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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 Matters of ) ) Bell Operating Companies ) ) Petitions for Forbearance from the ) CC Docket No. 96-149 Application of Section 272 of the ) Communications Act of 1934, As ) Amended, to Certain Activities ) MEMORANDUM OPINION AND ORDER Adopted: February 6, 1998 Released: February 6, 1998 By the Chief, Common Carrier Bureau: TABLE OF CONTENTS para. I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. TELECOMMUNICATIONS ACT OF 1996. . . . . . . . . . . . . . . . . . . 3 A. Section 10 . . . . . . . . . . . . . . . . . . . . . . . . . 3 B. Sections 271 and 272 . . . . . . . . . . . . . . . . . . . . 4 III. BOC E911 SERVICES. . . . . . . . . . . . . . . . . . . . . . . . . .7 A. Description of Services. . . . . . . . . . . . . . . . . . . 7 B. Need for Forbearance to Operate on an Integrated Basis . . . 11 1. Overview . . . . . . . . . . . . . . . . . . . . . . 11 2. Discussion . . . . . . . . . . . . . . . . . . . . . 15 C. Authority to Forbear . . . . . . . . . . . . . . . . . . . . 15 1. Overview . . . . . . . . . . . . . . . . . . . . . . 21 2. Discussion . . . . . . . . . . . . . . . . . . . . . 22 D. Application of Forbearance Criteria. . . . . . . . . . . . . 27 1. Section 10(a)(1) . . . . . . . . . . . . . . . . . . 27 a. Just, Reasonable, and Non-discriminatory Charges 29 b. Just, Reasonable, and Non-discriminatory Practices, Classifications, and Regulations. . . . . . . 30 c. Other Conditions. . . . . . . . . . . . . . . 41 2. Section 10(a)(2) . . . . . . . . . . . . . . . . . . 43 3. Sections 10(a)(3) and 10(b). . . . . . . . . . . . . 45 IV. BELLSOUTH'S REVERSE DIRECTORY SERVICES. . . . . . . . . . . . . . . 52 A. Description of Services. . . . . . . . . . . . . . . . . . . 52 1. Operator-Assisted Reverse Directory Services . . . . 52 2. Electronic Reverse Directory Services. . . . . . . . 55 B. Need for Forbearance to Operate on an Integrated Basis . . . 59 C. Authority to Forbear . . . . . . . . . . . . . . . . . . . . 65 D. Application of Forbearance Criteria. . . . . . . . . . . . . 69 1. Section 10(a)(1) . . . . . . . . . . . . . . . . . . 70 a. Just, Reasonable, and Non-discriminatory Charges 71 b. Just, Reasonable, and Non-discriminatory Practices, Classifications, and Regulations. . . . . . . 78 c. Other Conditions. . . . . . . . . . . . . . . 85 2. Section 10(a)(2) . . . . . . . . . . . . . . . . . . 87 3. Sections 10(a)(3) and 10(b). . . . . . . . . . . . . 94 V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 VI. ORDERING CLAUSES. . . . . . . . . . . . . . . . . . . . . . . . . . 99 I. INTRODUCTION 1. On February 8, 1996, the Telecommunications Act of 1996 (1996 Act) was enacted. The goal of the 1996 Act is to establish "a pro-competitive, de-regulatory national policy framework" in order to make available to all Americans advanced telecommunications and information technologies and services "by opening all telecommunications markets to competition." An integral part of this framework is the requirement in section 10 of the Communications Act of 1934, as amended (Communications Act or Act), that the Commission forbear from applying any provision of the Communications Act, or any of the Commission's regulations, to a telecommunications carrier or telecommunications service, or class thereof, if the Commission makes certain specified findings with respect to such provisions or regulations. 2. The 1996 Act also establishes, in section 272, structural, transactional, and other requirements applicable to Bell Operating Company (BOC) provision of certain services. In this Order, we address petitions for forbearance from the application of those requirements to the BOCs' enhanced 911 (E911) services and BellSouth's reverse directory services. The petitioners historically have provided these services on an integrated basis, rather than through separate affiliates that meet the section 272 requirements. We determine that to the extent that these services constitute interLATA information services, the petitioners may continue to provide them on an integrated basis only if we forbear from the application of section 272. We also determine that our authority to forbear from such application is not affected by the limitation in section 10(d) of the Act on the Commission's authority to forbear from applying the requirements of section 271 prior to their full implementation. Although section 271(d)(3) requires the Commission's prior approval of a BOC's application to provide in-region, interLATA service and the criteria for approval include compliance with section 272, prior Commission approval pursuant to section 271(d)(3) is not required where, as here, the BOCs provide services that are either previously authorized within the meaning of section 271(f) of the Communications Act or incidental interLATA services as defined by section 271(g) of that Act. We conclude, subject to certain conditions set forth in sections III.D.1. and IV.D.1., below, that the forbearance criteria in section 10 are met for the Commission to forbear from applying section 272 to the BOCs' E911 services and BellSouth's reverse directory services, and we permit petitioners to continue to provide those services on an integrated basis. We, therefore, grant the BOCs' petitions, subject to those conditions. II. TELECOMMUNICATIONS ACT OF 1996 A. Section 10 3. The 1996 Act provides for regulatory flexibility by requiring the Commission to forbear from applying any regulation or any provision of the Communications Act to telecommunications carriers or telecommunications services, or classes thereof, if the Commission determines that certain conditions are satisfied. Specifically, the 1996 Act amends the Communications Act to provide that: [T]he Commission shall forbear from applying any regulation or any provision of this Act to a telecommunications carrier or telecommunications service, or class of telecommunications carriers or telecommunications services, in any or some of its or their geographic markets, if the Commission determines that -- (1) enforcement of such regulation or provision is not necessary to ensure that the charges, practices, classifications or regulations by, for, or in connection with that telecommunications carrier or telecommunications service are just and reasonable, and are not unjustly or unreasonably discriminatory; (2) enforcement of such regulation or provision is not necessary for the protection of consumers; and (3) forbearance from applying such provision or regulation is consistent with the public interest. In making the public interest determination, the 1996 Act requires the Commission to consider whether forbearance will promote competitive market conditions, including the extent to which forbearance will enhance competition among providers of telecommunications services. Section 10(b) also provides that, "[i]f the Commission determines that such forbearance will promote competition among providers of telecommunications services, that determination may be the basis for a Commission finding that forbearance is in the public interest." Section 10(d) specifies, however, that "[e]xcept as provided in section 251(f), the Commission may not forbear from applying the requirements of section 251(c) or 271 under [section 10(a)] until it determines that those requirements have been fully implemented." B. Sections 271 and 272 4. Sections 271 and 272 of the 1996 Act establish a comprehensive framework governing BOC provision of "interLATA services." Section 271(a) states that neither a BOC nor a BOC affiliate "may provide interLATA services except as provided in [section 271]." Generally, under section 271(b)(1), a BOC or BOC affiliate "may provide interLATA services originating in any of its in-region States" only "if the Commission approves the application of such company for such state under [section 271(d)(3)]." Section 271(f), however, provides that section 271(a) shall not: [P]rohibit a Bell operating company or affiliate from engaging, at any time after the date of enactment of the Telecommunications Act of 1996, in any activity to the extent authorized by, and subject to the terms and conditions contained in, an order entered by the United States District Court for the District of Columbia pursuant to section VII or VIII(C) of the AT&T Consent Decree if such order was entered on or before such date of enactment, to the extent such order is not reversed or vacated on appeal. In addition, section 271(b)(3) authorizes the BOCs or their affiliates to engage in "incidental interLATA services," as defined in section 271(g). These include services that permit customers "located in one LATA to retrieve information from, or file information for storage in, information storage facilities of [a BOC or its affiliate] that are located in another LATA." Sections 272(a)(2)(B)(i) and (a)(2)(C) direct that a BOC provide such information retrieval and storage only through a separate affiliate. 5. Under section 271(d)(3)(B), a BOC may obtain authorization pursuant to section 271(d)(3) to originate in-region, interLATA services only if the Commission finds, among other things, that "the requested authorization will be carried out in accordance with the requirements of section 272." Sections 272(a)(1) and (a)(2)(C), in turn, require each BOC to provide interLATA information services, other than electronic publishing and alarm monitoring, only through a separate affiliate. This affiliate must meet particular structural, transactional, and auditing requirements, as specified in sections 272(b) and (d). The BOC must comply with certain non-discrimination safeguards and other requirements, as specified in sections 272(c) and (e). In the Non-Accounting Safeguards Order, the Commission determined that interLATA information services described in section 271(f) are subject to these requirements. The Commission observed, however, that it must forbear from application of those requirements to previously authorized interLATA information services to the extent the BOCs demonstrate that particular services meet the criteria for forbearance. 6. Under section 271(d)(3)(A), the Commission may grant a BOC authorization pursuant to section 271(d)(3) to originate in-region, interLATA services only if it finds that the BOC has met the competitive checklist set forth in section 271(c)(2)(B) and other statutory requirements. The checklist includes the provision of "[n]ondiscriminatory access . . . to 911 and E911 services" as a precondition to obtaining section 271(d)(3) authorization. III. BOC E911 SERVICES A. Description of Services 7. In both basic 911 and E911 services, carriers transmit 911 calls to public service answering points (PSAPs) for forwarding to police, fire, and other emergency service providers. In basic 911 service, the calling party must inform emergency service personnel of his or her location. This takes time, is subject to human error, and may not be completed if the caller is incapacitated or the call is interrupted. E911 services attempt to overcome these limitations by automatically providing emergency service personnel with additional information. At a minimum, E911 services forward the calling party's number to the PSAP, thus permitting the PSAP attendant to call back if the call is disconnected. E911 services also may permit the PSAP attendant to identify the calling party's location through the use of one or more external automatic location identification databases. These databases contain telecommunications service provider records that identify calling station locations and may include other information, such as the name, address, and telephone number of individual telecommunications subscribers. Automatic location identification databases may also contain notes providing information, such as the medical history of individuals residing at particular addresses, that may help emergency services personnel respond to specific emergencies. 8. Neither the Commission nor the states have prescribed a particular technical configuration for telephone companies' E911 services. The BOCs indicate that they use centralized and integrated system architectures that are designed to provide E911 services quickly, accurately, reliably, and economically. These systems include automatic location identification databases that serve broad geographic areas. These databases contain information on all BOC telephone subscribers, including those with unpublished or unlisted numbers. Some BOCs state that their databases include information on customers of other incumbent local exchange carriers (LECs) and competitive LECs serving the particular BOC's region. 9. The BOCs' automatic location identification databases typically list the public safety agencies responsible for each telephone subscriber location and include routing information identifying the appropriate PSAP for each calling station. The BOCs update this information on an on-going basis to reflect new PSAP assignments as well as changes in subscriber listings. The BOCs state that they route E911 calls to PSAPs through switches that contain this routing information or that are programmed to obtain that information from the centralized databases. These switches are typically tandem switches that route calls for a number of wire centers, although in some instances switches in individual wire centers route 911 calls to PSAPs. These switches sometimes serve E911 callers and PSAPs in more than one LATA. 10. The BOCs also indicate that, as the PSAP attendant answers E911 calls, including calls from competitive LECs, equipment located on the PSAP premises automatically sends a query to the automatic location identification database serving the PSAP. The database, in turn, sends the appropriate location and other information to the PSAP for display on the attendant's computer screen. Communications between PSAPs and automatic location identification databases typically involve interLATA transmissions. B. Need for Forbearance to Operate on an Integrated Basis 1. Overview 11. Section 272(a)(2)(B)(iii) specifies that a BOC need not use a separate affiliate to originate interLATA telecommunications services that are "previously authorized activities described in section 271(f)." In the Non-Accounting Safeguards Order, the Commission determined that interLATA information services described in section 271(f) fall outside section 272(a)(2)(B)(iii) and are, instead, governed by section 272(a)(2)(C), which requires the BOCs to provide interLATA information services other than electronic publishing and alarm monitoring only through separate affiliates. Therefore, if the BOCs' E911 services are "previously authorized" activities described in section 271(f), the BOCs are precluded from providing those services on an integrated basis only to the extent they include interLATA information services. 12. In the Non-Accounting Safeguards Order, the Commission concluded that, as used in section 272, "'interLATA information service' refers to an information service that incorporates as a necessary, bundled element an interLATA telecommunications transmission component, provided to the customer for a single charge." 13. Prior to the 1996 Act, the Commission established, in the Computer II and Computer III proceedings, a regulatory regime that distinguishes between basic and enhanced services. In 1982, shortly before the Computer II rules first took effect, the Common Carrier Bureau (Bureau) waived those rules to permit AT&T and its then-affiliated BOCs to continue to offer E911 services and associated customer premises equipment on an integrated basis. In waiving those rules, the Bureau declined to rule on whether E911 services are enhanced under the Computer II rules; instead, the Bureau determined that the public interest required that the BOCs offer E911 services on an integrated basis irrespective of whether those services were enhanced under the Computer II rules. In 1984, the United States District Court for the District of Columbia determined that "the information storage and retrieval functions of E911 services are an 'information service' within the meaning" of the Modification of Final Judgment (MFJ) under which the BOCs were divested from AT&T. The District Court, however, waived that decree so that the BOCs could continue to provide E911 services on an integrated basis. 14. The BOCs seek forbearance from the application of section 272 to their E911 services to the extent those services are interLATA information services. We now turn to the questions whether the BOCs' E911 services constitute information services and, if so, whether those services are interLATA information services. 2. Discussion 15. As the Commission indicated in the Non-Accounting Safeguards Order, sections 272(a)(2)(B)(iii) and (C) permit the BOCs to offer interLATA telecommunications services described in section 271(f) on an integrated basis, while requiring, in the absence of forbearance, the BOCs to offer interLATA information services described in that provision only through separate affiliates. AT&T suggests that we refrain from determining whether the BOCs' E911 services are interLATA information services and, instead, address the merits of the forbearance petitions without resolving that threshold issue. AT&T states that upon a proper showing under section 10, the Commission could simply rule that it will forbear from applying section 272 to E911 services, and could reserve judgment as to the status of E911 until such time as that question may be directly presented. 16. We reject AT&T's suggestions. To forbear, we must determine that each of the three forbearance criteria set forth in section 10 are met. Application of those criteria is not a simple task, and a decision to forbear must be based upon a record that contains more than broad, unsupported allegations of why those criteria are met. In these circumstances, the better use of our resources is to consider the merits of a request for forbearance only when it is clear that the telecommunications carrier or service is subject to the statutory provision or regulation from which forbearance is sought. Therefore, we first address whether the BOCs' E911 services are interLATA information services. 17. The Communications Act defines "information service" as "the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications, and includes electronic publishing, but does not include any use of any such capability for the management, control, or operation of a telecommunications system or the management of a telecommunications service." Although SWBT contends that there is some doubt that E911 services are information services, the record in this proceeding shows that the BOCs' E911 services enable PSAPs and emergency service providers to retrieve information from the BOCs' automatic location identification databases. The BOCs may also permit PSAPs or other emergency agencies to store information regarding PSAP assignments and, in some instances, individual telephone subscribers in these databases. Because the BOCs' E911 services offer the capability for storing and retrieving information, they are information services, except to the extent they are used for the management, control, or operation of telecommunications systems or the management of telecommunications services. This conclusion comports with the MFJ Court's determination that "the information storage and retrieval functions of E911 services are an 'information service' within the meaning of the [AT&T Consent Decree]." While the BOCs use their automatic location identification databases to ensure the proper routing of E911 calls, those databases also store information, including the name, address, and telephone number of individual telecommunications subscribers, which helps emergency service personnel respond to E911 calls. This information goes far beyond what the BOCs need to ensure the proper transmission of 911 calls to PSAPs and thus falls outside the "telecommunications management exception" to the information services definition. 18. U S West argues that the BOCs' storage and retrieval of the information that emergency service personnel use to respond to E911 calls fall within the "telecommunications management exception" because those functions are adjunct services, as defined in the NATA Centrex proceeding. U S West asserts that the Commission has the discretion to determine that the database functions of E911 services are adjunct services that fall outside the statutory definition of information services. U S West indicates that inclusion of a requirement to provide "[n]ondiscriminatory access to . . . E911 services" in the competitive checklist that BOCs must meet in order to obtain authorization to provide in-region, interLATA service indicates that E911 services should be treated as adjunct services. We reject these arguments. In the NATA Centrex proceeding, the Commission defined adjunct services as services that "facilitate the provision of basic services without altering their fundamental character," and determined that such services should be treated as basic services for purposes of the Computer II rules, even though they might fall within possible literal readings of the definition of enhanced services. In the Non-Accounting Safeguards Order, the Commission determined that adjunct services should be classified as telecommunications services, rather than information services, because they are used for the management, control, or operation of telecommunications systems or the management of telecommunications services. Although the "telecommunications management exception" encompasses adjunct services, the storage and retrieval functions associated with the BOCs' automatic location identification databases provide information that is useful to end users, rather than carriers. As a consequence, those functions are not adjunct services and cannot be classified as telecommunications services on that basis. 19. Our determination that E911 services are information services is not inconsistent with the inclusion of "[n]ondiscriminatory access to . . . E911 services" in the competitive checklist. In arguing to the contrary, U S West implicitly assumes that Congress intended to limit that checklist item to telecommunications services. U S West, however, fails to identify any statutory language or legislative history that might support such an assumption, and we find no such support. In these circumstances, we conclude that the inclusion of "E911 services" in the competitive checklist has no bearing on the question whether those services are information services. 20. The record also makes clear that the E911 services described above are, in many instances, interLATA information services. For example, when a PSAP receives an E911 call, equipment located on the PSAP premises automatically requests that the BOC's automatic location identification database provide information regarding the calling station. Both this request for information and any resulting response are transmitted over BOC facilities. Since many, if not all, of the BOCs' automatic location identification databases serve multiple LATAs, many of these transmissions cross LATA boundaries. In addition, it appears from the record before us that this interLATA transmission component is a necessary bundled element of the BOCs' E911 services. The bundled services are, therefore, interLATA information services. Sections 272(a)(1) and (a)(2)(C) direct that these services be provided through a separate subsidiary. The BOCs therefore may continue to provide them on an integrated basis only if we have the authority to forbear from application of those sections to the BOCs' E911 services and only if we conclude, in the exercise of such forbearance authority, that the forbearance criteria set forth in section 10 of the Act are met. We now turn to the question whether we have such authority. C. Authority to Forbear 1. Overview 21. Section 10(a) of the Communications Act specifies that we "shall forbear from applying . . . any provision of this Act to a telecommunications carrier" if we determine that the specified forbearance criteria are met. Section 10(d) states, however, that we "may not forbear from applying the requirements of section 251 or 271 until [we] determine[] that those requirements have been fully implemented." In this section, we address whether section 10(d) precludes our forbearing from the application of section 272 to the BOCs' E911 services. 2. Discussion 22. Whether section 10(d) precludes us from forbearing from the application of section 272 to the BOCs' E911 services depends on the meaning of several Communications Act provisions and judicial actions in connection with the MFJ. Based on our interpretation of the Communications Act provisions, we conclude, as AT&T and MCI argue, that prior to their full implementation we lack authority to forbear from application of the requirements of section 272 to any service for which the BOC must obtain prior authorization under section 271(d)(3). For the reasons discussed below, we determine, however, that the MFJ Court had authorized the BOCs to provide E911 services prior to enactment of the 1996 Act and that we, therefore, have authority to forbear from the application of the requirements of section 272 to those services. 23. Section 271 provides three ways in which a BOC or BOC affiliate may have the authority to provide in-region, interLATA service: the Commission may authorize the service pursuant to section 271(d)(3); the service may have been previously authorized within the meaning of section 271(f); or the service may be an incidental interLATA service as defined in section 271(g). We recognize that under section 271(d)(3)(B), we may not grant a section 271(d)(3) authorization unless we find that "the requested authorization will be carried out in accordance with the requirements of section 272." We believe that section 10(d), read in conjunction with section 271(d)(3)(B), precludes our forbearance for a designated period from section 272 requirements with regard to any service for which a BOC must obtain prior authorization pursuant to section 271(d)(3). We further conclude that our authority to forbear from application of section 272 to the BOCs' E911 services is dependent on whether the BOCs may provide such services in the absence of section 271(d)(3) authorization. 24. As noted above, one category of such services that may include interLATA information services is the group of services previously authorized within the meaning of section 271(f). A service falls within that group only if the MFJ Court had authorized its provision, pursuant to section VII or VIII(C) of the MFJ, prior to enactment of the 1996 Act. Section VII of that decree provided that the MFJ Court retained jurisdiction over the decree after its entry to, among other purposes, modify the restrictions on BOC businesses. Section VIII(C), in turn, provided that the restrictions would be removed upon a BOC's showing that "there is no substantial possibility that it could use its monopoly power to impede competition in the market it seeks to enter." 25. The BOCs argue that their E911 services are authorized within the meaning of section 271(f). This argument is based on two Court decisions subsequent to the MFJ, and on a DOJ letter interpreting those decisions. In the first decision, issued February 6, 1984, the Court recognized that "the information storage and retrieval functions of E911 services are an 'information service' within the meaning of the decree, and that such functions may not be performed without a waiver." The Court, however, granted the BOCs waivers, pursuant to section VIII(C) of the decree, so that they could provide E911 services. In the second decision, issued February 2, 1989, the Court waived the decree so the BOCs could "provide, using their own facilities, 911 emergency service across LATA boundaries to any 911 customer whose jurisdiction crosses a LATA boundary." In 1991, the DOJ interpreted these judicial decisions as enabling "the BOCs to provide multiLATA 911 services, including E911 services." DOJ stated that the transmission of "data interLATA between an E911 data base and E911 nodes, that may be in a different LATA, to public or private agency customers" is within the scope of those waivers. Based on the foregoing, we conclude that E911 services are "previously authorized" within the meaning of section 271(f). 26. MCI questions whether we can legally forbear from the application of any non- discrimination requirements, including those in sections 272(c)(1) and (e), to dominant carriers such as the BOCs. MCI maintains that the marketplace cannot be relied upon to prevent a dominant carrier from unjustly or unreasonably discriminating and that our forbearance authority is limited to circumstances that will not result in such discrimination. We agree with the BOCs that section 10 does not automatically foreclose forbearance from the application of sections 272(c)(1) and (e) to dominant carriers. Rather, section 10 mandates forbearance if the statutory criteria are met. A concern about dominant carriers is, therefore, relevant only to the extent it relates to one or more of the statutory criteria. Accordingly, we reject MCI's sweeping suggestion that forbearance from provisions governing dominant carriers is not possible under any circumstance. D. Application of Forbearance Criteria 1. Section 10(a)(1) 27. Section 10(a) requires us to forbear from application of section 272 to the BOCs' E911 services if we determine that each of three statutory forbearance criteria is satisfied. The first criterion requires that we analyze whether application of section 272 to the BOCs' E911 services is necessary to ensure that the BOCs' "charges, practices, classifications or regulations . . . are just and reasonable, and are not unjustly or unreasonably discriminatory." The BOCs argue that they meet this forbearance criterion. AT&T and MCI disagree, claiming that sections 272(c)(1) and (e) require that the BOCs make available to unaffiliated entities certain information that the BOCs provide to their own E911 services operations. AT&T and MCI contend that unaffiliated entities must have access to that information before the Commission may determine that the BOCs' practices with regard to their E911 services operations are just, reasonable, and not unjustly or unreasonably discriminatory. 28. We conclude that this statutory forbearance criterion is satisfied with respect to the BOCs' E911 services, provided that the BOCs make available to unaffiliated entities that wish to provide E911 services all subscriber listing information, including unlisted numbers, unpublished numbers, and the numbers of other LECs' customers, that the BOCs use to provide their E911 services. In accordance with the Non-Accounting Safeguards Order, the BOCs shall make this information available at the same rates, terms, and conditions, if any, that they charge or impose on their own E911 services operations. a. Just, Reasonable, and Non-discriminatory Charges 29. We consider first the effect, if any, that application of section 272 to the BOCs' E911 services would have on BOC charges. As BellSouth points out, the BOCs charge for E911 services by imposing a surcharge on end-user bills, the amount of which is regulated by the states. While that fact in and of itself is not dispositive of whether the first forbearance criterion is met, no commenter has alleged that application of any section 272 requirement to the BOCs' E911 services is necessary to ensure that any of the BOCs' charges, including those for E911 services, are just and reasonable. Indeed, the record shows that, as a result of the Common Carrier Bureau and MFJ Court waivers, the BOCs realize substantial economies in providing E911 services on an integrated basis. Providing E911 services through separate affiliates or on an intraLATA basis would make the services more costly, which presumably would only increase the amounts the BOCs or their affiliates would be entitled to recover for those services. In these circumstances, we find that application of the section 272 requirements is not necessary to ensure that the BOCs' charges are just, reasonable, and not unjustly or unreasonably discriminatory within the meaning of section 10(a). b. Just, Reasonable, and Non-discriminatory Practices, Classifications, and Regulations 30. Listing Information. The BOCs' automatic location identification databases include unlisted and unpublished numbers as well as the numbers of other LECs' customers. AT&T claims that the BOCs' exclusive access to this information discriminates against competitors and precludes them from offering their own E911 services. We agree. If the BOCs were providing E911 services through separate affiliates, their practice of not providing unaffiliated entities with access to all the telephone numbers they use to provide those services would be inconsistent with section 272(c)(1) of the Communications Act. That section specifies that a BOC "may not discriminate between its [section 272] affiliate and any other entity in the provision of . . . information." This provision makes clear that the BOCs could not provide their section 272 affiliates with listing information, including listing information obtained from other LECs, without also making that information available to third parties. As the Commission stated in the Non-Accounting Safeguards Order, section 272(c)(1) "establishes an unqualified prohibition against discrimination by a BOC in its dealings with its section 272 affiliate and other entities." This prohibition extends to listing information that a BOC provides to its section 272 affiliate. 31. Under section 272(c)(1), a BOC's practice of not providing unaffiliated entities with all of the subscriber listings that an affiliate of the BOC uses to provide E911 services would be deemed discriminatory, if the BOC provided the affiliate with those listings. We must consider, however, whether this practice would be unjustly or unreasonably discriminatory within the meaning of section 10(a)(1). We conclude that it would be. Absent access to the subscriber listing information, including unlisted and unpublished numbers as well as the numbers of other LECs' customers, in the BOCs' automatic location information databases, unaffiliated entities would be at a disadvantage in competing with the BOCs to provide E911 services. This disadvantage stems from the BOCs' position as the dominant providers of 911 and E911 services within their regions. Ever since AT&T and its then-affiliated BOCs designated 911 for access to emergency services approximately thirty years ago, state and local governmental bodies have relied on the BOCs to provide emergency services. By 1982, this reliance had led to a situation in which it was "not clear that any other service provider would, or could, fill the void" if the BOCs were to cease providing E911 services. Indeed, the inclusion of "[n]ondiscriminatory access . . . to 911 and E911 services" in the competitive checklist that a BOC must satisfy to obtain authorization to provide in-region interLATA services implicitly recognizes the BOCs' unique position in the provision of those services. As the Commission recently determined in the Ameritech Michigan Order, a BOC's failure to include competitive LECs' customers in its automatic location identification database "pose[s] very serious . . . competitive concerns." 32. Based on this prior history and the record before us, we conclude that the BOCs have competitive advantages in the provision of E911 services stemming from the BOCs' dominant positions in the provision of local exchange services in their respective regions. These advantages will persist if the BOCs continue to deny unaffiliated entities access to listing information that the BOCs use to provide their E911 services or if the BOCs fail to provide such access at the rates, terms, and conditions, if any, that they charge or impose on themselves. We therefore also conclude that, until they provide such access at those rates, terms, and conditions, the BOCs' subscriber listing information practices will be unjustly or unreasonably discriminatory within the meaning of section 10(a)(1). 33. Because section 272(c)(1) literally applies only to BOC discrimination between a separate affiliate and unaffiliated entities, a decision permitting the BOCs to provide E911 services on an integrated basis would relieve those carriers of their obligation to provide unaffiliated entities with the listing information described above. MCI argues that it may therefore be necessary to require separation of the E911 services from the BOCs' local exchange services simply in order to apply the non-discrimination safeguard in section 272(c)(1). Alternatively, MCI contends that we must condition any forbearance from the application of the section 272 separate affiliate requirement on BOC compliance with non-discrimination requirements at least equivalent to those in section 272(c)(1). 34. Because application of the section 272 separate affiliate requirement to the BOCs' E911 services would impose substantial costs without increasing the quality of those services, we conclude that the better approach is to forbear from application of section 272 while maintaining the substance of the non-discrimination safeguard through appropriate conditions. We, therefore, condition our forbearance from the application of section 272's separate affiliate requirement on each BOC's making available to unaffiliated entities all listing information, including unlisted and unpublished numbers as well as the numbers of other LECs' customers, that it uses to provide E911 services. In accordance with the Commission's determination in the Non-Accounting Safeguards Order, each BOC must provide those listings at the same rates, terms, and conditions, if any, it charges or imposes on its own E911 services. 35. The Commission has previously recognized the interests of telephone subscribers in protecting the privacy of their telephone numbers. In doing so, the Commission distinguished between emergency and non-emergency calls, and allowed carriers to transmit otherwise protected telephone numbers to public safety agencies in conjunction with 911 calls. This distinction recognizes that consumers' expectation of privacy may be greater in non-emergency situations than in emergency situations. We believe it appropriate to recognize this distinction in the context of our forbearance decision, especially since section 10(a)(2)of the Act instructs us to consider consumer protection. Accordingly, we require entities that obtain unlisted or unpublished numbers pursuant to the conditions stated in paragraph 34 to use those numbers only to provide E911 services. 36. Routing Information. We reject MCI's argument that application of section 272 to the BOCs' E911 services is necessary to prevent discriminatory BOC practices from impeding MCI's delivery of emergency operator services. MCI claims that it needs access to the information LECs use to route E911 calls to the appropriate PSAPs if it is to fulfill its legal obligation to provide emergency operator services on an interLATA basis. This obligation apparently arises when a caller reaches a MCI operator after dialing "0" rather than "911" to report an emergency. MCI fails to demonstrate that, absent forbearance from section 272, the BOCs would be required to provide information associated with the routing of E911 calls to unaffiliated entities, pursuant to the non-discrimination requirements in section 272. Thus, we decline to require that the BOCs make such routing information available to unaffiliated entities, because we do not believe such a condition is necessary to ensure that BOC provision of E911 service is just, reasonable, and non-discriminatory, in accordance with section 10(a). 37. MCI also argues that we should require the BOCs to make E911 routing information available to unaffiliated entities because the Local Competition Order requires them to do so as part of their obligation to provide access to unbundled local switching. We reject this request because it is beyond the scope of the current proceeding, which concerns application of the section 272 separate affiliate and non-discrimination requirements to BOC provision of certain previously authorized interLATA information services. Thus, while we do not here decide the nature and extent of the obligations that the Local Competition Order places on incumbent LECs to provide E911 routing information, we find that that order, which implements the requirements of section 251, does not address whether the BOCs have an obligation to provide E911 routing information pursuant to section 272. 38. Uploading Data. We also reject MCI's argument that the application of section 272 to the BOCs' E911 services is necessary to facilitate the "uploading" of data about MCI's local exchange customers into the BOCs' E911 databases for purposes of delivering E911 calls. MCI points to no provision of section 272 that would require the BOCs to permit such uploading, and we find no such provision. We, therefore, conclude that MCI's argument has no bearing on whether application of section 272 is necessary to ensure that the BOCs' practices, classifications, and regulations are just, reasonable, and not unjustly or unreasonably discriminatory. 39. Additional Non-Discrimination Requirements. MCI contends that we must condition any forbearance from the application of the section 272 separate affiliate requirements to the BOCs' E911 services on BOC compliance with non-discrimination requirements at least equivalent to those in sections 272(c)(1) and (e). We find, based on the record before us, that the conditions set forth in paragraph 34, effectively impose the non-discrimination safeguards contained in section 272(c)(1) as they relate to the BOCs' E911 services, and are therefore responsive to MCI's section 272(c)(1) argument. MCI, however, does not explain, and we do not see, how the non-discrimination provisions of section 272(e) might require the imposition of any additional requirements on BOC integrated provision of E911 services. In these circumstances, we decline to impose any conditions based on section 272(e). 40. Overall Evaluation. The conditions set forth in paragraph 34 will enable unaffiliated entities to compete with the BOCs for contracts to provide E911 services. In view of these conditions, we find that application of section 272 to the BOCs' E911 services is not necessary to ensure that the BOCs' practices, classifications, and regulations are just and reasonable, and not unjustly or unreasonably discriminatory. c. Other Conditions 41. AT&T suggests that we should require the BOCs to comply with the accounting requirements of section 272 if we permit those companies to provide E911 services on an integrated basis. Although we agree that accounting safeguards are essential to ensuring that the BOCs' E911 operations do not result in unjust, unreasonable, or unjustly or unreasonably discriminatory charges, practices, classifications, or regulations, the accounting requirements in section 272 assume that a section 272 affiliate will provide any interLATA information service, other than electronic publishing and alarm monitoring. We, therefore, adapt those requirements to reflect our decision to permit the BOCs to provide E911 services on an integrated basis. Because the Commission's rules already require the BOCs to account for their E911 services on the books of account that they maintain in accordance with Part 32 of the Commission's rules, we decline to impose additional requirements as to where those carriers should record the costs and revenues of their E911 services. We require, however, that the BOCs treat their E911 services as nonregulated activities for federal accounting purposes to the extent they involve storage and retrieval functions included within the statutory definition of information service. That accounting is consistent with the Commission's determination, in the Accounting Safeguards Order, that the BOCs should account for any interLATA services they provide on an integrated basis as nonregulated activities for federal accounting purposes. 42. In part III.D.1.b, supra, we require the BOCs to make available to unaffiliated entities all listing information that they use to provide their E911 services at the same rates the BOCs charge or impose on their own E911 services operations. To the extent they charge unaffiliated entities for listing information that they use to provide E911 services on an integrated basis, the BOCs must impute the same charges in order to comply with this condition. Consistent with the Accounting Safeguards Order, the BOCs shall record any charges they impute for their E911 services in their revenue accounts. The BOCs shall account for any imputed charges by debiting their nonregulated operating revenue accounts and crediting their regulated revenue accounts by the amounts of the imputed charges. On or before May 4, 1998, the BOCs shall make any changes to their cost allocation manuals necessary to reflect this accounting. The BOCs' independent auditors shall include this accounting in their review of the BOCs' compliance with their cost allocation manuals. 2. Section 10(a)(2) 43. In order to forbear from applying section 272's requirements to the BOCs' E911 services, section 10(a)(2) requires us to analyze whether such application is necessary to ensure the protection of consumers. 44. For reasons similar to those that persuade us that the application of the section 272 requirements is not necessary to ensure that the BOCs' charges, practices, classifications, and regulations are just and reasonable, and not unjustly or unreasonably discriminatory, we also conclude that application of those requirements is not necessary for the protection of consumers. No party before us argues that application of section 272 is necessary to protect consumers in this situation. The prices, terms, and conditions of E911 services are subject to state regulation. The record indicates that the BOCs realize substantial economies from providing E911 services on an integrated basis that would be lost if they were required to provide those information services through separate affiliates. The BOCs, in reliance on Common Carrier Bureau and MFJ Court waivers, have configured their networks to provide E911 services efficiently and reliably. A decision not to forbear thus could compromise system integrity and reliability, to consumers' detriment. Since these facts make it likely that consumers will benefit from the BOCs' integrated provision of these services, we conclude that this forbearance criterion is met. 3. Sections 10(a)(3) and 10(b) 45. In order to forbear, section 10(a)(3) requires us to analyze whether forbearance would be consistent with the public interest. Section 10(b) of the Act elaborates on our obligation: In making the determination under subsection (a)(3), the Commission shall consider whether forbearance from the provision or regulation will promote competitive market conditions, including the extent to which such forbearance will enhance competition among providers of telecommunications services. If the Commission determines that such forbearance will promote competition among providers of telecommunications services, that determination may be the basis for a Commission finding that forbearance is in the public interest. 46. We conclude that forbearance from application of the section 272 requirements to the BOCs' E911 services would be consistent with the public interest. In reaching this conclusion, we reject, as inconsistent with the statutory language, AT&T's suggestion that section 10(b) precludes forbearance absent a showing that it would enhance competition among providers of telecommunications services. We conclude, instead, that the integrated provision of E911 services, as authorized by prior Common Carrier Bureau and MFJ Court waivers, produces substantial cost savings and helps ensure the reliability of those vital public services. These cost savings and increases in reliability persuade us that forbearance would be consistent with the public interest. 47. AT&T's argument that we cannot forbear absent an affirmative showing that forbearance would enhance competition among providers of telecommunications services is apparently based on the language of section 10(b). That subsection, however, requires that we "consider" whether forbearance would "promote competitive market conditions, including the extent to which such forbearance will enhance competition among providers of telecommunications services." In requiring us to "consider" this particular public interest factor, Congress clearly did not intend to preclude our consideration of other factors. The public interest is a broad standard, to be exercised consistent with the underlying goals of the Communications Act, as amended by the 1996 Act. 48. Section 10(b) also states that if we determine that "forbearance will promote competition among providers of telecommunications services, that determination may be the basis for a Commission finding that forbearance is in the public interest." The plain meaning of this statutory language is that a determination that forbearance would promote competition is a possible, though not a necessary, basis for a finding that forbearance would be consistent with the public interest. As SBC asserts, "[w]ere it otherwise, no petition could ever be granted that, although neutral in competitive effect, would clearly advance the public interest. . . ." 49. The record in this proceeding, however, will not support a finding that forbearance from the application of section 272 to the BOCs' E911 services "will promote competition among providers of telecommunications services" within the meaning of section 10(b). Consistent with our conclusion above that the Act does not require such a finding, we therefore conclude in this case that competitive effects should not form the basis of our public interest determination under section 10(a). To support their argument that forbearance would promote competition among providers of telecommunications services, the BOCs rely on Common Carrier Bureau findings under the Computer II rules, and District Court and DOJ findings under the MFJ. The BOCs observe that the Bureau concluded that BOC provision of E911 did not pose a threat to competition and that the service might not be provided absent BOC provision; that the MFJ Court found that BOC provision of E911 services on an integrated basis "will not endanger competition;" and that DOJ found that "[a]llowing the BOCs to provide interLATA 911 service and E911 service is in the public interest for it permits customers to reach providers of emergency services conveniently and efficiently [and] does not present any threat to competition among interexchange service providers." 50. We agree with AT&T that in making these findings, the Bureau, MFJ Court, and DOJ were concerned with the effects of BOC integrated provision of E911 services on competition among interexchange carriers. We also recognize that section 10(b) is concerned more broadly with "competitive market conditions" and "competition among providers of telecommunication services," which include both local and interexchange service providers. The Bureau, MFJ Court, and DOJ findings, moreover, were made in 1982 and 1985, 1984, and 1991, respectively. Since those times, technological and regulatory changes have altered competitive conditions in the telecommunications markets. Thus, the Bureau, MFJ Court, and DOJ findings, though relevant, provide only a starting point for assessing the competitive effects of forbearance from the application of the section 272 requirements to the BOCs' E911 services. The BOCs, however, provide no information or analysis to take us beyond this starting point. In addition, as the conditions set forth in paragraph 34 should ensure that unaffiliated entities obtain access to the same information that they would have obtained absent forbearance, grant of the BOCs' E911 petitions is unlikely to affect competitive conditions. 51. In reliance on the Bureau and MFJ Court waivers, the BOCs have configured their networks to provide E911 services efficiently and reliably. We agree with the BOCs' claim that providing E911 services on an integrated basis saves money and enhances the reliability of those services. Application of section 272 to the BOCs' E911 services would increase costs, because it would require the BOCs to construct new facilities to provide E911 services either on a purely intraLATA basis or through separate affiliates. We also agree that such a reconfiguration of the BOCs' E911 services could compromise system integrity and reliability, which would be contrary to the fundamental purpose of E911. Thus, applying the section 272 separate affiliate requirements to BOC provision of E911 services would prevent them from continuing to realize the economies and efficiencies that the Bureau and MFJ Court waivers permitted. Since the BOCs' competitors can realize these economies and efficiencies through the provision of E911 services on an integrated basis, we conclude that forbearance from the application of section 272 to the BOCs' E911 services would serve the public interest, so long as forbearance is conditioned as stated above. Because we also conclude that the first and second criteria for forbearance are met, section 10 mandates that we forbear from such application. We so forbear. IV. BELLSOUTH'S REVERSE DIRECTORY SERVICES A. Description of Services 1. Operator-Assisted Reverse Directory Services 52. Reverse directory services provide the user with a telephone customer's name, address, or both, upon the input of a telephone subscriber's number. BellSouth provides both operator-assisted and electronic reverse directory services. The operator-assisted service uses the same trunking and switching facilities, centrally-located operator service centers, centralized databases, and personnel that BellSouth uses to provide its traditional voice-based, directory assistance services. BellSouth states that, in addition to information regarding BellSouth customers, these databases contain the names, addresses, and telephone numbers of subscribers of other carriers, including other incumbent LECs and competing LECs, in the BellSouth region. The databases include non-listed information (i.e., listings available through directory assistance but not in printed white pages directories), but do not include non-published listings (i.e., listings available through neither directory assistance nor printed white pages directories). BellSouth states that it has been providing operator-assisted reverse directory services since the MFJ Court authorized it to do so in 1989. 53. To obtain reverse directory information for numbers within the customer's toll- free calling area, users of BellSouth's operator-assisted reverse directory services dial the same local number (411) that they use to obtain standard directory assistance services. BellSouth states that it routes operator-assisted reverse directory services over the same network using the same resources as it uses for standard directory assistance services. BellSouth also states that each type of call terminates in an automatic answering system located in a traffic operator position system (TOPS) switch located within the caller's LATA. This system, according to BellSouth, prompts the caller to provide his or her information request, records the caller's information request, and then signals a TOPS host, which finds an available directory assistance operator who serves the caller's state. BellSouth states that this operator plays back the caller's information request, retrieves the requested information from one of BellSouth's two centrally located, directory assistance databases, and orally conveys the information to the caller. BellSouth states further that it provides all facilities for communications between the customer and the operator, and between the operator and the database, for these reverse directory and directory assistance services. 54. To obtain reverse directory information for a location outside his or her toll-free calling area using BellSouth's operator-assisted reverse directory service, the caller dials 1+NPA+555-1212. These calls are routed to the caller's interexchange carrier. BellSouth states that the call flow activity for these calls is identical to that for 411 calls, except that when a caller seeks information for a number in a LATA other than the caller's LATA, an interexchange carrier provides the transmission link between the caller and a TOPS switch located in a distant LATA. When an interexchange carrier routes a reverse directory call to a BellSouth TOPS switch, BellSouth provides any transmissions between that switch and the directory assistance operator. 2. Electronic Reverse Directory Services 55. BellSouth offers electronic white pages and electronic reverse directory services that allow subscribers to use their personal computers to obtain directory and reverse directory information. These subscribers use personal identification number codes to access one of BellSouth's centralized, directory assistance databases. BellSouth states that although it also uses this database to provide operator-assisted directory assistance and reverse directory services, its electronic services provide access to listings that are not available through its operator- assisted services. These additional listings, according to BellSouth, consist of directory listing information that "independent or other telephone carriers" have authorized BellSouth to make available through its electronic, but not its operator-assisted, services. BellSouth did not offer either of these electronic services prior to July 1996. In July 1996, BellSouth received a Common Carrier Bureau waiver authorizing it to provide electronic reverse directory services. 56. BellSouth subscribers have a choice of two types of electronic reverse directory services, a home numbering plan area service and a regional service. BellSouth states that the home numbering plan area service allows a subscriber to obtain reverse directory information only for customers in the subscriber's numbering plan area. To access this service, the subscriber calls a local telephone number. BellSouth then uses its own facilities to transmit the call to its centralized database and thus provides an interLATA transmission component whenever this transmission crosses LATA boundaries. 57. BellSouth's "regional" electronic service lets the subscriber obtain reverse directory information for locations throughout BellSouth's region, including locations within the customer's numbering plan area. BellSouth does not provide any interLATA transmission associated with this service. Instead, subscribers to the "regional" service must use an interexchange carrier to obtain any interLATA service required to communicate with the centralized database. 58. BellSouth states that it has negotiated over 90 interconnection agreements that allow competing LECs to resell BellSouth's directory assistance services. BellSouth also states that these resale offerings include reverse directory functions for every directory listing in BellSouth's database, including those of non-BellSouth subscribers. BellSouth states further that competitive LECs that wish to provide their own directory assistance services (in lieu of reselling BellSouth's services) can obtain from BellSouth the information about BellSouth customers necessary to populate their databases with the information about those customers that is in BellSouth's directory assistance database. BellSouth states that it handles an average of about 3.2 million directory assistance calls each day and that thousands of these calls are reverse directory calls. B. Need for Forbearance to Operate on an Integrated Basis 59. As part III.B of this Order indicates, sections 272(a)(2)(B)(iii) and 272(a)(2)(C) of the Communications Act preclude BellSouth from providing the services described in section 271(f) of the Act on an integrated basis only to the extent those services include interLATA information services. We address here the extent to which BellSouth's reverse directory services are such information services. 60. The Communications Act defines "information service" as "the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications, and includes electronic publishing, but does not include any use of any such capability for the management, control, or operation of a telecommunications system or the management of a telecommunications service." The record in this proceeding makes clear that each of BellSouth's reverse directory services provides users with the capability to acquire and retrieve information (i.e., the names and addresses of telephone subscribers) via telecommunications. Those services thus fall squarely within the statutory definition of information service. 61. The record also makes clear that three of the four types of reverse directory services that BellSouth offers -- its operator-assisted service for numbers within the toll-free calling area, its operator-assisted service for numbers outside that calling area, and its "home NPA" electronic service -- are interLATA information services, whenever the centralized database from which the reverse directory information is acquired or retrieved is located in a LATA different from that where the customer's call originates. This is because each of these three services incorporates as a necessary, bundled element for a single charge an interLATA telecommunications transmission component. In contrast, subscribers to BellSouth's "regional" electronic reverse directory service must purchase that service separately from the interLATA transmissions that allow the subscriber to communicate with BellSouth's centralized database. This "regional" service, therefore, is an intraLATA information service that BellSouth need not provide through a separate affiliate. 62. BellSouth states that the MFJ Court classified operator-assisted reverse directory services as information services, but points out that the Court required BellSouth to use revenues from those services to support regulated operations. BellSouth argues that this judicial requirement effectively rendered operator-assisted reverse directory services "adjunct to exchange or exchange access service" for MFJ purposes, and thus telecommunications services. We reject the notion that the MFJ Court's actions require or permit us to treat reverse directory services as telecommunications services. As AT&T points out, that Court specifically held that reverse directory services are "clearly" information services within the meaning of the MFJ because they offer "a capability for . . . retrieving . . . information which may be conveyed by telecommunications." If we were to follow the MFJ Court in this matter, we would determine that BellSouth's reverse directory services are information services. 63. We also reject BellSouth's suggestion that we should treat its reverse directory services as adjunct services, as defined in the NATA Centrex proceeding. As previously indicated, adjunct services "facilitate the provision of basic services without altering their fundamental character," and are treated as basic services for purposes of the Computer II rules, even though they might fall within possible literal readings of the definition of enhanced services. In the Non-Accounting Safeguards Order, we determined that such adjunct services should be treated as telecommunications, rather than information, services under the Communications Act. As explained below, BellSouth's reverse directory services do not "facilitate the provision of basic services without altering their fundamental character" and thus cannot be classified as adjunct services. 64. BellSouth's instant request is similar to an argument that it previously advanced that its electronic reverse directory services should be classified as adjunct services so that BellSouth could offer them on an integrated basis without complying with, or obtaining a waiver of, the Commission's comparably efficient interconnection (CEI) requirements. In rejecting that argument, the Common Carrier Bureau observed that the NATA Centrex Order had distinguished between an enhanced service (AT&T's "Dial-it" service) and an adjunct service (directory assistance) by stating: The only significant difference between Dial-it and directory assistance is that the latter service provides only that information about another subscriber's telephone number which is necessary to allow use of the network to place a call to that other subscriber. The Bureau determined that, like Dial-it service, BellSouth's electronic reverse directory services, provide information in addition to that necessary to use the network to place a call and therefore could not be classified as adjunct services. BellSouth presents no reason for departing from this prior determination and for not applying it to BellSouth's operator-assisted reverse directory services, which also provide information in addition to that necessary to use the network to place a call. We consequently find no basis in the record in this proceeding for concluding that BellSouth's operator-assisted and electronic reverse directory services are adjunct services. C. Authority to Forbear 65. In part III.C of this Order, supra, we determine that we have authority to forbear from the application of section 272 to BOC provision of the previously authorized activities described in section 271(f) of the Communications Act and the incidental activities described in section 271(g) of that Act. In the preceding section of this order, we determine that BellSouth's operator-assisted and "home NPA" electronic reverse directory services include interLATA information services. In this section, we address whether these services fall within the scope of either section 271(f) or section 271(g). 66. BellSouth points to a June 2, 1989, Order of the MFJ Court that authorized it to provide reverse directory services. BellSouth states that the waiver request leading to this Order was a "me too" request based on a similar authorization the MFJ Court had previously granted Ameritech. BellSouth also states that the Ameritech Reverse Directory Order broadly addressed services under which "the company provides a customer's name, his address, or both, upon the input of a telephone number." MCI and Sprint maintain that the MFJ waiver BellSouth received during 1989 did not authorize it to provide electronic reverse directory services. Sprint points out that BellSouth did not begin offering electronic reverse directory services until after receiving a CEI waiver in 1996. MCI and Sprint contend that the significant differences between BellSouth's operator-assisted reverse directory services and its electronic reverse directory services make the MFJ waiver inapplicable to the electronic services. Sprint states, in particular, that, unlike operator-assisted reverse director services in which interexchange carriers transmit any interLATA calls to BellSouth's operator centers, BellSouth's "home NPA" service involves interLATA transport by BellSouth. 67. In the BellSouth Reverse Directory Order, the MFJ Court waived section II(D)(2) of the MFJ to permit BellSouth to provide "customer name and address service" throughout the BellSouth region. The parties addressing this issue all agree that this Order authorized BellSouth to provide operator-assisted reverse directory services. We find that position correct and therefore determine that those services are previously authorized services within the meaning of section 271(f) of the Act and thus subject to our forbearance authority. 68. BellSouth's "home NPA" electronic reverse directory service permits subscribers to obtain reverse directory information from a centrally located BellSouth database. We agree with BellSouth and find that this service falls squarely within section 271(g)(4) of the Act, which permits the interLATA provision by a BOC or its affiliate "of a service that permits a customer that is located in one LATA to retrieve stored information from . . . information storage facilities of such company that are located in another LATA." Since we have authority to forbear from the application of section 272 to such storage and retrieval services, we see no need to resolve the dispute over whether the MFJ Court's BellSouth Reverse Directory Order authorized BellSouth to provide its "home NPA" reverse directory service. D. Application of Forbearance Criteria 69. As set forth above, section 10(a) requires that we forbear from the application of section 272 to BellSouth's reverse directory services if we conclude that section 272 is not necessary to ensure that the charges, practices, classifications, or regulations are just and reasonable, and not unjustly or unreasonably discriminatory; that it is not necessary for the protection of consumers; and forbearance would be consistent with the public interest. BellSouth claims that it satisfies these three statutory criteria. AT&T, MCI, and Sprint claim that it does not, for various reasons. 1. Section 10(a)(1) 70. First, we address whether application of section 272 to BellSouth's reverse directory services is "necessary to ensure" that BellSouth's "charges, practices, classifications or regulations . . . are just and reasonable, and are not unjustly or unreasonably discriminatory." As summarized above, BellSouth provides three types of reverse directory services -- its operator-assisted service for numbers within the customer's toll-free calling area, its operator-assisted service for numbers outside the customer's toll-free calling area, and its "home NPA" electronic service -- that constitute interLATA information services to the extent the centralized database from which the reverse directory information is acquired or retrieved is located in a LATA different from that where the customer's call originates. We conclude that the first forbearance criterion is satisfied with regard to these services, provided BellSouth makes available to unaffiliated entities all directory listing information that it uses to provide its reverse directory services at the same rates, terms, and conditions, if any, BellSouth charges or imposes on its reverse directory operations. a. Just, Reasonable, and Non-discriminatory Charges 71. We consider first the effect, if any, that application of section 272 to BellSouth's reverse directory services would have on BellSouth's charges for operator-assisted reverse directory services. As BellSouth points out, the MFJ Court conditioned BellSouth's authorization to provide reverse directory services on the use of the associated revenues to support regulated operations. In compliance with this condition, BellSouth has included operator-assisted services in its general subscriber tariffs for end-users, and intrastate access tariffs, which are on file with the appropriate state agencies, and its interstate access tariffs. BellSouth indicates that it uses the revenues generated by the rates set in these tariffs to reduce the rates for its regulated telecommunications services. 72. BellSouth argues that existing regulations, in the form of the tariffing process and complaint procedures, are sufficient to ensure that its charges for its operator-assisted reverse directory services are just and reasonable. This argument implicitly assumes that BellSouth will continue to be subject to the MFJ Court's requirement that BellSouth use reverse directory revenues to support regulated operations. If, however, BellSouth receives authorization, pursuant to section 271(d)(3), to originate interLATA services in an in-region state, its provision of operator-assisted reverse directory services in that state will no longer be subject to the terms of the MFJ Court's waiver. Once those terms cease to be effective, BellSouth will be free to retain any profits it earns from those services unless the relevant State commission requires to the contrary. We cannot forbear based on BellSouth's compliance with a condition that may cease to be effective. 73. In these circumstances, we must assess the consequences if BellSouth were permitted to provide its operator-assisted reverse directory services on an integrated basis and no longer were required to use the revenue from those services to support regulated operations. As an initial matter, BellSouth states, and opponents of its petition do not dispute, that the costs of providing its reverse directory services through a separate affiliate would be much higher than the costs of providing those services on an integrated basis. Consequently, BellSouth's charges for these services would almost certainly be higher. We find that BellSouth has made a convincing showing that it achieves significant economies in using the same facilities and personnel to offer reverse directory services as it uses for its standard directory assistance operation. If we were to preclude BellSouth from providing operator-assisted reverse directory services on an integrated basis, BellSouth either would have to cease providing those services or provide them through a separate affiliate. The first result would be contrary to the 1996 Act's policy of encouraging competition in all markets. The second would significantly increase BellSouth's costs of providing operator-assisted reverse directory services and, if the State commissions were to allow BellSouth to recover the increased costs, the consequent charges to consumers. 74. As stated above, the MFJ Court condition will cease to be effective in any state for which BellSouth receives section 271(d)(3) authorization. We recognize, of course, that this condition may have constrained BellSouth's charges for operator-assisted reverse directory services and that the elimination of that condition may induce BellSouth to increase those charges to the extent the relevant State commissions permit. Our forbearance decision regarding operator-assisted reverse directory services, however, will affect neither the efficacy of that condition nor the State commissions' ability to regulate the prices for those services in the event the Commission authorizes BellSouth to originate in-region interLATA services. We therefore conclude that the MFJ Court condition does not require that section 272 continue to apply to BellSouth's operator-assisted reverse directory services. 75. In addition, BellSouth has provided operator-assisted reverse directory services since 1989, using the same personnel and facilities that it uses to provide its standard directory assistance services. Even though BellSouth's operator-assisted reverse directory services thus are well-established, BellSouth's standard directory assistance operations dwarf its operator- assisted reverse directory operations. Of the roughly 3,200,000 calls to directory assistance that BellSouth receives each day, only thousands seek reverse directory information. These relative call volumes make clear that BellSouth's charges for services other than reverse directory services likely would not change significantly even if BellSouth were to cease using revenues from those services to support regulated operations, as the MFJ Court condition presently requires. 76. With respect to its electronic reverse directory services, BellSouth argues that although the Commission has treated the service as "enhanced" and thus not subject to regulation and tariffing, competition is sufficient to ensure that its charges are just and reasonable, and non- discriminatory. BellSouth states that these services face competition from interexchange carriers, Internet service providers, information service providers, alternate directory assistance providers (such as cellular service and payphone providers), and paper directories, among other sources. BellSouth also states that it facilitates this competition by making its own directory listing information available under tariff and by allowing competing LECs to resell its operator- assisted directory assistance services. BellSouth, however, provides no information or analysis that might support a conclusion that its "home NPA" electronic reverse directory service will face meaningful competition from other providers of reverse directory services if BellSouth does not provide unaffiliated entities with access to all listing information that BellSouth uses to provide its "home NPA" service. Indeed, the database BellSouth uses to provide its "home NPA" electronic reverse directory service contains listing information for LECs throughout BellSouth's region, information that BellSouth uses to provide its "home NPA" electronic reverse directory service, but refuses to provide unaffiliated entities that wish to maintain their own directory services databases. In view of this refusal, we cannot assume that alternative providers of reverse directory services are able to compete effectively against BellSouth's "home NPA" electronic reverse directory service. 77. As discussed more fully below, we conclude that we may forbear from the application of section 272 to BellSouth's reverse directory services only if we condition that action on BellSouth's providing any other entity with all listing information that it uses to provide its reverse directory services at the same rates, terms, and conditions, if any, BellSouth charges or imposes on its reverse directory operations. Since this condition will require BellSouth to make available to others listings for which it offers reverse directory services, we conclude that competition with BellSouth's reverse directory services will be sufficient to ensure that forbearance in this instance will not result in BellSouth's charges being unjust, unreasonable, or unjustly or unreasonably non-discriminatory. b. Just, Reasonable, and Non-discriminatory Practices, Classifications, and Regulations 78. AT&T's and MCI's fundamental objection to our forbearing from the application of section 272 to BellSouth's reverse directory services is based on BellSouth's refusal to provide to unaffiliated entities listings for subscribers of other LECs that BellSouth uses to provide its own reverse directory services. AT&T objects to forbearance from the non-discrimination and accounting requirements of sections 272(c) and (e). MCI maintains that BellSouth's practice of not providing information about subscribers of other LECs when it uses such information for its own reverse directory services is unlawfully discriminatory and that we must apply the non- discrimination provisions of sections 272(c) and (e) to BellSouth's reverse directory operation to prevent continuation of the practice. 79. We agree that if BellSouth were providing reverse directory services through a separate affiliate, BellSouth's practice of denying access to certain subscriber listings would be inconsistent with section 272(c)(1) of the Communications Act. That section specifies that a BOC "may not discriminate between its [section 272] affiliate and any other entity in the provision of . . . information." This provision makes clear that BellSouth could not provide its section 272 affiliate with listing information obtained from other LECs without also making that information available to third parties. As the Commission stated in the Non-Accounting Safeguards Order, section 272(c)(1) "establishes an unqualified prohibition against discrimination by a BOC in its dealings with its section 272 affiliate and other entities." This prohibition extends to any information that a BOC provides to its section 272 affiliate. 80. BellSouth also uses directory listings for its own customers to provide its reverse directory services. If BellSouth were providing reverse directory services through a separate affiliate, it would have to provide all the listing information that it uses to provide those services to unaffiliated entities at the same rates, terms, and conditions, if any, it charges or imposes on its own reverse directory operations. While BellSouth states that it provides directory listings for its own customers to competitive providers of reverse directory services, it makes no claim that it provides that information at the same rates, terms, and conditions that it charges or imposes on itself. 81. Under section 272(c)(1), a practice of not providing unaffiliated entities with all of the subscriber listings that a BellSouth affiliate uses to provide reverse directory services at the same rates, terms, and conditions that it charges or imposes on itself would be deemed discriminatory, if BellSouth provided the affiliate with those listings. We must consider, however, whether this practice would be unjustly or unreasonably discriminatory within the meaning of section 10(a)(1). BellSouth argues that competitive providers of reverse directory services can obtain listing information regarding other LECs' customers directly from those carriers and that the other carriers have an obligation to provide such information. BellSouth also argues, in effect, that complaint procedures and non-discrimination safeguards elsewhere in the Communications Act make it unnecessary for the Commission to rely on section 272(c)(1) to guarantee BellSouth's competitors access to listing information that BellSouth obtains from other LECs and uses in its reverse directory services. We agree with MCI that BellSouth obtained directory listings from other LECs for use in its directory assistance services solely because of its dominant position in the provision of local exchange services throughout its region. That position enables BellSouth to include listings for customers of other incumbent LECs and competitive LECs as well as its own customers within the databases it uses to provide reverse directory services. Because BellSouth has the vast majority of access lines within its region, it is to the advantage of independent LECs and competitive LECs to have the listings of their customers included in BellSouth's directory listing databases so that callers throughout the region using BellSouth lines can obtain the telephone numbers of non-BellSouth customers. In some instances at least, the other independent LEC or competitive LEC does not charge BellSouth for including these listings within those databases, presumably because it is economically beneficial for that independent or competitive LEC to have its customers' listings maintained in the BellSouth databases. 82. The circumstances described above indicate that BellSouth has competitive advantages in the provision of reverse directory services within its region. Based on the record before us, we conclude that these competitive advantages stem from BellSouth's dominant position in the provision of local exchange services in the BellSouth region. These advantages will persist if BellSouth continues to deny unaffiliated entities access to all of the listing information that it uses to provide reverse directory services or if BellSouth fails to provide such access at the same rates, terms, and conditions, if any, that it charges or imposes on itself. We therefore conclude that, until it provides such access at those rates, terms, and conditions, BellSouth's subscriber listing information practices will be unjustly or unreasonably discriminatory within the meaning of section 10(a)(1). 83. Because section 272(c)(1) literally applies only to BOC discrimination between a separate affiliate and unaffiliated entities, a decision permitting BellSouth to provide its reverse directory services on an integrated basis would relieve that carrier of its obligation to provide unaffiliated entities all listing information that it uses to provide interLATA reverse directory services. As AT&T and MCI suggest, we conclude, consistent with our determination in section III.D.1.b, supra, that we should forbear from application of section 272 to BellSouth's interLATA reverse directory services, yet effectively impose the non-discrimination safeguards contained in section 272(c)(1)'s non-discrimination safeguards through appropriate conditions. We therefore condition our forbearance from the application of section 272's separate affiliate requirement on BellSouth's making available to unaffiliated entities all directory listing information that it uses to provide its interLATA reverse directory services. In accordance with the Commission's determination in the Non-Accounting Safeguards Order, BellSouth must provide those listings at the same rates, terms, and conditions, if any, it charges or imposes on its own reverse directory operations. These conditions will enable unaffiliated entities to compete effectively with BellSouth's interLATA reverse directory services. In view of these conditions, we find that application of section 272 to BellSouth's interLATA reverse directory services is not necessary to ensure that the BOCs' practices, classifications, and regulations are just and reasonable, and not unjustly or unreasonably discriminatory. 84. BellSouth contends that it is not legally obligated to provide, and absent the other LECs' consent, is prohibited from providing, other carriers with access to information about subscribers of other LECs in its directory assistance databases. Because BellSouth is not legally obligated to provide reverse directory services, it can comply with any duty it has not to disclose listing information obtained from other LECs by declining to use that information in its own interLATA reverse directory services. As a consequence, the conditions set forth above will not force BellSouth to violate any non-disclosure obligation it may have regarding information about the other LECs' subscribers. In addition, while BellSouth suggests that Communications Act provisions other than section 272 may give interexchange carriers the right to obtain directory listing information, we conclude, based on the record before us, that BellSouth to date has not given those carriers all the directory listing information that it uses to provide interLATA reverse directory services. In this circumstance, the conditions set forth above are necessary to ensure that our forbearance decision regarding reverse directory services does not result in unjustly and unreasonably discriminatory BellSouth practices. c. Other Conditions 85. AT&T suggests that we should require BellSouth to comply with the accounting requirements of section 272 if we permit BellSouth to provide reverse directory services on an integrated basis. Although we agree that accounting safeguards are essential to ensuring that BellSouth's reverse directory operations do not result in unjust, unreasonable, or unjustly or unreasonably discriminatory charges, practices, classifications, or regulations, the accounting requirements in section 272 assume that a section 272 affiliate will provide any interLATA information service, other than electronic publishing and alarm monitoring. We, therefore, adapt those requirements to reflect our decision to permit BellSouth to provide interLATA reverse directory services on an integrated basis. Because the Commission's rules already require BellSouth to account for its reverse directory services on the books of account that it maintains in accordance with Part 32 of the Commission's rules, we decline to impose additional requirements as to where BellSouth should record its reverse directory costs and revenues. BellSouth, however, must treat its reverse directory services as nonregulated activities for federal accounting purposes. 86. To the extent it charges unaffiliated entities for directory listings that it uses to provide reverse directory services, BellSouth must impute the same charge to itself in order to comply with the condition that it charge itself and others the same rates for such directory listings. BellSouth shall record any charges it imputes for its "home NPA" and operator-assisted reverse directory services in its revenue accounts. BellSouth shall account for these imputed charges by debiting its nonregulated operating revenue account and crediting a regulated revenue account by the amount of the imputed charges. On or before May 4, 1998, BellSouth shall make any changes to its cost allocation manual necessary to reflect this accounting. BellSouth's independent auditor shall include this accounting in its review of BellSouth's compliance with its cost allocation manual. 2. Section 10(a)(2) 87. Under section 10(a)(2), we must evaluate whether the application of section 272 is necessary for the protection of consumers. 88. The 1996 Act's fundamental objective is to bring consumers of telecommunications services in all markets the full benefits of competition. Section 272 attempts to further that objective by imposing on the BOCs requirements designed, in the absence of full local exchange competition, to prohibit anticompetitive discrimination and cost- shifting. The question before us is whether application of the section 272 safeguards to the specific interLATA reverse directory services that BellSouth offers is necessary for the protection of consumers. Based on the present record, we conclude that it is not. 89. BellSouth has offered its operator-assisted reverse directory services since 1989. In granting BellSouth a waiver to provide those services, the MFJ Court required that the BellSouth operating companies "will use the revenues generated by [that] service solely to support their regulated operations and will not divert those revenues to support other business ventures." In accordance with this condition, BellSouth has included the operator-assisted reverse directory services in its tariffs for directory assistance services. BellSouth states that the tariffing process protects consumers by ensuring that rates and terms are just and reasonable. BellSouth argues that application of the requirements of section 272 to its operator-assisted reverse directory services would provide consumers no greater protection than that described above. 90. We again recognize that if BellSouth receives authorization, pursuant to section 271(d)(3), to originate in-region, interLATA services, its ability to provide operator-assisted reverse directory services will no longer be subject to the terms of the MFJ Court's waiver and that we cannot forbear based on BellSouth's compliance with a condition that may cease to be effective. Despite this concern, our assessment of the potential consequences of regulatory forbearance persuades us that application of section 272 to BellSouth's operator-assisted reverse directory services is not necessary for the protection of consumers. As our discussion of the first forbearance criterion makes clear, precluding BellSouth from providing operator-assisted reverse directory services on an integrated basis would result in either BellSouth's ceasing to provide those services or, if BellSouth were to provide those services through a separate affiliate, higher charges to consumers. Neither result would benefit consumers. 91. We also find that application of section 272 to BellSouth's "home NPA" electronic reverse directory services is not necessary for the protection of consumers. In our discussion of the first forbearance criterion, we determine that BellSouth must make available to unaffiliated entities all directory listing information that it uses to provide interLATA reverse directory services. We also determine that this condition should promote the development of a fully competitive market for those services. BellSouth's "home NPA" electronic reverse directory service is a mechanization of operator-assisted reverse directory services that BellSouth has offered since 1989 on an integrated basis. We find that, given the safeguards on which we condition our approval and the likely future availability of competitive alternatives, consumers will benefit from allowing BellSouth to offer its previously authorized, operator-assisted reverse directory services on an electronic basis, without moving the mechanized service to a separate affiliate. 92. In concluding that application of section 272 to BellSouth's reverse directory services is not necessary for the protection of consumers, we reject BellSouth's position that section 272 has little direct bearing on consumer protection as a general matter. Although, as BellSouth points out, the specific safeguards in section 272 address a BOC's relationship with its separate affiliate, Congress designed those safeguards to prohibit anti-competitive discrimination and cost-shifting while giving consumers the benefit of competition. 93. We also reject BellSouth's argument that compliance with the Commission's cost allocation, cost allocation manual, and independent audit requirements provides sufficient consumer protection and that we should, therefore, find this forbearance criterion satisfied solely on that basis. Congress was aware of these requirements when it required the BOCs to provide interLATA information services only through separate affiliates. A finding that compliance with the Commission's cost allocation, cost allocation manual, and independent audit requirements, and with parallel state requirements, is sufficient to protect consumers would be inconsistent with the Congressional judgment that led to that separate affiliate requirement. Instead, we must analyze, as we have above, the conditions under which the carrier would provide the specific services for which forbearance is sought to determine whether application of section 272 to those services is necessary for the protection of consumers. 3. Sections 10(a)(3) and 10(b) 94. Section 10(a)(3) sets forth the third criterion for forbearance. We must evaluate whether forbearance would be consistent with the public interest. This evaluation must include consideration of whether forbearance would promote competitive market conditions. 95. We conclude that forbearance would be consistent with the public interest. Consumers benefit from BellSouth's providing operator-assisted reverse directory and electronic reverse directory services on an integrated basis. They benefit by being able to call a single number to obtain directory assistance and reverse directory services. As discussed above, if BellSouth were to offer reverse directory services through a separate affiliate, BellSouth's costs of providing those services would increase significantly. These costs would presumably be passed through to consumers in the form of increased charges. 96. With respect to competition, we conclude that the market for reverse directory services likely will become increasingly competitive in BellSouth's region, given the conditions set forth in paragraph 83, supra. The record in this proceeding indicates that directory services are available through interexchange carriers, Internet services, CD-ROMs, alternate directory assistance providers (e.g., cellular providers, payphone service providers), white pages and yellow pages, and electronic versions of white pages and yellow pages. Reverse directory services, in particular, are available through at least Internet services and CD-ROMs. As discussed above, these alternative providers will be able to obtain from BellSouth all directory listing information that BellSouth uses to provide interLATA reverse directory services. Provision of these listings should ensure that efficient alternative providers of reverse directory services will be able to compete against BellSouth. 97. We further conclude that forbearance would promote competition. As BellSouth explains, application of section 272 would require it, and only it, to offer reverse directory services only through a separate affiliate, and thus prohibit it, and only it, from realizing economies of scale from offering those services and its electronic directory assistance services on an integrated basis. Opponents of forbearance are correct that section 272 is designed to deprive BOCs and their affiliates of advantages derived from the BOCs' local exchange and exchange access monopolies. When, as the conditions set forth in paragraph 83 should ensure with regard to reverse directory services, consumers can select from among a number of competitive alternatives, however, the BOC derives no undue advantages from those monopolies. Conversely, allowing BellSouth to provide reverse directory services on an integrated basis would allow it to compete in a more efficient manner in the market for those services. Although, as Sprint suggests, integration of BellSouth's reverse directory services and basic exchange service operations may allow BellSouth to dissuade some consumers from using competitors' directory assistance or reverse directory services, BellSouth's competitors also will be able to integrate their reverse directory services with other offerings. Because the conditions set forth in paragraph 83 should enable consumers to choose from among a number of competitive providers of reverse directory services, we conclude that forbearance from the application of section 272 to BellSouth's reverse directory services would be consistent with the public interest. Because we also conclude that the first and second criteria for forbearance are met, section 10 mandates that we forbear from such application. We so forbear. V. CONCLUSION 98. In this Order, we apply the forbearance criteria in section 10 of the Communications Act to the BOCs' E911 services, BellSouth's operator-assisted reverse directory services, and BellSouth's "home NPA" reverse directory service. Our conclusion that the application of section 272 to those services would be inconsistent with those forbearance criteria, given the conditions we impose, reflects the unusual circumstances produced by the MFJ Court waivers. Unlike virtually all of the interLATA information services that a BOC might wish to offer directly, the BOCs' E911 services and BellSouth's operator-assisted reverse directory services were the subject of such waivers. In accordance with those waivers, the BOCs provided their E911 services and BellSouth provided operator-assisted reverse directory services on an integrated basis prior to the enactment of the 1996 Act. For the reasons stated above, we conclude that it is in the public interest to allow the BOCs to continue to provide E911 service on an integrated basis, and to allow BellSouth to continue to provide reverse directory services on an integrated basis. Having concluded that the statutory criteria for forbearance are satisfied, section 10 requires us to forbear from the application of section 272 to the BOC's E911 services, and BellSouth's reverse directory services. VI. ORDERING CLAUSES 99. Accordingly, IT IS ORDERED, pursuant to Section 10 of the Communications Act of 1934, as amended, 47 U.S.C.  160, that the following petitions for forbearance are GRANTED, subject to the conditions regarding E911 services stated in Part III.D.1 and the conditions regarding reverse directory services stated in Part IV.D.1 of this Order: a. Ameritech Corp., Amended and Restated Petition for Forbearance, dated May 13, 1997, as supplemented by its showing, dated June 30, 1997, to the extent that petition concerns E911 services; b. Bell Atlantic, Petition for Forbearance, dated March 6, 1997, as supplemented by its showing, dated June 30, 1997 (involving E911); c. BellSouth Corporation, Petition for Forbearance, dated February 7, 1997, as supplemented by its showing, dated June 30, 1997 (involving E911 and reverse directory services); d. NYNEX Telephone Companies, Petition for Forbearance, dated May 6, 1997, as supplemented by its showing, dated June 30, 1997 (involving E911); e. Pacific Telesis Group, Petition for Forbearance, dated March 19, 1997 (involving E911); f. Southwestern Bell Telephone Company, Petition for Forbearance, dated March 17, 1997, as supplemented by its showing, dated July 10, 1997 (involving E911); and g. U S West Communications, Inc., Petition for Forbearance, dated March 14, 1997, as supplemented by its showing, dated June 30, 1997 (involving E911). 100. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and 10 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i) & 160, that each of the BOCs shall comply with the conditions stated in Part III.D.1 of this Order. 101. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and 10 of the Communications Act of 1934, as amended, 47 U.S.C.  154(i) & 160, that BellSouth shall comply with the conditions stated in Part IV.D.1 of this Order. FEDERAL COMMUNICATIONS COMMISSION A. Richard Metzger, Jr. Chief Common Carrier Bureau APPENDIX A FEBRUARY 14, 1997 PUBLIC NOTICE Petition BellSouth Corporation (BellSouth) - filed Feb. 7, 1997 Comments Ameritech Corp. (Ameritech) - filed March 6, 1997 AT&T Corp. (AT&T) - filed March 6, 1997 Bell Atlantic - filed March 6, 1997 MCI Telecommunications Corporation (MCI) - filed March 6, 1997 Sprint Communications Co., L.P. (Sprint) - filed March 6, 1997 Reply Comments AT&T - filed March 17, 1997 Bell Atlantic - filed March 17, 1997 BellSouth - filed March 17, 1997 MCI - filed March 17, 1997 Southwestern Bell Telephone Company (SWBT) - filed March 17, 1997 U S West Communications, Inc. (U S West) - filed March 17, 1997 MARCH 25, 1997 PUBLIC NOTICE Petitions Bell Atlantic - filed March 6, 1997 Pacific Telesis Group (PacTel) - filed March 19, 1997 SWBT - filed March 17, 1997 U S West - filed March 14, 1997 Comments AT&T - filed April 21, 1997 MCI - filed April 21, 1997 Reply Comments Bell Atlantic - filed May 6, 1997 NYNEX Telephone Companies (NYNEX) - filed May 6, 1997 SBC Communications, Inc. (SWBT) - filed May 6, 1997 U S West - filed May 6, 1997 MAY 14, 1997 PUBLIC NOTICE Petitions Ameritech - filed May 13, 1997 NYNEX - filed May 6, 1997 Comments AT&T - filed June 4, 1997 MCI - filed June 4, 1997 SWBT - filed June 4, 1997 Reply Comments Ameritech - filed June 16, 1997 NYNEX - filed June 16, 1997 JULY 3, 1997 PUBLIC NOTICE Supplemental Showings Ameritech - filed June 30, 1997 Bell Atlantic - filed June 30, 1997 BellSouth - filed June 30, 1997 NYNEX - filed June 30, 1997 U S West - filed June 30, 1997 Comments AT&T - filed July 22, 1997 MCI - filed July 22, 1997 Reply Comments Bell Atlantic and NYNEX - filed Aug. 5, 1997 BellSouth - filed Aug. 5, 1997 U S West - filed Aug. 5, 1997 JULY 10, 1997 PUBLIC NOTICE Supplemental Showing SWBT, Pacific Bell, and Nevada Bell (collectively, SWBT) - filed July 10, 1997 Comments AT&T - filed July 28, 1997 MCI - filed July 28, 1997 Texas Advisory Commission on State Emergency Communications - filed July 28, 1997 Reply Comments SWBT - filed Aug. 11, 1997 Texas Advisory Commission on State Emergency Communications - filed Aug. 17, 1997