276 with regard, for example, to the removal of subsidies from exchange and exchange access services; and (3) nondiscriminatory. In addition, the order established that "[s]tates must apply these requirements and the Computer III guidelines for tariffing such intrastate services." The order further stated that "[w]here LECs have already filed intrastate tariffs for these services, states may, after considering the requirements of this order, the Report and Order, and section 276 conclude: 1) that existing tariffs are consistent with the requirements of the Report and Order as revised herein; and 2) that in such case no further filings are required." Finally, the Commission noted that "[s]tates unable to review these tariffs may require the LECs operating in their state to file these tariffs with the Commission." Similarly, we find that the objections to the rates in SWBT's federal tariff appropriately are raised in this Commission's tariff proceeding where, in fact, APCC has filed a petition challenging SWBT's rates. 3. Screening Codes 63. APCC and MCI contend that SWBT is required, pursuant to the Reconsideration Order, to provide PSPs using COPTS lines with screening digits that uniquely identify their lines as payphone lines. APCC asserts that if SWBT transmits a unique screening code only on its SmartCoin lines, which is primarily used by SWBT's own payphone division, and not on its COPTS lines, which are primarily used by PSPs, SWBT is discriminating in favor its payphone division by providing it a great advantage in the collection of per-call compensation from IXCs. In addition, MCI maintains that SWBT's plan does not provide screening code digits that can be "transmitted by PSPs for all access methods and from all locations." 64. In reply, SWBT asserts that the transmission of screening code digits does not fall under any of the CEI plan requirements or other nonstructural requirements under Computer III. Nevertheless, SWBT recognizes that pursuant to the payphone rulemaking proceeding, it must transmit screening code digits to allow IXCs to track payphone calls for the purpose of paying compensation. SWBT contends that SmartCoin lines, including those used by SWBT, will transmit a "27" screening code indicating to IXCs that the originating line is a LEC payphone, and all COPTS lines, including those used by SWBT, will transmit an "07" screening code indicating to the IXC that the originating line requires special operator handling. SWBT explains that a screening code discretely identifying the COPTS line as a payphone line will be provided to IXCs through the use of SWBT's Line Information Data Base (LIDB). 65. We find that the issue of whether SWBT is providing screening information in compliance with the requirements established in the payphone rulemaking proceeding to be outside the scope of the CEI review process and is more appropriately raised in that proceeding or in other proceedings. 4. Numbering Assignments 66. According to APCC, the Payphone Order requires LECs to assign line numbers to payphones on a nondiscriminatory basis. It contends that SWBT's CEI plan is deficient in that it does not describe its number assignment policy or how that policy will be applied to SWBT's payphone operation and other PSPs. For example, APCC maintains that SWBT should be required to reallocate the numbers assigned to the existing base of payphones, without charge, so that an equal percentage of LEC payphones and PSPs are assigned 8000 and 9000 series numbers. In reply, SWBT asserts that it presently assigns new payphone numbers randomly to both its own payphone operations and to other PSPs and does not prefer or discriminate in making such assignments. 67. We agree with APCC that the Payphone Order requires LECs to provide numbering assignments on a nondiscriminatory basis; it did not, however, require LECs to reallocate existing number assignments. SWBT represents that it presently assigns payphone numbers on a nondiscriminatory basis. We conclude that no further showing is required by SWBT in the context of this CEI plan. 5. Dialing Parity 68. MCI also asserts that SWBT does not explain how it will comply with the dialing parity requirement in the Payphone Order, including access to operator services, directory assistance, and directory listings. 69. The Payphone Order concluded that the dialing parity requirements adopted pursuant to section 251(b)(3) of the Communications Act should extend to all payphone location providers. The Commission stated that such dialing parity for payphones should be implemented at the same time as dialing parity for other telephones. SWBT must, of course, comply with these requirements. We conclude, however, that SWBT is not required as part of the CEI process to demonstrate how it will comply with the dialing parity requirement. The Commission specified in the Payphone Order that the BOC's CEI plan describe how it will conform to the CEI requirements with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. We find MCI's request that SWBT detail how it intends to comply with the dialing parity requirement, therefore, to be beyond the scope of this CEI review proceeding. 6. Uncollectibles 70. AT&T asserts that SWBT must explain its treatment of uncollectibles due to fraud. AT&T contends that, to the extent SWBT establishes a policy of foregoing uncollectibles due to fraud for its payphone service affiliates, the same treatment must be accorded to non-affiliates. In reply, SWBT asserts that all "bad debt" will be recorded solely in SWBT's payphone operations accounts, which will be entirely responsible for the loss. According to SWBT, the only funding to SWBT's payphone operations will come from payphone revenue. We find that, while the Payphone Order generally requires that fraud protection must be available on a nondiscriminatory basis, it does not establish any specific requirements for uncollectibles. Because the issue of the treatment of uncollectibles appears to raise principally accounting matters, that issue will be addressed in the review of SWBT's CAM. 7. Operator Services 71. APCC contends that SWBT's CEI plan fails to address whether SWBT's operator services are part of its deregulated payphone services. If SWBT's operator services are regulated, APCC claims that SWBT must demonstrate that it is not subsidizing its payphone operations or discriminating between its payphone operations and other PSPs in the provision of these services. For example, if SWBT is offering a commission to its payphone operations for presubscribing its payphones to SWBT's operator services, then such commissions must also be available to independent PSPs on the same terms and conditions. SWBT responds that its operator services are regulated and will be offered to affiliated and nonaffiliated PSPs on a nondiscriminatory basis. Further, SWBT asserts that it presently offers a commission plan to independent PSPs for operator services and intends to make the same commission arrangement available to its own deregulated payphone operations. We note that, in the Reconsideration Order, the Commission declined to require LECs to make available, on a nondiscriminatory basis, any commission payments provided to their own payphone divisions in return for the presubscription of operator service traffic to the LEC, because the Commission concluded that the level of 0+ commissions paid pursuant to contract on operator service calls was beyond the scope of section 276 and the Payphone proceeding. We conclude therefore that SWBT has sufficiently addressed the concerns raised by APCC. 8. Inmate Calling Services Issues 72. The Inmate Calling Service Provider Coalition (ICSPC) and AT&T raise a number of issues related to the provision of inmate calling services (ICS). ICSPC and AT&T contend that SWBT should be required to identify the network support and tariffed services its regulated operations will provide to its ICS operations. ICSPC also argues that SWBT must disclose whether its regulated operations will provide its ICS operations with inmate call processing and call control functions, information for fraud protection, and the validation of called numbers. ICSPC contends that such services or information must be provided to other carriers on a nondiscriminatory basis. More specifically, to ensure that SWBT is not treating its affiliated inmate payphones differently than the inmate payphones of other PSPs, AT&T suggests that the Commission should require SWBT to set forth in its CEI plan and tariffs the network-based functionalities for inmate payphones that are currently available and make them available to all PSPs at the same rates, and under the same terms and conditions. According to ICSPC, SWBT's failure to describe its provision of ICS in detail prevents the Commission from determining whether SWBT has complied with the requirements of section 276. In addition, ICSPC asserts that SWBT should be required to disclose whether its payphone operations will be responsible for the cost of ICS calls for which SWBT payphone operations do not receive compensation. 73. ICSPC also asserts that SWBT must show that any call processing and call control system used for its ICS is being provided on a deregulated basis, regardless of whether that system is located at a central office or at a customer premises. According to ICSPC, to the extent SWBT's call processing and call control systems dedicated to ICS are located in SWBT's central offices, SWBT must provide physical or virtual collocation to other providers. ICSPC also contends that SWBT must disclose information on interfaces between SWBT's equipment dedicated to ICS and its regulated network support services, so that other providers can utilize the same interface if they wish. 74. In a subsequent ex parte filing, ICSPC argues that section 276 requires the BOCs to treat collect call processing for ICS as part of their nonregulated ICS operations because collect calling is fundamental to ICS. According to ICSPC, if a BOC's ICS operation "hands off" collect calls to its network-based operator services division for processing and that division assumes the responsibility and risk associated with billing and collecting for those calls, then the BOC is essentially providing ICS as a regulated service and is still subsidizing that service contrary to the prohibition in section 276. 75. In response to ICSPC's arguments, SWBT represents that, although it identified ICS as one of the payphone services that it offers, it did not separately discuss this service in detail because its treatment of ICS is consistent with its treatment of its other payphone services. SWBT further asserts that its payphone operations, in providing ICS, will purchase from SWBT the same tariffed services, at the same rates, as all other PSPs. In addition, it avers that its payphone operations do not use any network-based call control and call processing functions and therefore will not offer such services to other providers. Call control and call processing functions, SWBT explains, are provided by hardware and software owned and operated exclusively by SWBT's payphone operations. According to SWBT, this equipment is not housed in SWBT central offices but in space owned or leased solely by SWBT payphone operations. Thus, SWBT asserts, ICSPC's concern over potential collocation issues is unfounded. 76. Section 276 specifically defines payphone service to include the provision of inmate telephone service in correctional institutions. In the Reconsideration Order, we clarified that the requirements of the Payphone Order apply to inmate payphones that were deregulated in an earlier order. Thus, SWBT is required to reclassify as unregulated assets all of its payphone assets related to its provision of ICS, with the exception of the loops connecting the inmate telephones to the network, the central office "coin service" used to provide the ICS, and the operator service facilities used to support the ICS. In addition, SWBT is required to offer on a tariffed basis any basic payphone service or network feature used by its payphone operations to provide ICS. 77. We conclude that SWBT's CEI plan comports with our CEI requirements with respect to its provision of ICS. SWBT avers that its payphone operations, in providing ICS, will purchase from SWBT the same tariffed services, at the same rates, as all other ICS providers. Although we agree with ICSPC that any call processing and call control equipment related to SWBT's provision of ICS must be reclassified as nonregulated, regardless of whether that equipment is located at a customer premises or a SWBT central office, SWBT avers that it has done so. Significantly, SWBT represents that its payphone operations do not use any network-based call control and call processing functions. More specifically, SWBT asserts its ICS will make use of SWBT operator services, which will be purchased from SWBT's state tariffs in the same manner that any other ICS provider may purchase them. Likewise, any other SWBT service, such as fraud protection and LIDB validation information, employed by SWBT's ICS operations will be purchased and offered to all PSPs on a tariffed basis. We find no support in the Payphone Order or Reconsideration Order for ICSPC's contention that SWBT is required to provide collect calling as a nonregulated service when used with inmate payphones. 78. We conclude that the other issues raised by ICSPC related to the provision of ICS either have already been addressed in this Order or are beyond the scope of this proceeding. We find that there is no requirement in the Commission's rules, and the ICSPC has cited no authority, that obligates SWBT to allow the collocation of nonaffiliated providers' call processing and call control equipment in a central office. As previously noted, the issue of the treatment of uncollectibles will be addressed in the review of SWBT's CAM. Finally, with regard to the disclosure of interface information, we concluded above that SWBT's CEI plan comports with the Commission's network information disclosure requirements. 9. Primary Interexchange Carrier (PIC) Selection 79. AT&T and Oncor maintain that because SWBT will soon assume a dual role as both a provider of interexchange services and the administrator of the PIC selection process, SWBT's CEI plan must address SWBT's role in the PIC section process. Specifically, they contend that SWBT must describe how its PIC selection process for payphones will be performed in a nondiscriminatory manner. In its reply, SWBT contends that concerns regarding the PIC selection process are not relevant to the issue of SWBT's CEI compliance and should be handled in the enforcement process. SWBT asserts, nevertheless, that it will handle PIC verification and changes for SWBT payphones and independent PSPs' payphones in the same manner. Thus, no payphone provider will receive preferential treatment. 80. We conclude that SWBT is not required as part of the CEI process to demonstrate how it will administer the PIC selection process for payphones. The Commission specified in the Payphone Order that the BOC's CEI plan describe how it will conform to the CEI requirements with respect to the specific payphone services it intends to offer and how it will unbundle those basic payphone services. The payphone rulemaking proceeding did not require the BOCs to describe how they will administer the PIC selection process in their CEI plans, as requested by AT&T and Oncor. We find therefore that the arguments raised by parties regarding SWBT's role as PIC administrator are beyond the scope of this proceeding. 10. Subscriber-Selected Call-Rating 81. APCC contends that, in order to meet the Commission's CEI requirements, SWBT must provide a coin line service that allows independent PSPs to set the initial time period, the overtime periods, and all rates corresponding to these periods for local calls. An example of an initial rate is $0.25 for the first five minutes. An example of an overtime rate is $0.05 for each additional three minute period after the first five minutes. APCC therefore requests the Commission to require SWBT to develop a more flexible rating feature such that independent PSPs will not have to use SWBT payphone operation's preferred rates and time periods for local calls. Likewise, APCC continues, SWBT should specify how directory assistance (DA) rates and rates for DA call completion are set. In reply, SWBT maintains that local rates are a state matter and no state in the SWBT's region has either permitted or required local measured coin service. Further, SWBT asserts that it will allow PSPs to set their own rates for sent-paid DA in compliance with the Commission's requirement that states must allow PSPs to change end-users a market-based rate for DA calls. 82. We find that the Payphone Order did not require the BOCs to provide to independent PSPs an unbundled call rating feature for coin line services. In addition, on reconsideration of the Payphone Order, in response to a request that it require access to, inter alia, call rating capabilities, the Commission specifically declined to require further unbundling of payphone services beyond those established in the Payphone Order. As previously noted, independent PSPs may seek additional unbundling through the 120-day ONA process. The appropriate state regulatory authorities may also impose further unbundling requirements. 11. Operator Service Provider (OSP) Selection 83. APCC requests that the Commission require SWBT to unbundle operator services from its SmartCoin service so that PSPs may select their own operator service provider for intraLATA calls. APCC asserts that, under section 276, PSPs are entitled to select their OSP of choice for intraLATA calls, including local, operator-assisted calls, and therefore that, to the extent SWBT does not permit OSP selection for its SmartCoin service, its CEI plan is inconsistent with section 276. In reply, SWBT maintains that before subscribers to its SmartCoin service can select the OSP for intraLATA traffic, intraLATA dialing parity must be implemented. We find that APCC's request is beyond the scope of this proceeding, which is limited to determining whether SWBT's CEI plan complies with the Commission's Computer III CEI requirements. 12. Interim Compensation Scheme 84. Telco argues that apart from the numerous deficiencies in SWBT's CEI plan, the Commission should refrain from allowing SWBT or any BOC to participate in the interim compensation scheme outlined in the Payphone Order. We find that this argument is beyond the scope of the CEI review proceeding. Moreover, the interim compensation rules issue were addressed at length in the payphone rulemaking proceeding. 13. Timing 85. APCC asserts that SWBT fails to provide any information on whether there are differences in the timing of call set-up between SWBT's COPTS lines and SmartCoin lines. To the extent differences exist, APCC contends that SWBT must describe these differences in detail and explain what steps it will take to equalize timing "in accordance with the Commission's CEI requirement." SWBT maintains that there will be no difference in the call set-up delay between an unaffiliated PSP and SWBT's own payphone service operations, regardless of the type of basic payphone service used by the PSP. We conclude that SWBT has adequately addressed APCC's concern. 14. Semi-Public Service Issues 86. APCC maintains that to the extent that SWBT's payphone operation continues to offer a "semi-public-like" payphone service that involves charging location providers for lines and usage on their payphones, SWBT must disclose how such a service will be supported by its network operations and how charges for the service will be treated on the subscriber's bill. We find these semi-public service issues to be beyond the scope of the CEI review process. 15. Taxes 87. APCC contends that SWBT does not describe it procedures for ensuring that independent PSPs and SWBT's payphone operations are taxed in the same fashion. We find that this concern is not within the scope of this CEI proceeding. V. CONCLUSION 88. We conclude that SWBT's CEI plan complies with the Computer III requirements. Accordingly, in this Order, we approve SWBT's CEI plans to offer basic payphone service, as described herein. We also grant SWBT a waiver of the testing requirement for the provision of its SmartCoin service as described above. VI. ORDERING CLAUSE 89. IT IS HEREBY ORDERED that, pursuant to Sections 1, 4(i) and (j), 201, 202, 203, 205, 218, 222, 276 of the Communications Act of 1934, as amended, 47 U.S.C.  151, 154(i) and (j), 201, 202, 203, 205, 218, 222, and 276 and authority delegated thereunder pursuant to Sections 0.91, 0.291, and 1.3 of the Commission's rules, 47 C.F.R.  0.91, 0.291, 1.3, SWBT's Comparably Efficient Interconnection Plan for the Provision of Basic Payphone Services IS APPROVED, subject to the requirements and conditions discussed herein. Federal Communications Commission A. Richard Metzger, Jr. Deputy Chief, Common Carrier Bureau