BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D. C. 20554
In the Matter of
)
)
Pacific Bell's, Nevada Bell's, and
)
Southwestern Bell Telephone Company's
)
Comparably Efficient Interconnection Plan
)
For Voice Store And Forward Services,
)
Including Voice Mail/Messaging Services
)
___________________________________________)
INFORMATIONAL AMENDMENT
TO MERGE PACIFIC BELL'S, NEVADA BELL'S, AND
SOUTHWESTERN BELL TELEPHONE COMPANY'S
COMPARABLY EFFICIENT INTERCONNECTION ("CEI") PLANS
FOR VOICE MAIL/MESSAGING SERVICES INTO THEIR CEI PLAN FOR
VOICE STORE AND FORWARD SERVICES AND TO
DESCRIBE EXAMPLES OF COMBINED APPLICATIONS
I.
THIS AMENDMENT COMBINES PREVIOUSLY APPROVED CEI PLANS AND
AMENDMENTS AND PROVIDES EXAMPLES OF COMBINED APPLICATIONS
OF ENHANCED SERVICES
Pacific Bell, Nevada Bell, and Southwestern Bell Telephone Company
("SWBT") (referred to collectively as "SBC"1) hereby post on the Internet this
Informational Amendment to merge Pacific Bell's, Nevada Bell's, and SWBT's
Comparably Efficient Interconnection ("CEI") Plans for Voice Mail and Voice Messaging
Services into their Plan for Voice Store and Forward ("VS&F") Services and to describe
1
This Amendment does not include Southern New England Telephone ("SNET")
because SNET is not a Bell Operating Company ("BOC") and, thus, is not subject to the
CEI plan requirements.
examples of combined applications that use voice mail together with other VS&F
functionality. This posting is made consistent with the Commission's Report and Order
released March 10, 1999 in the Computer III Further Remand Proceedings (CEI Plan
Order).2 In the CEI Plan Order, the Commission replaced the requirements to file and
obtain pre-approval of CEI plans or amendments to CEI plans for new or revised
enhanced services with new requirements that permit the Bell Operating Companies
(BOCs) to offer and provide new or revised enhanced services upon (1) posting of CEI
plans and amendments on their publicly accessible Internet sites and (2) notifying the
Common Carrier Bureau of such posting.3
This Amendment merges previously approved CEI plans and
amendments in order to bring all of Pacific Bell's, Nevada Bell's, and SWBT's VS&F
Services together under one plan. In 1988, the Bureau approved both (1) the Pacific
Bell & Nevada Bell Voice Mail Plan and (2) the SWBT Voice Messaging Plan. 4 In
1989, the Bureau approved Pacific Bell's and Nevada Bell's CEI Plan to offer VS&F
services.5 Finally, on February 8, 1999, the Bureau orally approved a Minor
2
Computer III Further Remand Proceedings: Bell Operating Company
Provision of Enhanced Services, 1998 Biennial Regulatory Review – Review of
Computer III and ONA Safeguards and Requirements, CC Docket Nos. 95-20, 98-10,
Report and Order, Released March 10, 1999 (CEI Plan Order).
3 Id. at paras. 4, 12, and 20.
4 Pacific Bell and Nevada Bell Plan for the Provision of Voice Mail Services,
conditionally approved 3 FCC Rcd1095 (1989), finally approved 3 FCC Rcd 3552
(1989); amendment approved 7 FCC Rcd 3487 (1992); amendments approved in Bell
Operating Companies Joint Petition for Waiver of Computer II Rules, Order, 10 FCC
Rcd 13758 (1995) ("BOC CEI Approval Order"). SWBT CEI Plan for Voice Messaging
Services, approved 3 FCC Rcd 6912 (1988); amendment approved BOC CEI Approval
Order.
5 Pacific Bell and Nevada Bell Plan for the Provision of Comparably Efficient
Interconnection for Voice Store and Forward Services, approved, Memorandum
Opinion and Order, 4 FCC Rcd 4491 (1989) ("Pacific Bell and Nevada Bell VS&F CEI
Plan Approval Order"). Amendments approved BOC CEI Approval Order.
2
Amendment To Add SWBT to Pacific Bell's and Nevada Bell's CEI Plan for VS&F
Services.
This merger of CEI plans and amendments is the result of the merger of
Pacific Bell and Nevada Bell with SWBT in SBC Communications Inc. and of the
technological convergence of broad VS&F capabilities with traditional voice mail
services.6 This amendment describes examples of combined applications resulting
from this technological convergence. This convergence is similar to that which the
Bureau addressed in connection with approving identical amendments to Pacific Bell's
Electronic Messaging and Videotex Gateway CEI Plans. The Bureau agreed with
Pacific Bell that "videotex and electronic messaging services have converged to such a
degree in recent years that there are no longer any clear distinctions between
them…."7 Similar convergence of voice mail and broader VS&F functionality has
occurred. Moreover, some applications of the interactive voice response (IVR)
functionality, which is at the heart of VS&F services, entail technological convergence of
VS&F with electronic messaging, videotex, and facsimile store and forward, as shown
in examples described below.
6
Under their approved CEI Plans, Pacific Bell, Nevada Bell, and SWBT are
allowed to offer VS&F on an integrated basis, or partially integrated via subsidiaries or
via other affiliates of Pacific Bell, Nevada Bell, SWBT or SBC Communications Inc. In
this CEI Plan, designations such as Pacific Bell's, Nevada Bell's, or SWBT's enhanced
service operation include these various options. For marketing purposes, Pacific Bell,
Nevada Bell, and SWBT may adopt various titles for VS&F services. All
representations made herein for such services will apply fully regardless of the titles
used.
7 BOC CEI Approval Order at para. 66. The Bureau stated, "The Bureau has
previously held that a carrier need not file separate CEI plans for enhanced services
that are provided as a package." Id. at n.158.
3
Combined Applications
In SBC's past VS&F plans and amendments, SBC has pointed out that
the variety of VS&F applications is potentially unlimited. 8 SBC has identified voice mail
(also referred to as voice messaging) as one VS&F application. 9 In past plans and
amendments, SBC also has explained that some of its VS&F applications allow end
users to acquire information from, and deposit information with, local, regional, national,
and international sources via the existing access network.10 Moreover, SBC has
explained that VS&F can be used to direct end users' calls to the proper sales
representatives or other people with whom the end users can then talk directly over the
telephone in order to meet their needs.11 Pacific Bell, Nevada Bell, and SWBT have
decided to merge their Voice Mail plans into their VS&F plan because voice mail
applications are expanding to include broader VS&F functionality.
8
Minor Amendment to Add SWBT to Pacific Bell's and Nevada Bell's VS&F CEI
Plan, filed February 3, 1999, p. 7 ("February 3, 1999 Minor Amendment").
9 Pacific Bell and Nevada Bell VS&F CEI Plan, filed November 18, 1988, p. 3,
("VS&F CEI Plan").
10 February 3, 1999 Minor Amendment, p. 7.
11 VS&F CEI Plan, pp. 9-10. February 3, 1999 Minor Amendment, p. 13. For
example, an end-user dials the number to a sales catalog company. The number is
routed to the IVR system. The IVR system plays an announcement asking the
end-user to enter the catalog number of the item wanted. The digits are collected and
a database is checked for the item's availability. An announcement is played telling
the end-user that the item is unavailable and that the call will be transferred to a sales
agent for further assistance. From the IVR, the end user is interconnected via a
communication link to the host system which contains information on sales
representatives. From the host, the end user is interconnected via network service or
a PBX to the proper sales representative. The IVR system then forwards the call to the
sales agent. Similar functionality can be used by a department store that wants to
direct callers to the proper extensions.
4
An example of an application that combines voice mail and broader VS&F
functionality is a unified information and call management system. This broader
functionality allows end user customers to reach out beyond their voice mail boxes,
which store their messages, for interaction with other stored information sources. This
broader functionality also allows end user customers to more efficiently move back into
the public switched telephone network ("PSTN") to complete live calls, and to then
move back into their voice mail boxes and other information sources (e.g., "message
direct," or "live reply" type applications). In this manner, end user customers can better
manage their acquisition and provision of information together with management of
their stored and live telephone calls.
The unified information and call management system and related services
combine features such as call answering, voice mail, email, fax mailbox, and personal
website on the net, and interact with network services via voice activated dialing,
conference call bridging, find me service, and management services (e.g., electronic
phonebook on the web, contact lists, on-line billing information, call history, etc.). The
functionality needed to provide these features is dedicated to the VS&F enhanced
service, and equipment providing the functionality may be purchased from vendors by
any ESP for the same uses. All network interconnections are via standard interfaces
available to all customers with tariffed network services. This application will be
available in a standard version, which includes all the voice mail-related call answering
capabilities, and in an advanced version that incorporates the voice mail-related call
answering capabilities together with store and forward capabilities that use IVR
functionality to combine VS&F with email (including notification and review) and fax
mailbox (including review, forwarding, and answering). For instance, the customer can
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give voice commands that direct the sending or audio playing of email or facsimile
messages. In addition, some features of this application may be made available
separately from the overall package and may be dedicated to particular enhanced
applications. For instance, "message direct," or "live reply" types of applications may
be combined with, and dedicated to, voice mail service. As another example, IVR
equipment and functionality may be dedicated to voice mail service to allow end user
customers to deposit information concerning their choice of number of ring cycles
before calls enter voice mail. SBC's voice mail operation would then transmit that
information to SWBT, Pacific Bell, or Nevada Bell in the same ways that are available to
all ESPs (e.g., call on the phone). Some applications may include protocol
conversions.
These services combine and expand functionalities SBC has described in
previous, approved CEI plans and amendments. SBC has explained in detail how
VS&F services enable end users to interact with recorded announcements in order to,
among other things, (1) acquire information via audio, email, or fax applications,
including text to speech and voice recognition applications, from databases owned by
customers of VS&F service, (2) deposit information via these same means into
databases owned by customers of VS&F service,12 and (3) send messages over the
12
At this time, SBC's IVR will simply store the deposited information for retrieval
by, or forwarding to, the customers of SBC's VS&F service. SBC's IVR will not
manipulate the information deposited by the end user. To the extent that we may
provide electronic publishing services in the future, SWBT will meet any electronic
publishing requirements that still exist at that time.
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PSTN to third parties who are not subscribers to SBC's VS&F or Voice Messaging
services.13
II.
THIS AMENDMENT LEAVES IN PLACE PACIFIC BELL'S, NEVADA BELL'S,
AND SWBT'S FULL COMPLIANCE WITH COMPUTER INQUIRY III CEI PLAN
REQUIREMENTS
This amendment does not change the basic network services that Pacific
Bell, Nevada Bell, or SWBT described in the previously approved VS&F or Voice
Mail/Messaging CEI Plans as basic services that their enhanced services operations
may use to provide enhanced services. All those basic services will continue to be
provided under tariff to all customers, including all ESPs, at the same rates, terms, and
conditions as to Pacific Bell's, Nevada Bell's, and SWBT's enhanced service
operations.14 Tariffed features are continually expanding that help end users obtain
increased benefits from the enhanced services, including features that make voice mail
more similar to answering machines in certain respects. For instance, visual message
waiting indicator for Centrex or non-Centrex lines may be ordered under Pacific Bell's
tariffs by any ESP for use on end users' lines.
Accordingly, this amendment does not affect SBC's compliance with the
CEI requirements which the Commission established in Phase I of Computer Inquiry
13
February 3, 1999 Minor Amendment, p. 8.
The Commission has stated that "a carrier is permitted to offer unregulated,
enhanced services if it files a CEI plan demonstrating the underlying regulated basic
services are available on an equivalent basis to unaffiliated enhanced services
providers (ESPs)." This Amendment does not affect the underlying basic network
services used to provide the enhanced services. The basic services continue to be
available under tariffs, at the same rates, terms, and conditions, to unaffiliated ESPs as
to Pacific Bell's, Nevada Bell's, and SWBT's enhanced service operations.
14
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III.15 The Commission approved SBC's compliance with Computer Inquiry III and other
related non-structural safeguards (e.g., accounting safeguards) in the CEI plans and
amendments now being merged, and SBC's compliance continues.
Amendment of Section 64.702 of the Commission’s Rules and Regulations
("Computer Inquiry III"), Report and Order, 104 FCC 2d 958 (1986) (Phase I Order) at
paras. 147, 154-166, recon., 2 FCC Rcd 3035 (1987) (Phase I Reconsideration Order),
further recon., 3 FCC Rcd 1135 (1988) (Phase I Further Reconsideration Order),
second further recon., 4 FCC Rcd 5927 (1989) (Phase I Second Further
Reconsideration, Phase I Order and Phase I Reconsideration Order vacated, California
v. FCC, 905 F.2d 1217 (9th Cir. 1990); Phase II, 2 FCC Rcd 3072 (1987) (Phase II
Order), recon., 3 FCC Rcd 1150 (1988) (Phase II Reconsideration Order), further
recon., 4 FCC Rcd 5927 (1988) (Phase II Further Reconsideration Order), Phase II
Order vacated, California v. FCC, 905 F.2d 1217 (9th Cir. 1990); Computer III Remand
Proceeding, 5 FCC Rcd 7719 (1990) (ONA Remand Order), recon., 7 FCC Rcd 909
(1992), pets. for review denied, California v. FCC, 4 F.3d 1505 (9th Cir. 1993);
Computer III Remand Proceedings: Bell Operating Company Safeguards and Tier 1
Local Exchange Company Safeguards, 6 FCC Rcd 7571 (1991) (BOC Safeguards
Order); BOC Safeguards Order vacated in part, California v. FCC, Nos. 92-70083,
92-70186, 92-70217, 92-70261 (9th Cir. Oct. 8, 1994).
15
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III.
CONCLUSION
This Informational Amendment merges SBC's previously approved Voice
Mail/Messaging and VS&F CEI plans and Amendments and describes examples of
combined applications. This Informational Amendment retains SBC's full compliance
with the Commission's Computer III CEI requirements.
Respectfully submitted,
Pacific Bell, Nevada Bell, and
Southwestern Bell Telephone Company
By___/s/ Jeffrey B. Thomas________________
Robert M. Lynch
Roger Toppins
Michael J. Zpevak
Jeffrey B. Thomas
Attorneys for
Pacific Bell, Nevada Bell, and
Southwestern Bell Telephone Company
One Bell Plaza
208 South Akard Street
Room 3043
Dallas, Texas 75202
(214) 464-4490
April 22, 1999
9