FCC Record, Volume 2, No. 1, Pages 1 to 409, January 5 - January 16, 1987 Page: 185

                                
Federal Communications Commission Record

switches can make the proper billing entries, accept the
response signal from the carrier and measure the duration
of the call. Absent such information, NYNEX contends, it
cannot be confident that the billing will avoid improper
Carrier Common Line charges and provide an accurate
and auditable record of traffic sensitive minutes. Id.
NYNEX also agrees, as an interim measure, that no
WALE charge will apply to customers served by equal
access WATS serving offices other than #1ESS and
#1AESS switches and not colocated with those switches.
Id. at 5. NYNEX also promises that if the provisioning
difficulties can be overcome without a generic software
change, the WALEs will be rehomed without charge to
the interexchange carrier (IXC). If NYNEX determines
that a generic change is required, the WALE charge will
be applicable "on a going forward basis" until the manufacturer
is able to provide the program modifications. At
that time, rehoming will be accomplished without charge
to the carrier. Id.
8. NYNEX also explains the problems associated with
providing bidirectional WATS access lines through Centrex.
NYNEX states that one way functionality in Centrex
operates through the use of simulated facility groups
which provide virtual WATS capacity, rather than
through physical WATS line connections. According to
NYNEX, the current software which enables virtual
WATS capacity cannot be made to function in a bidirectional
mode. It notes that the new access services can be
provided to Centrex customers on a physical line connection
basis apart from their Centrex operating systems. Id.
at n.2.
B. Discussion
9. We consider first NYNEX's request for clarification
that the May 20 Order requires the LECs to provide
WATS access lines only where "technically feasible."
Such an open-ended "clarification" would invite subjective
interpretation regarding service obligations and thus
effectively negate the intent of the May 20 Order. Moreover,
the Commission's recently adopted Order responding
to petitions for reconsideration of the May 20 Order '1
recognized the availability of limited waivers to afford
carriers sufficient time in which to resolve technical problems
associated with provision of unrestricted WATS access
lines. Id. at para. 25. We therefore conclude that
NYNEX's request for clarification should be denied.
10. NYNEX's petition, however, has presented a sufficient
showing of good faith efforts to achieve compliance
with the Bureau's Orders to justify a grant of its alternative
request for waiver." NYNEX has demonstrated
that it is unable to provide unrestricted WALs from all
end offices at this time. Further, NYNEX's plan to provide
service via WALEs is a reasonable solution to the
technical problems it has apparently encountered. IXCs
should not be unduly inconvenienced by the NYNEX
waiver since NYNEX has promised to provide the
WALEs without charge to converted offices other than
those with #1ESS and #1AESS switches while it determines
the nature and extent of the software changes
required. Moreover, NYNEX's decision to assess no
charge for those WALEs for the interim period should
encourage it to proceed with a rapid resolution of its
problems.12
11. We cannot conclude, however, that an indefinite
waiver is needed to afford NYNEX time in which to
determine whether generic software is available to provide

full service through switches other than the #1ESS and
#1AESS. As MCI notes, other companies have already
modified their DMS 100 and #5ESS switches to provide
unscreened and unbanded two-way WATS access lines.'3
Despite this evidence of carrier response capability, we
recognize that regions differ in their switching configurations.
We will therefore grant NYNEX a waiver until
February 28, 1987 for WATS access lines served by
switches other than the #IESS and #IAESS.
III. GTOC PETITION
A. Contentions
12. The GTE Telephone Operating Companies (GTOC)
request a waiver of the standard ordering interval until
January 5, 1987.14 GTOC alleges that it has identified a
number of serious technical, operational and administrative
"uncertainties" which must be resolved before it will
be able to furnish "modified" WATS access. Id. at 2.
13. In its original waiver petition, GTOC reported that
its billing system would require "major changes" in order
to be able to bill for WATS access. Id. In addition, GTOC
stated that technical changes must be implemented in its
switching systems and in the software and operating procedures
related to those systems. GTOC alleged that it
would not be possible to implement the necessary changes
by December 1 and that it was unable to provide any firm
commitment as to when "modified" WATS access will be
available. GTOC subsequently reported, however, that it
now expects to be able to provide WATS access as mandated
by the Bureau's Orders by January 1987. GTOC
Supplement at 1.
14. GTOC states that in order to bill for terminating
WATS calls two information elements must be available
in a single Automatic Message Accounting (AMA) record:
(1) one element which identifies the interexchange carrier
(IXC) over whose network the call was routed, and (2)
another element which identifies the call as a WATS call
(WATS call indicator) in order to permit deletion of the
CCL charge. Id. at 5. GTOC states that in a "number" of
its locations these two information elements occur in two
separate AMA records. Therefore, it claims, the operating
companies must develop data tables listing every terminating
WATS telephone number and its associated IXC code.
This data table will be used to affix the proper IXC code
to the AMA record which includes the WATS call indicator.
Id. The other AMA record (which contains the IXC
code but no WATS call indicator) will have all WATS
calls purged in order to avoid double billing for WATS
calls. Id. at 6.
15. GTOC also alleges that some of its switching systems
will require memory expansions using software derived
techniques in order to provide two-way WATS
access lines. Id. at 7. It reports that it is evaluating the use
of a hardware device that can provide two-way WATS
access as an alternative provisioning method.
16. GTOC's petition is opposed by ALC and MCI.'5
ALC asserts that GTOC's arguments are "merely a thinly
disguised attempt to avoid providing unrestricted WATS
access service." It charges that GTOC's request for waiver
is neither reasonable nor based upon technical or operational
considerations. ALC Response at 4. ALC contends
that while GTOC admits that its billing problem can be
corrected by implementing data tables, it is unclear why
GTOC has not implemented such "corrective action." Id.
at 5. Though GTOC has had over four months to imple185