Before the

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | * | CC Docket No. 96-61          |
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**ORDER**

**Adopted:** November 16, 2000 **Released:** November 17, 2000

By the Chief, Common Carrier Bureau:

# INTRODUCTION

1.  In 1996, the Commission adopted mandatory detariffing for the
    interstate, domestic, interexchange service of nondominant
    interexchange carriers (IXCs).[^1] After two Commission orders on
    reconsideration and judicial review in the D.C. Circuit, the
    Commission's detariffing rules took effect on May 1, 2000.[^2] In
    this Order, the Common Carrier Bureau, pursuant to a specific
    delegation of authority, resolves a number of issues relevant to the
    transition to a detariffed regime. Specifically, we:

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(1) Extend the deadline for detariffing mass-market consumer services
    from January 31, 2001 to April 30, 2001;

(2) Affirm that the deadline for detariffing contract-type services is
    January 31, 2001;

(3) Decline to permit IXCs to continue filing new or revised contract
    tariffs that bundle domestic and international service until such
    time as the Commission may have detariffed their international
    offerings;

(4) Permit the practice of filing a bundled domestic and international
    tariff with a disclaimer stating that the domestic portion of the
    document is for information purposes only;

(5) Require IXCs to be in full compliance with the public disclosure and
    Internet web-posting requirements at the time any service is
    detariffed, with respect to that service. With respect to new and
    revised contract services that have become effective since May 1,
    2000, IXCs must be in full compliance with the public disclosure and
    web-posting requirements within 30 days of the release of this
    Order;

(6) Require Internet web sites and public disclosure sites to be updated
    no later than 24 hours after the effective date of a change in the
    rates, terms, or conditions of a detariffed service;

(7) Clarify that the disclosure and web-posting requirements apply to
    contract services as well as to mass-market offerings;

(8) Specify the filing deadlines for the required annual certification
    of compliance with geographic rate averaging and rate integration
    requirements; and

(9) Clarify the application of tariff filing requirements during the
    transition period.

# DETARIFFING AND TRANSITION ISSUES

## Transition Period

2.  The Commission ordered all nondominant IXCs to cancel or permit the
    expiration of all tariffs for domestic, interstate, interexchange
    services within nine months of the effective date of the *Second
    Report and Order* and not to file any such tariffs thereafter.[^3]
    The Commission also required carriers to establish public disclosure
    locations and web sites to distribute information on the rates,
    terms, and conditions of the carrier's interstate, domestic,
    interexchange services during the transition period.[^4] In response
    to the D.C. Circuit's stay of the Commission's detariffing rules
    pending judicial review, the Commission delegated authority to the
    Bureau to determine the appropriate transition period and to address
    other transition issues when the detariffing rules became
    effective.[^5] The court subsequently upheld the detariffing
    rules[^6] and lifted its stay on May 1, 2000,[^7] at which time the
    rules became effective. Pursuant to its delegated authority, the
    Bureau then adopted a nine-month transition period with a deadline
    of January 31, 2001 for detariffing of IXC interstate, domestic,
    interexchange services.[^8] The Bureau also sought comment on
    potential modifications to the transition plan.[^9]

3.  In response to the Bureau's action, several parties recommend that
    the transition period be extended to allow the Commission an
    opportunity to complete a detariffing proceeding for international
    interexchange services, and that the transition periods for both the
    domestic and international interexchange services should
    coincide.[^10] On October 18, 2000, the Commission released a Notice
    of Proposed Rulemaking seeking comment on whether to detariff the
    international interexchange services of nondominant IXCs.[^11] The
    pleading cycle in that proceeding closes December 4, 2000.

4.  The Commission has engaged in a lengthy effort to accomplish
    detariffing of long-distance service in large part because it
    concluded that tariffing both prevents the operation of competitive
    markets and ultimately is harmful to the interests of consumers of
    such services. In particular, the Commission concluded that
    detariffing will enhance competition among providers of interstate,
    domestic, interexchange services; promote competitive market
    conditions; eliminate possible invocation of the filed rate doctrine
    by nondominant IXCs; and establish market conditions that more
    closely resemble an unregulated environment.[^12] Commenters assert,
    however, that the long-term benefits of detariffing may be
    overshadowed, in the short term, by the inconvenience and possible
    confusion of going through the detariffing process twice in the
    event the Commission decides to detariff international interexchange
    services. We find that, with respect to users of mass-market
    consumer services, we should extend briefly the deadline for
    detariffing such services in order to allow the Commission time to
    fully consider whether such an approach is appropriate. Accordingly,
    in order to allow the Commission to consider whether to establish a
    coordinated timetable for detariffing domestic and international
    consumer services, we extend the deadline for full detariffing of
    IXC interstate, domestic, interexchange services to April 30, 2001.
    For the contract-type services of domestic interexchange carriers,
    we retain the nine-month transition period that we announced in the
    *May 9 Notice*. We conclude that the likelihood of confusion with
    respect to business customers using such services is much less of a
    concern, and thus is clearly outweighed by the benefits of
    detariffing as soon as possible.

## Bundled Domestic and International Services

### Permissive Tariffing of Domestic Services

5.  In the *Second Report and Order*, the Commission recognized that a
    number of IXCs file bundled or "mixed" services tariffs, which
    include both interstate, domestic, interexchange services and
    international services. Because the order did not require
    detariffing of international services, it allows carriers to cancel
    portions of "mixed" services tariffs that are subject to detariffing
    by either: (1) cancelling the entire tariff and refiling a new
    tariff for only those services that remain subject to tariff filing
    requirements; or (2) issuing revised tariff pages cancelling the
    material in the tariffs that relate to services subject to
    forbearance. In order to minimize the costs of partitioning bundled
    offerings, the Commission also modified its rules to permit
    nondominant IXCs to cross reference detariffed interstate, domestic,
    interexchange service offerings in their tariffs for international
    services for purposes of calculating discounts and minimum revenue
    requirements.[^13] The Commission also determined in the *Second
    Report and Order* that it would not accept new contract tariffs or
    revisions to current contract tariffs for long-term service
    arrangements during the transition period but would accept new and
    revised tariffs for mass market services.

6.  A number of parties filed comments stating that the cancellation of
    the domestic portion of bundled contract tariffs will cause
    confusion for customers and administrative problems for the
    carriers.[^14] These parties recommend permissive tariffing[^15] of
    the domestic portion of the bundled contract tariffs to alleviate
    potential customer confusion during the transition period and while
    the Commission decides the issue of international detariffing,
    because customers expect to find service information in one document
    or location.[^16] Business Consumers, however, objects to these
    proposed modifications of the Commission's mandatory detariffing
    decision.[^17]

7.  We will not depart from the policy the Commission enunciated in the
    *Second Report and Order* that permissive tariffing of the domestic
    portion of bundled contract tariffs is not in the public interest
    because permissive tariffing would not eliminate the possible
    invocation of the "filed-rate" doctrine.[^18] Also, permissive
    tariffing would merely cause added delay to the process of
    implementing detariffing for all domestic services. Because we find
    that the requested actions are inconsistent with the Commission's
    goals outlined in the *Second Report and Order*, we decline to adopt
    these suggestions.

    **2. Disclaimers**

8.  In their comments, some IXCs suggest that the problems associated
    with a dual regime for domestic and international services would be
    minimized if carriers were allowed to file the domestic portion of a
    contract tariff for bundled domestic and international services with
    a disclaimer or banner that states that the domestic portion is
    included only for informational purposes.[^19] Several IXCs have
    been filing new and revised contract tariffs for bundled services
    with such banners.[^20] Several parties cite to the potential for
    customer confusion during both the transition period and during the
    period in which Commission considers detariffing of international
    services as a basis for allowing banners to be included in the
    bundled contract tariffs.[^21]

9.  The Commission has already revised its rules to allow carriers to
    cross-reference detariffed interstate, domestic interexchange
    service offerings in their tariffs for international services for
    the purpose of calculating discounts.[^22] Cross-referencing is
    technically sufficient to ensure that detariffing of domestic
    offerings does not deprive customers of the opportunity to negotiate
    discounts based on their total volume of calls. It is appropriate,
    however, to consider whether additional relief is necessary to
    reduce customer confusion that could arise during the period that
    international services are subject to tariff filing requirements and
    domestic services are subject to detariffing.

10. We will permit IXCs to file, as international service tariffs,
    tariff documents that describe bundled domestic and international
    contract service. Such filings must bear a banner or disclaimer in a
    conspicuous place, and will be permitted only during the transition
    period and until the Commission makes a final determination
    regarding detariffing of international services. This will help
    minimize customer confusion and reduce the administrative burden
    associated with separating the two services in existing contracts
    and contracts currently under negotiation. Bundled domestic and
    international contract tariffs filed that include a disclaimer or
    banner in a conspicuous place are consistent with the Commission's
    detariffing goals, and the domestic portions of such mixed service
    contract offerings will not be considered to be official tariffs
    filed pursuant to Section 203.

11. We direct carriers that choose to use the banner approach to
    include: (1) a statement that the domestic services portion of the
    tariff has been filed for informational purposes only and is not on
    file pursuant to the tariff filing requirements of 47 U.S.C. §
    203; (2) in the case of a revised tariff, a statement that the
    domestic services portion of the tariff was effectively cancelled as
    of the date the banner language was added to the tariff; and (3) a
    statement that the domestic services portions of contracts relating
    to bundled domestic and international contract services supersede
    the domestic information included in the bundled domestic and
    international contract tariffs on file with the Commission. The
    inclusion of the banner language does not affect carriers' ability
    to negotiate new contracts covering the domestic portions of their
    existing contracts.[^23] Customers are free to negotiate for
    domestic services that are not filed in bundled domestic and
    international tariffs. If a carrier has already separated the
    domestic portion from the international portion in a mixed service
    contract arrangement, the banner is not required on the
    international tariff filed with the Commission.

## Public Disclosure and Internet Information Requirements

### Timing of Compliance and Updates

12. The Commission determined in the *Second Report and Order*, and
    affirmed in the *Second Order on Reconsideration,* that it is in the
    public interest for nondominant IXCs to make available to the public
    information on current rates, terms, and conditions for all of their
    interstate, domestic, interexchange services in an easy to
    understand format, in a timely manner, and in at least one location
    during regular business hours.[^24] In addition, the Commission
    required IXCs that have established Internet websites to post that
    same information on-line in a timely and easily accessible manner,
    and to update the information regularly.[^25] The Commission
    determined that IXCs should also maintain price and service
    information regarding all of the interstate, domestic, interexchange
    service offerings to present to the Commission upon request.[^26]

13. The parties' comments include various recommended deadlines for
    compliance with the public disclosure and Internet web-posting
    requirement. Various parties recommend that carriers should comply
    with the requirement (1) immediately, regardless of whether services
    have been detariffed;[^27] (2) when a service offering is detariffed
    and no later than the expiration of the nine-month transition
    period;[^28] (3) at the end of the nine-month transition
    period;[^29] (4) 30 days after the expiration of the transition
    period;[^30] and (5) within 30 days of the Commission's final
    decision.[^31] One party recommends that revised information and
    updates should be posted within 24 hours of the effective date of
    the new or revised rates and terms, but no later than the next
    business day.[^32]

14. With respect to services that are permitted to remain under tariff
    during the transition period, we conclude that carriers should be
    allowed the full transition period in order to comply with the
    Internet and public disclosure requirements of the *Second Report
    and Order* and the *Second Order on Reconsideration*. We find that
    it is in the public interest to allow the carriers adequate time to
    establish public information locations and to modify their websites
    so as to provide accessible, comprehensive and comprehensible
    information about their service offerings to the public.

15. We also agree, however, with parties that argue that carriers should
    post information at public information sites and on Internet
    websites as soon as practicable after cancelling the tariff for a
    service. This timing is important so customers will have continuous
    access to information during the transition to a detariffed
    environment. We find, therefore, that carriers should not cancel
    tariffs pursuant to the *Second Report and Order* and the
    Commission's rules until they are able to post rate, term, and other
    service information regarding the services included in the cancelled
    tariffs at a public information location and, for those that
    maintain web sites, on the Internet. Consistent with section
    61.87(b) of the Commission's rules,[^33] when a carrier cancels its
    tariff, the carrier should indicate on the title page or the first
    page of the cancelled tariff the website address and the address of
    the public information site where the rates, terms, and conditions
    can be found.

16. Carriers that have already cancelled their tariffs must be in full
    compliance with section 42.10 of the Commission's rules within 30
    days from the release of this order.[^34] Likewise, carriers must be
    in full compliance with section 42.10 within 30 days of the release
    date of this order, with respect to all new and revised contract
    service arrangements that have become effective since May 1, 2000.

17. During the transition period, carriers cancelling their tariffs must
    post the rates, terms, and conditions of the cancelled tariff on
    their website within 24 hours after the cancellation takes effect.
    Both during and after the transition period, new or revised service
    offerings that are not permitted to be offered under tariff must be
    posted on the Internet websites within 24 hours after these
    offerings take effect.[^35] Public information sites must be updated
    within 5 days after a tariff cancellation or new or revised service
    offering becomes effective.

18. The Commission's rules established in the *Second Report and Order*
    also require nondominant IXCs to maintain price and service
    information regarding all of their detariffed interstate, domestic,
    interexchange service offerings;[^36] and to retain the information
    for a period of at least two years and six months after the carrier
    ceases to provide the service.[^37] Parties are reminded that these
    requirements are subject to the Commission's enforcement policies.

### Content of Public Information Disclosure

19. In the *Second Report and Order*, the Commission determined that the
    public information locations should contain information on a
    carrier's current rates, terms, and conditions for all of their
    interstate, domestic, interexchange services that is available to
    the public in an easy to understand format, in a timely manner, and
    in at least one location during regular business hours.[^38] In the
    *Order on Reconsideration*, the Commission eliminated the public
    disclosure requirement, but later reestablished the requirement in
    the *Second Order on Reconsideration*. The Commission did not
    prescribe specific content, or require that public disclosure of
    this information be made in any particular format or at any
    particular location, except that the information must be posted on
    the websites of those IXCs that currently maintain them over the
    Internet.[^39]

20. The commenters disagree as to whether the Commission requires the
    public disclosure of rates, terms and conditions for all services.
    WorldCom and SBC/SNET contend that only the standard, mass market
    offerings must be disclosed publicly and on the carriers' websites,
    and not individually negotiated contracts,[^40] while other parties
    argue that information on all services must be publicly
    disclosed.[^41] We reiterate the requirement explicitly stated in
    the *Second Reconsideration Order* that information on
    [all]{.underline} services must be publicly disclosed, including
    information on services offered through individually negotiated
    contracts.[^42]

21. Several parties also urge us to require carriers to include
    information that is "easy to understand," and in sufficient detail
    to allow consumers to make informed choices.[^43] We reemphasize
    that carriers should disclose enough information to allow consumers
    to make comparisons among the various services offered by the
    carrier and the services offered by other carriers. Carriers,
    however, are not required to include more information than is
    currently included in their tariffs. [^44]

22. Although we decline to mandate a specific format to which carriers
    must adhere with respect to publicly disclosed information, we
    nevertheless are cognizant of the need for carriers to provide this
    information in a format which is "easy to understand" by consumers
    in the business and especially the residential mass market. We
    recognize that this information is critical in order to allow
    consumers to make comparisons among the various services offered by
    the carrier and services offered by other carriers. We encourage
    carriers to work with the Commission's Consumer Information Bureau
    to develop appropriate formats for the required disclosures.

    **D. Carrier Certification**

23. The Commission recognized in the *Second Report and Order* that
    carriers operating in competitive markets would not necessarily
    maintain geographically averaged and integrated rates for
    interstate, domestic, interexchange services, absent a legal
    requirement that they do so.[^45] The Commission is committed to
    enforcing the rate averaging and rate integration requirements of
    the 1996 Act, and has put carriers on notice that they may be
    subject to civil and criminal penalties for violations of these
    requirements. Specifically, the Commission has directed the IXCs to
    file annual certifications stating that they are in compliance with
    their statutory geographic rate averaging and rate integration
    obligations.[^46] The certifications must be signed by an officer of
    the company under oath attesting to the company's compliance with
    the statutory geographic rate averaging and rate integration
    requirements of section 254(g) of the Act.[^47]

24. WorldCom requests that carriers be allowed to file their initial
    certifications at the end of the transition period after all tariffs
    have been cancelled.[^48] We find that this is a reasonable request
    that will reduce administrative burdens on affected carriers. We
    conclude, therefore, that IXCs are required to file initial
    certifications by May 1, 2001. Subsequently, the annual
    certifications should be filed on May 1 of each year.

    **E. Summary of Tariff Filing Requirements**

25. Several parties have requested clarification of the carriers' tariff
    filing requirements during the transition period. WorldCom requests
    clarification of the prohibition on filing individually negotiated
    service arrangements and of the status of mass market service
    offerings that contain term and volume commitments during the
    transition period.[^49] Several parties have requested clarification
    of the carriers' obligations with respect to contract tariffs that
    include both domestic and international services.[^50]

26. Pursuant to the *Second Report and Order*, carriers may file new
    tariffs and revisions to existing tariffs for mass market,
    interstate, domestic, interexchange services during the transition
    period, but must discontinue this practice at the end of the
    transition period.[^51] This includes mass-market services that
    contain volume and term requirements, but excludes contract tariffs
    such as AT&T's Tariff 12 options, MCI's special customer
    arrangements, and Sprint's custom network service arrangements.

27. Carriers are required to file tariffs for international services,
    including those in mixed service tariffs, during the transition
    period and until the Commission issues a final decision regarding
    detariffing of international services. Carriers may file the
    domestic portion of mixed service contract tariffs during the
    transition period and until a final decision regarding international
    detariffing, as long as the tariff includes the disclaimer or banner
    described in Section II. B.2 above. Carriers must have on file at
    the Commission an international tariff that reflects the
    international portion of a mixed services contract. Finally,
    carriers may file tariffs for dial-around 1+ services or "casual
    calling" services[^52] and for services provided to new customers
    until a written contract is executed, but for no longer than 45
    days.[^53] The casual calling services that may continue to be
    tariffed are those services for which the customer and carrier do
    not have an underlying contractual relationship because of the
    unique technological concerns with dial-around services that are not
    conducive to the establishment of a written contract.[^54]

# ORDERING CLAUSES

28. Accordingly, IT IS ORDERED that pursuant to the authority
    specifically delegated to the Common Carrier Bureau in the *Second
    Report and Order*, and under Sections 0.91 and 0.291 of the
    Commission's rules, 47 C.F.R. §§ 0.91 and 0.291, the deadline for
    detariffing mass-market consumer services IS EXTENDED from January
    31, 2001 to April 30, 2001.

29. IT IS FURTHER ORDERED that pursuant to the authority delegated under
    Sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R. §§ 0.91
    and 0.291, Econobill Corporation's Motion to Accept Late-Filed
    Pleading IS HEREBY GRANTED.

    FEDERAL COMMUNICATIONS COMMISSION

    Dorothy T. Attwood

> Chief, Common Carrier Bureau

**APPENDIX A**

**List of Parties**

**Comments**

Ad Hoc Telecommunications Users Committee (Business Consumers)

Association of Communications Enterprises (ASCENT)

AT&T Corporation (AT&T)

Bell Atlantic Long Distance Companies (Bell Atlantic)

Competitive Telecommunications Association (Comptel)

Econobill Corporation (Econobill)

General Services Administration (GSA)

GTE Service Corporation (GTE)

National Telephone Cooperative Association (NTCA)

Sprint Communications Company, L.P. (Sprint)

Telecommunications Management Information Systems Coalition (TMIS
Coalition)

WorldCom, Inc. (WorldCom)

**Reply Comments**

ASCENT

American Petroleum Institute (API)

AT&T

Bell Atlantic

Business Consumers

Cable & Wireless, Inc. (Cable & Wireless)

TMIS Coalition

Econobill

GSA

GTE

SNET America, Inc. and Southwestern Bell Telephone Company (SBC/SNET)

Sprint

WorldCom

[^1]: *Policy and Rules Concerning the Interstate, Interexchange
    Marketplace, Implementation of Section 245(g) of the Communications
    Act of 1934*, CC Docket No. 96-61, Second Report and Order, 11 FCC
    Rcd 20730 (1996) (*Second Report and Order*).

[^2]: *Policy and Rules Concerning the Interstate, Interexchange
    Marketplace, Implementation of Section 245(g) of the Communications
    Act of 1934*, CC Docket No. 96-61, Order on Reconsideration, 12 FCC
    15014 (1997)(*Reconsideration Order*); *Policy and Rules Concerning
    the Interstate, Interexchange Marketplace, Implementation of Section
    254(g) of the Communications Act* of 1934, CC Docket No. 96-61,
    Second Order on Reconsideration and Erratum, 14 FCC Rcd 6004
    (1999)(*Second Reconsideration Order*); *Domestic, Interexchange
    Carrier Detariffing Order Takes Effect*, CC Docket No. 96-61, Public
    Notice, DA 00-1028 (Com.Car.Bur. May 9, 2000)(*May 9 Notice*); *MCI
    WorldCom, Inc. v. FCC*, 209 F.3d 760 (D.C.Cir. 2000)(*MCI
    WorldCom*).

[^3]: *Second Report and Order*, 11 FCC Rcd at 20779, para. 89.

[^4]: *Second Report and Order*, 11 FCC Rcd at 20745-46, para. 25;
    *Second Reconsideration Order*, 14 FCC Rcd at 6015-16, para. 18.

[^5]: *See Reconsideration Order*, 12 FCC Rcd at 15044, para. 52.

[^6]: *See MCI WorldCom*.

[^7]: *MCI WorldCom, Inc. v. FCC*, No. 96-1459, Order (D.C.Cir. May 1,
    2000).

[^8]: *See May 9 Notice*.

[^9]: A list of parties filing comments is attached as Appendix A.

[^10]: AT&T at 5-8; Econobill Reply at 5; Sprint at 7.

[^11]: *2000 Biennial Regulatory Review, Policy and Rules Concerning the
    International, Interexchange Marketplace*, IB Docket No. 00-202,
    Notice of Proposed Rulemaking, FCC 00-367 (rel. Oct. 18, 2000).

[^12]: *Second Report and Order*, 11 FCC Rcd at 20760, para. 52.

[^13]: *Second Report and Order*, 11 FCC Rcd at 20780-83, paras. 91-98;
    *May 9 Notice* at 3.

[^14]: AT&T at 2-8; ASCENT at 2; Econobill at 1-2; Sprint at 2-5; Letter
    from Mike Del Casino, AT&T Regional Division Manager, to Magalie
    Roman Salas, Secretary, FCC, filed April 17, 2000.

[^15]: We note that the parties have used the terms "permissive
    detariffing" and "permissive tariffing" interchangeably to describe
    a regime in which carriers are permitted but not required to file
    tariffs for services subject to our detariffing order. The term
    "permissive tariffing" is used in that context for this order.

[^16]: AT&T at 2-8; ASCENT at 2; Econobill at 1-2; Sprint at 2-5. *See
    also* Econobill Reply at 3 (arguing that permissive tariffing should
    be allowed only where the carrier agrees to waive its rights to
    invoke the filed-rate doctrine). These parties also suggest that the
    Commission extend the transition period until such time as the
    Commission makes a decision regarding detariffing of the IXCs
    international services. The issue of the transition period is
    discussed at Section III.A above.

    We grant Econobill's Motion to Accept Late-Filed Pleading, filed on
    June 15, 2000 in order to develop the record in this proceeding to
    the fullest extent possible. No other parties are prejudiced by this
    action. *See also* *Motion for Extension of Time to File Comments
    Denied*, CC Docket No. 96-61, Public Notice, DA 00-1275
    (Comp.Pric.Div., June 14, 2000) (Division denied Econobill's Motion
    for Extension of Time to file reply comments).

[^17]: Business Consumers at 5.

[^18]: *Second Report and Order*, 11 FCC Rcd at 20765-66, paras. 60-62.

[^19]: AT&T at 4-5; Sprint at 4-5; *see also* Letter from Mike Del
    Casino, Regulatory Division Manager, AT&T, to Magalie Roman Salas,
    Secretary, FCC, filed May 17, 2000; Letter from Leonard J. Cali,
    Vice President of Federal Government Affairs, AT&T, to Magalie Roman
    Salas, Secretary, FCC, filed April 19, 2000.

[^20]: *See*, *e.g.*, AT&T Communications International Contract Tariff
    No. 13904, Issued May 26, 2000, Effective May 27, 2000 at Original
    Title Page ("This International Contract Tariff only applies to the
    AT&T international services specified herein and does not apply to
    any AT&T domestic interstate services. Pursuant to FCC Rule 61.20,
    all AT&T domestic interstate services are furnished under a separate
    non-tariffed arrangement. Accordingly, all references in this
    International Contract Tariff to terms, conditions and charges
    relating to domestic interstate services are to be construed for the
    sole purpose of determining the terms, conditions and charges
    applicable to AT&T international service.").

[^21]: AT&T at 4-5; Sprint at 4-5. *But see* Comptel at 3 (arguing that
    banners will not be able to prevent consumer confusion).

[^22]: *Second Report and Order*, 11 FCC Rcd at 20783, para. 99.

[^23]: *Second Report and Order*, 11 FCC Rcd at 20779-80, para. 90.

[^24]: *Second Report and Order*, 11 FCC Rcd at 20776-77, paras. 84-85;
    *Second Order on Reconsideration*, 14 FCC Rcd at 6015, para. 18.
    *See* 47 C.F.R. § 42.10(a).

[^25]: *Second Order on Reconsideration*, 14 FCC Rcd at 6015-16, para.
    18. *See* 47 C.F.R. § 42.10(b).

[^26]: *Second Report and Order*, 11 FCC Rcd at 20777-78, para. 87. The
    Commission determined that this information, including documents
    supporting the rates, terms, and conditions of the carriers'
    interstate, domestic, interexchange offerings, should be retained
    for a period of at least two years and six months following the date
    the carrier stops providing the services. The Commission also
    required carriers to keep the records in a manner that will allow
    the carrier to produce them within 10 business days of the
    Commission's request. *See* 47 C.F.R. § 42.11.

[^27]: Econobill at 2.

[^28]: ASCENT at 3; Bell Atlantic at 2; TMIS Coalition at 3-4; Sprint at
    6; WorldCom at 4-6. GSA favored compliance no later than five months
    into the transition period, *i.e.*, September 30, 2000. GSA Comments
    at 6.

[^29]: AT&T Reply at 4-5; GTE at 5.

[^30]: AT&T at 8; Cable & Wireless Reply at 1-2; SBC/SNET Reply at 3.

[^31]: NCTA at 7.

[^32]: TMIS Coalition at 4-5.

[^33]: 47 C.F.R. § 61.87(b).

[^34]: 47 C.F.R. § 42.10.

[^35]: We note that, consistent with section 255 of the
    Telecommunications Act of 1996, 47 U.S.C. § 255, and under the
    Commission's rules implementing section 255, carriers' websites are
    required to be accessible to and usable by individuals with
    disabilities. 47 C.F.R. §§ 6.5(b)(1), 6.11(a).

[^36]: 47 C.F.R. § 42.11(a).

[^37]: 47 C.F.R. § 42.11(b).

[^38]: *Second Report and Order*, 11 FCC Rcd at 20776, para. 84; *Second
    Order on Reconsideration*, 14 FCC Rcd at 6015, para. 18.

[^39]: See *Second Order on Reconsideration*, 14 FCC Rcd at 6015, para.
    18.

[^40]: WorldCom at 7-9; SBC/SNET Reply at 4.

[^41]: ASCENT Reply at 3-5; TMIS Coalition Reply at 4.

[^42]: *Second Reconsideration Order*, 14 FCC Rcd at 6013-15, n.60,
    para. 16. *See also Second Report and Order*, 11 FCC Rcd at
    20776-77, paras. 84-86.

[^43]: TMIS Coalition at 5; Econobill Reply at 6-7; Letter from Thomas
    Crowe, Attorney, Econobill, to Magalie Roman Salas, Secretary, FCC,
    filed June 6, 2000.

[^44]: *Second Report and Order*, 11 FCC Rcd at 20776, para. 84.

[^45]: *Second Report and Order*, 11 FCC Rcd at 20776, para. 84.

[^46]: *Second Report and Order*, 11 FCC Rcd at 20775, para. 83. Rule
    64.1900 requires nondominant IXCs to file certifications on an
    annual basis that they are providing interexchange
    telecommunications services in compliance with the geographic rate
    averaging and rate integration obligations pursuant to section
    254(g) of the 1996 Act. 47 C.F.R. § 64.1900. Section 254(g) requires
    a provider of interexchange telecommunications services to provide
    these services to subscribers in rural and high cost areas at rates
    no higher than the rates charged to its subscribers in urban areas,
    and to provide these services to subscribers in each State at rates
    no higher than the rates charged to its subscribers in any other
    State. 47 U.S.C. § 254(g).

[^47]: 47 C.F.R. § 64.1900(a) and (b). *See* *Implementation of Section
    254(g) of the Communications Act of 1934*, 11 FCC Rcd 9564 (1996)
    (*Geographic Rate Averaging Order*).

[^48]: WorldCom at 9-11.

[^49]: WorldCom at 11-15.

[^50]: Business Consumers at 4-6. *See also* Letter from Mike Del
    Casino, Regional Division Manager, AT&T, to Magalie Roman Salas,
    Secretary, FCC, filed April 11, 2000; Letter from Mike Del Casino,
    Vice President Federal Government Affairs, AT&T, to Magalie Roman
    Salas, Secretary, FCC, filed April 19, 2000; Letter from Michael
    Fingerhut, General Attorney, Sprint, to Magalie Roman Salas,
    Secretary, FCC, filed May 22, 2000.

[^51]: *Second Report and Order*, 11 FCC Rcd at 20780, para. 90.

[^52]: Dial around 1+ calls are calls made by accessing the IXC through
    the IXC's carrier access code (CAC) in the absence of a
    presubscription agreement with the IXC. A CAC is a five or seven
    digit access code that enables callers to reach any carrier,
    presubscribed or otherwise, from any telephone. 47 C.F.R. § 61.19
    (b).

[^53]: 47 C.F.R. § 61.19(c).

[^54]: *Reconsideration Order*, 12 FCC Rcd at 15036, para. 36.