DA 95-1800 Federal Communications Commission Record 10 FCC Red No. 20 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Ameritech Operating Companies Transmittal No. 892 Tariff F.C.C. No. 2 ORDER Adopted: August 14,1995; Released: August 15,1995 By the Chief, Tariff Division, Common Carrier Bureau: 1. On June 20, 1995, Ameritech Operating Companies (Ameritech) filed Transmittal No. 892 to introduce an optional feature. Carrier Identification Parameter (CIP), as part of the services offered under its Tariff F.C.C. No. 2. Transmittal No. 892 is scheduled to become effective on August 18, 1995. 2. Ameritech explains that in the signalling system seven (SS7) environment, the Carrier Identification Code (CIC) currently is generated at Ameritech end offices and trans mitted to the Ameritech access tandem or to an alternate provider's access tandem. The parameter containing the CIC code is subsequently stripped at the access tandem and the CIC is not sent to the customer. Ameritech explains that, by contrast, CIP will allow the transmission .of the CIC to the customer. CIP will be deployed at both end offices and tandem offices. Ameritech states that CIP will facilitate the growth of competition in tandem switching services and will enable interexchange carriers (IXCs) to meet branding needs and offer new services, such as cus tomized routing, traffic analysis, and traffic prioritization.1 3. Ameritech proposes recurring and nonrecurring charges for CIP on a per trunk group basis. Ameritech states that the recurring charges recover the costs associated with the purchase and the loading of the right-to-use soft ware to equip end offices and tandem offices with the CIP functionality. Ameritech states that the nonrecurring charges recover the provisioning costs associated with equipping the customer's trunk groups with the option, as well as the costs required to modify Ameritech's billing system.2 4. Ameritech claims that the provision of CIP as an optional feature is a service authorized by the Commis sion's Tandem Switching Order.3 Ameritech states that the Tandem Switching Order requires it to provide signaling information from equal access end offices to third parties. Ameritech claims that this filing is consistent with the Commission's affirmation that broader interconnection re quirements to facilitate access competition are in the pub lic interest.4 5. On July 5, 1995, MCI Telecommunications Corporation (MCI) filed a petition to suspend and investi gate Ameritech Transmittal No. 892. MCI argues that CIP should be a non-rated feature because it is a network upgrade -- similar to SS7.5 MCI states that in the 800 Access Order, the Commission decided that SS7 represents a gen eral network upgrade, the core costs of which should be borne by all network users.6 MCI then asserts that Ameritech should not be able to charge for CIP because it is an SS7-based feature.7 MCI also argues that there is no difference between CIP and the Commission's recent de cision to require carriers to pass Calling Party Number (CPN) information to interconnecting carriers free of charge.8 Assuming arguendo that it is reasonable to charge for CIP, says MCI, CIP should be available on a trunk- by-trunk, as opposed to a per trunk group, basis to allow MCI to buy only the amount of CIP capacity needed. MCI claims that such unbundled pricing is in the public inter est." 6. On July 5, 1995, Allnet Communication Services, Inc. (Allnet) filed a petition to reject Ameritech Transmittal No. 892. Allnet claims that in the recent Caller ID Order, the Commission decided that CPN should be passed from carrier to carrier at no charge because it is an intrinsic part of SS7 call set up and because the cost for transporting the CPN parameter for carriers equipped with call set up is de minimus. 10 Allnet also claims that in the Caller ID Order, the Commission found that installation of SS7 and related features is a general network upgrade and the cost of this upgrade should be borne by all network users. Allnet then argues that, just like CPN, CIP is an intrinsic part of the SS7 call set up process and no additional costs are required to forward CIP to the IXC. Allnet therefore reasons that, consistent with the Commission's previous findings, CIP should be provided at no charge." 7. On July 17, 1995, Ameritech filed a reply to MCI's and Allnet's petitions. Ameritech argues that MCI and Allnet cite "completely out of context" Commission state ments on the topic of SS7 costs being treated as a "general network upgrade." Ameritech notes that in the same pas sage, the Commission states that it will "treat as the costs of providing data base access service only those costs that are 1 Ameritech Transmittal No. 892. Description and Justification (D&J) at 1. 2 Id. at 2. 3 Id. at 1, citing Expanded Interconnection with Local Tele phone Company Facilities, Transport Phase 11, Third Report and Order, CC Docket No. 91-141, 9 FCC Red. 2718 (l994)(T<zndem Switching Order). * Ameritech D&J at 2. 5 MCI Petition at 2. 6 Id. at 3-4, citing Provision of Access for 800 Service, Report and Order, CC Docket No. 86-10, 4 FCC Red. 2824 (1989) (800 Access Order). 7 MCI Petition at 2-4. 8 Id. at 4, citing Rules and Policies Regarding Calling Number Identification Service - Caller ID, Memorandum Opinion and Order on Reconsideration, Second Report and Order and Third Notice of Proposed Rulemaking, CC Docket No. 91-281, FCC 95-187 (rel. May 5, 1995) (Caller ID Order). 9 MCI Petition at 5. 10 Allnet Petition at 2-3, citing Caller ID Order, FCC 95-187 (para. 33). n Allnet Petition at 3-4, citing Caller ID Order, FCC 95-187 (para. 34) . 10586 io FCC Red NO. 20 Federal Communications Commission Record DA 95-isoo incurred specifically for the implementation and operation of the data base system." 12 Ameritech then argues that in the instant transmittal, the recurring charges cover only the incremental costs associated with the purchase and loading of the right-to-use software to equip end offices and tandem offices with the CIP functionality itself. Ameritech argues (hat no portion of the cost recovery associated with this rate element can be considered a "general network up grade;" rather, this element recovers only those costs which are incurred specifically for the implementation and opera tion of the CIP functionality. 13 Finally, Ameritech explains that it adopted a per trunk group basis for the rate struc ture of CIP because it is the industry standard for this feature. 14 8. The Tariff Division has reviewed Ameritech's Trans mittal No. 892 and the related pleadings. We conclude that no compelling argument has been presented that this tariff is patently unlawful so as to warrant rejection or that it raises substantial questions of lawfulness that warrant inves tigation at this time. 9. Accordingly, IT IS ORDERED that the petition to suspend and investigate Ameritech Tariff F.C.C. No. 2. Transmittal No. 892, filed by MCI Telecommunications Corporation, IS DENIED. 10. IT IS FURTHER ORDERED that the petition to reject Ameritech Tariff F.C.C. No. 2, Transmittal No. 892. filed by Allnet Communication Services, Inc., IS DENIED. FEDERAL COMMUNICATIONS COMMISSION Geraldine A. Matise Chief, Tariff Division Common Carrier Bureau 12 Ameritech Reply at 2, citing 800 Access Order, 4 FCC Red. at 2832. 13 Ameritech Reply at 2. 14 Id. at 3, citing Bell Communications Research, Inc. Tech nical Publication No. TR-TSV-000905. 10587