Delaware PSC Hearing on ISDN Pricing

Volume 2 31

1 PUBLIC SERVICE COMMISSION

2 STATE OF DELAWARE

3 In the matter of the tariff :

filing of Bell Atlantic - : P.S.C. Docket

4 Delaware, Inc. for the : No. 95-014T

implementation of residence :

5 ISDN service :

6

The above matter came on for public hearing

7 on Tuesday, January 16, 1996, at 7:00 p.m. in the

Public Service Commission Hearing Room, 1560 South

8 Du Pont Highway, Dover, Delaware.

9

BEFORE:

10

G. ARTHUR PADMORE, The Hearing Examiner

11

12 APPEARANCES:

13 On behalf of Public Service Commission

Staff:

14 BRUCE BURCAT, Executive Director

JOHN CITROLO, Public Utilities Analyst

15

16 On behalf of Bell Atlantic - Delaware:

17 LINDA GAGHAN

GINNY LEONETTI

18

19 On behalf of Office of the Public Advocate:

20 PATRICIA STOWELL

21

22

23 WILCOX & FETZER

1330 King Street - Wilmington, Delaware 19801

24 (302) 655-0477

32

1 THE HEARING EXAMINER: For the

record,

2 we'll open the hearing at 7:00 as advertised. Let the

3 record reflect that Bell Atlantic is represented by

4 Linda Gaghan, product manager, Ginny Leonetti, an

5 official of the Company, the Public Advocate and

6 John Citrolo of the Public Service Commission Staff.

7 We will recess a few minutes. We understand that

some

8 customers are on their way.

9 (A brief recess was taken.)

10 THE HEARING EXAMINER: Good

evening,

11 ladies and gentlemen. This is a public comment

session

12 in Docket No. 95-014T. I've been appointed the

Hearing

13 Examiner in these proceedings and a part of my

14 responsibility is to summarize the remarks made

here

15 tonight by members of the public who have

appeared to

16 include in my official report to the Commission.

17 Neither I nor anyone from the Commission will be

making

18 any decisions tonight. We're here just to hear what

19 the members of the public have to say about the

filing

20 that Bell Atlantic - Delaware has made for the

21 provision of residential IntelliLinQ BRI Service. This

22 is the service that's come known to be residence

ISDN

23 service.

24 The Commission has determined to

conduct

33

1 public evidentiary hearings to investigate the justness

2 and reasonableness of the proposed residence ISDN

3 rates. And as I said earlier, we're conducting this

4 public comment session to take public input about

the

5 service so that the Commission may consider these

6 comments when it makes a final decision about

whether

7 or not the rates are appropriate.

8 Representatives from the Commission

here,

9 the executive director, Bruce Burcat and John Citrolo,

10 a utilities analyst. The Public Advocate is here,

11 Patricia Stowell. And also the representatives from

12 Bell Atlantic - Delaware, Linda Gaghan and

13 Ginny Leonetti.

14 Notice has been published of this

15 proceeding and we have a speaker's list which

consists

16 of two names: Paul Gumerman. Am I pronouncing

this

17 correctly?

18 MR. GUMERMAN: Yes.

19 THE HEARING EXAMINER: And

20 Michael Lecuyer.

21 MR. GUMERMAN: I didn't realize we

were

22 on the speaker's list already.

23 THE HEARING EXAMINER: Well, I

assume you

24 have some comment you'd like to make.

34

1 MR. GUMERMAN: I'd like to get some

2 information from the Bell Atlantic representatives and

3 see what the filing was about. This was something

that

4 we found out about just earlier this afternoon.

5 THE HEARING EXAMINER: Okay.

Well,

6 before we begin getting to the comment session, I

just

7 wanted to lay down some ground rules by which

we're

8 going to operate. And since we have only two

speakers,

9 two potential speakers, I'm going to recognize them

in

10 the order that their names appear on the list. That

11 shouldn't be too difficult to do.

12 When you come forward, state your

name

13 and address for the court reporter. And as you see,

we

14 do have a court reporter, so I'm only going to let

one

15 person speak at a time. Since the comments will

become

16 a part of the case record for the Commission, it's

17 essential that your comments remain relevant to the

18 subject matter that we're here to discuss, which is

19 residence ISDN service.

20 So before we begin, I'll let the

21 representative from Bell Atlantic give a brief

overview

22 of the proposed service; after which we'll start with

23 Mr. Gumerman for his comments or questions.

24 MS. GAGHAN: Thank you. Good

evening,

35

1 ladies and gentlemen. As was mentioned, my name

is

2 Linda Gaghan. I'm the product and marketing

manager

3 for residential ISDN for Bell Atlantic across the whole

4 region as well as in Delaware. I'm here this evening

5 to answer questions about the service and, for those

of

6 you who are interested in knowing more about it, to

7 provide an overview of what the service is and how

it

8 might be used.

9 To start, ISDN service is basically like

10 getting two phone lines over a single pair of wires

11 into your home, the same kind of wires that are

going

12 into your home today. It can be used to make

normal

13 voice or fax calls, but more importantly, it can be

14 used to send and receive information much faster

over

15 your computer. I assume many of you probably are

using

16 on-line services today. Then you probably are using

a

17 modem to access those services. But with ISDN,

you

18 would be able to send and receive information to

these

19 services up to eight times faster if you were using a

20 14.4 modem or four times faster if you were using a

21 28.8 modem.

22 I brought some handouts with me that

23 provide information about residential ISDN as well

as a

24 few real life case examples of when we've done

speed

36

1 comparisons of using ISDN versus a 28.8 modem,

which is

2 the fastest analogue modem today. And as you'll see,

3 the more graphical or video intensive the

information,

4 the more dramatic the benefit of residential ISDN.

5 One example that's in the handouts is

6 that we access the Cable News Network InterNet site,

7 the CNN InterNet site, to retrieve a story, an audio

8 clip and a news clip. I mean a video clip. And with

9 ISDN, it took less than three minutes to download

that

10 information. But with the 28.8 modem, the fastest

11 analogue modem, it took almost 11-and-a-half

minutes.

12 So the speed and performance benefit of ISDN is

quite

13 considerable. And the differences would even be

14 greater if you were using a slower speed modem

like a

15 14.4 which many common on-line service users do

have at

16 home.

17 We believe this particular benefit, the

18 speed benefit of ISDN, will be particularly appealing

19 to the growing base of home InterNet and on-line

20 services users which are already in the tens of

21 millions across the country and to the 64 million

22 individuals who do some sort of work from home.

23 In the State of Delaware for residential

24 ISDN, we currently have 13 confirmed orders for

the

37

1 service and are following up on 28 phone inquiries

and

2 over 30 InterNet inquiries we've gotten since

November

3 13th. So already the service is taking off in the

4 state.

5 As our initial entry into the market

with

6 residential ISDN, we have positioned the service so

7 that the costs are charged back to only those people

8 who use the service and that individuals who use the

9 service pay only for what they use, no more and no

10 less. And as we gather information on customer

usage

11 patterns and their overall requirements for different

12 applications, we do plan on introducing other

pricing

13 options that will meet those different customer

needs.

14 This is something we are working on today and

plan to

15 do by no later than the end of this year and

hopefully

16 much sooner. But to let you know, the pricing

17 proposal, which I'll quickly go over, is our initial

18 entry into the market based on the market

information

19 we have.

20 For an individual to subscribe to

21 residential ISDN, it will cost $28.90 in the State of

22 Delaware plus usage, and that includes both the

ISDN

23 service components plus the dial tone line. The

usage

24 elements apply for a data usage which are two cents

per

38

1 minute per B channel during peak hours, which are

2 Monday through Friday, 7 a.m. to 7 p.m., and it's one

3 cent per minute per B channel for nonpeak hours

which

4 applies to all other times which is evenings and

5 weekends all day long. What that equates to is

6 approximately 60 cents an hour if you have one B

usage

7 in off-peak hours up to a maximum of $2.40 full two

B

8 128-kilobit-per-second data in peak times. And that is

9 the service in a nutshell.

10 So I'd be happy to entertain questions

or

11 answer any other questions about the service.

12 THE HEARING EXAMINER: State

your name.

13 MR. GUMERMAN: Paul Gumerman.

And my

14 address? 519 Marshy Hope Road, Felton, Delaware.

15 What additional equipment is required

at

16 Bell's end to offer the ISDN service?

17 MS. GAGHAN: Okay. In our central

office

18 which is -- there is a separate module, a part of the

19 physical switch which is a digital switch. That is

set

20 aside for ISDN. It's configured to support ISDN

21 service. There are separate physical line cards in

22 which an ISDN will terminate in that switch

module.

23 There is software that is associated with the switch

24 module in operating the ISDN service in handling

the

39

1 traffic management in our service.

2 Also, if the office that we use to serve

3 a given residential customer is not a digital switch,

4 we will extend the service from a digital switch in

5 another location so there is, we call it foreign

6 exchanging, so we have the cost associated with

7 bringing that service to the individual's home site.

8 So it's a piece of equipment that basically lets you

9 extend ISDN from one switch to another and then to

the

10 residential customer, even if their home central

office

11 does not support it.

12 Also, if a customer is located farther

13 from our network than 18,000 feet, which is a

parameter

14 for sending a digital signal, that there is additional

15 equipment that must be put on the customer's lines

so

16 that the quality of the signal doesn't degrade, and

17 that equipment is also included in the cost.

18 MR. GUMERMAN: Is the cost the

19 subscription cost of 28.90 a month and then you

said

20 plus the dial tone?

21 MS. GAGHAN: That includes the dial

tone

22 line.

23 MR. GUMERMAN: That includes the

dial

24 lines?

40

1 MS. GAGHAN: That's correct. The

ISDN

2 feature element of that is $19.50. And the dial tone

3 line rate in Delaware is $9.40 a month. So if you

add

4 the two, that's how you get ISDN.

5 MR. GUMERMAN: And are there any

savings

6 that Bell realizes from taking two pairs and

7 getting -- from taking one pair and getting two lines

8 to offset the increased cost of the -- and removal of

9 the analogue line cards and --

10 MS. GAGHAN: Well, actually, that's an

11 interesting question. But what we're finding is that

12 because the primary driver for use of ISDN in the

home

13 is data, on-line services, work at home, whatever,

the

14 customers that have been signing up for the service

15 have all been additional line customers. So they are,

16 in essence, just converting an existing line or even

17 adding an additional line into their home. So we're

18 actually adding facilities to our network rather than

19 decreasing the numbers.

20 Also, in the switch itself, you're

21 basically taking up two slots through the switch

anyway

22 because each B channel is considered as a separate

23 pathway through the switch. So you're not

necessarily

24 saving anything with an ISDN line, per se, because

41

1 you're still terminating two lines or channels in our

2 switch. So we haven't seen that to be the case so

3 far.

4 MR. GUMERMAN: So that's pretty

much a

5 wash as far as --

6 MS. GAGHAN: Yes, pretty much.

7 MR. GUMERMAN: And one question

that

8 really concerns me the most is why are you making

a

9 distinction cost-wise between data and voice usage?

10 MS. GAGHAN: Well, with ISDN, when

the

11 line terminates in the switch and if it is set up as a

12 data call through the switch, the trunking facilities

13 out the back that connect you to another location

are

14 guaranteed 64 kilobit clear trunks which are separate

15 from the 56 kilobit trunks that we have to support

16 voice service. We have guaranteed the 64 clear with

17 ISDN because one of the key reasons you purchase

the

18 service is to get the full band of the data service.

19 So there is that additional cost of guaranteed 64

clear

20 trunks and there's a very small number of them

today.

21 And that's also connecting to the interexchange

company

22 services if you're going long distance or just to

23 connect to the other office. So there is additional

24 cost from that perspective.

42

1 Also, with data service, the holding

2 times for data service tend to be much longer than

with

3 voice traffic. So that ties up facilities so you have

4 to engineer much more robustly to support data

traffic

5 than you do for voice. So there is a distinction in

6 usage and in facilities.

7 Also, since ISDN is primarily

8 data-oriented, the equipment associated with ISDN,

9 per se, is more expensive than if you're looking at

10 just normal, POTS, plain old telephone service.

11 MR. GUMERMAN: Does Bell have a

position

12 on the use of ISDN, for want of a better word,

modems

13 that do data-over-voice channels?

14 MS. GAGHAN: I don't understand.

What do

15 you mean?

16 MR. GUMERMAN: Is there any

reaction on

17 the part of Bell to the use of the voice 56K service?

18 MS. GAGHAN: Okay.

19 MR. GUMERMAN: With data?

20 MS. GAGHAN: Oh. Well, I guess the

only

21 reaction would be that because of the different

22 engineering parameters associated with data, you

know,

23 you have to engineer to cover the capacity

requirements

24 for data service. If that call is being connected

43

1 through our analogue network piece, per se, what

you're

2 doing is basically taking some facilities out of

3 service for longer periods of time, thus not making

4 them available for the traditional voice users, which

5 could, over time, if you get enough people doing

that,

6 would cause us to have to build extra capacity in the

7 switch and there would essentially be more cost that

8 would have to be covered through some service.

9 MR. GUMERMAN: But there's no

difference

10 in someone doing that than simply having an

analogue

11 modem?

12 MS. GAGHAN: Correct. And actually

if

13 enough people did that through our voice network

even

14 with an analogue modem, which we are starting to

see

15 more and more of these days because of on-line and

16 InterNet access services, what we're starting to see is

17 that the engineering that we have for those

switches,

18 which is based on certain assumptions about usage.

Are

19 being, for lack of a better phrase, blown out of the

20 water. And so we're finding that a lot of those

21 switches are being tied up and people that are

trying

22 to pick up their phone to make a voice call are

getting

23 busies. And so we're going to have to expand the

24 capacity of those switches for the analogue side, not

44

1 just the ISDN.

2 So it's not so much an issue of analogue

3 versus digital. It's more what you're using the

4 service for and what the assumptions are on usage

and

5 how we engineer accordingly. And so if you have a

6 certain infrastructure, you cost that out and try, as

7 in any switch service, to spread those costs over a

8 broad base of users. Once those parameters get

9 exceeded, you're sort of having a bigger cost base

that

10 has to be spread over the customers. So we're

seeing

11 that that's a problem in the analogue network

because

12 of all this data traffic which the analogue network

was

13 not originally engineered to support. So it's a

14 challenge on both sides.

15 So the distinction primarily has been

16 that with ISDN, because it's data oriented, that we

17 have it as a measured service so that you are

paying

18 for the facilities you are using and we can gather

19 information about usage patterns. And as we go

20 forward, we can offer packages that can meet

different

21 needs based on that information and we can

engineer our

22 switches accordingly and make sure that it's as

widely

23 affordable as we can. So it's a starting point. We

24 know it'll cover costs and drive costs back to the

45

1 people who are actually using the service and not

2 having any other user base pick up those costs.

3 MR. GUMERMAN: Okay.

4 MS. GAGHAN: It's kind of a long

answer.

5 MR. GUMERMAN: My one comment

that I

6 have, and it was my initial reaction on seeing the

7 measured usage rates for the data only for ISDN,

was

8 that it looked to me at first blush to be a really

9 blatant attempt to protect leased lines business

10 because the pricing was such that it looked like it

11 would be just marginally more expensive to go with

ISDN

12 than a leased line if you were up for 24 hours a

day.

13 And my impression was that it was -- the pricing

was

14 driven not so much by marketing and cost of ISDN

as

15 much as trying to protect an older technology.

16 MS. GAGHAN: Oh. Actually, not

really.

17 The whole concept behind ISDN and other public

switch

18 network services is to provide broad conductivity to

19 the broadest base of users. So you're typically

20 designing an infrastructure that can be cost-effective

21 for, say, the low-to-moderate-level user. And we

22 engineer the network based on assumptions about

what

23 those average user patterns are going to be. For

24 example, we have about eight analogue users per

46

1 analogue facility. It's sort of like an eight-to-one

2 concentration ratio. Whereas with ISDN where the

3 service is much more, has much longer hold times,

we've

4 engineered the network for like four-to-one

5 concentration ratios. So that whenever you hit a

6 certain usage threshold, it really is more

7 cost-effective to go to a private line alternative

8 because essentially what you're doing is you're using

9 an inordinate share of those shared facilities for your

10 particular use. So essentially you're getting greater

11 benefit than, say, the average user, but paying a

12 reduced rate because those customers are sharing the

13 cost over the whole base.

14 But if you're nailed up 24 hours a day,

15 you basically have a private line for the benefit of a

16 shared network service price. And so you're taking

17 those facilities out of the public network domain

and

18 forcing those other remaining customers to vie for a

19 smaller number of facilities.

20 So it's basically that constant tradeoff

21 of when a public switch or usage-based service is

more

22 cost-effective and when it's really in the best, in the

23 best response to your application to go to a

dedicated

24 private line facility where it is available to you only

47

1 for 24 hours a day and that there are costs associated

2 with having a personal facility, basically, through the

3 network.

4 So I did a little calculation of a

5 crossover point with our T1 rates which is, I'm not --

6 I apologize, I'm not sure if that's the rate in

7 Delaware, but it's around $700 a month in some of

our

8 jurisdictions. And you have to be on 270 hours a

month

9 or about nine hours a day to cross over. So that's a

10 very heavy user of service.

11 MR. GUMERMAN: You should

compare that

12 not to a basic rate but primary rate.

13 MS. GAGHAN: Well, actually, our

primary

14 service, I think it's very close to that.

15 MS. LEONETTI: The primary rate uses

the

16 T1 rate, so that would be accurate.

17 MS. GAGHAN: So it's sort of like if

you

18 really have a need to have a facility on line 24

hours

19 a day, that really shouldn't be going over a public

20 switch network service. I mean, that's not what

these

21 services are designed for. It's sort of like a public

22 switch service is designed to provide the greatest

good

23 for the greatest number of people. And you get the

24 benefit because you're sharing the costs of the whole

48

1 solution over a broad number of people. So it's

2 affordable and gives everybody a chance to get

added

3 functionality. Whereas if you really are that intense

4 a user, you really aren't geared more to a private or

a

5 dedicated-type facility.

6 So I guess we priced it thinking of how

7 we could make it as affordable for as many people

but

8 still cover costs until we could get more usage data

9 and market intelligence on customer needs. And

what

10 we're trying to do in the analysis we're working on

11 right now with pricing is to try to develop usage

12 packages that will track with what we think some

of the

13 driving applications will be. Much like you have

with

14 an InterNet provider where you have 30 hours for

$30 a

15 month and then you pay $10.50 above that for

every hour

16 you use or trying to match -- like if I were a

17 full-time telecommuter, I would need maybe 160

hours a

18 month, which would be eight hours a day, five days

a

19 week, four weeks a month. So that if I'm literally

20 there and working, I would be able to have this

package

21 that I know would cover my requirements. So

we're

22 trying -- and to give discounts on that usage or that

23 package because we have predictability, the

customer

24 has predictability and we can engineer our network

49

1 accordingly.

2 But when we went to our initial launch,

3 as I say, that 19.50 plus usage was as low a rate as

we

4 felt we could charge to cover costs and to meet its

5 broadest base customer requirements. As I say, we're

6 trying to make other things more attractive to meet

7 different needs, but we had to start somewhere and

we

8 wanted to get the service out to the market as

quickly

9 as possible. And that was a good model to start

with

10 since it seemed attractive to some of the other

11 providers.

12 MR. GUMERMAN: I think I'm finished.

13 Thanks.

14 THE HEARING EXAMINER: Will you

state

15 your name and address.

16 MR. LECUYER: Yes. Michael Lecuyer,

17 South Temple Avenue, Viola, Delaware. The

18 data-over-voice question, everybody is using it. And

19 one of the aspects of the InterNet is continuous

20 conductivity of the nature of the InterNet. In other

21 words, I may get mail any time of the day into my

22 system which can be a private system. People want

that

23 conductivity. Doesn't the phone company have --

24 doesn't it see it changing? People will get around

you

50

1 by using the data-over-voice channels. Every ISDN

user

2 is aware ISP is doing this. They're saying get these

3 modems. These do it. These do voice over data,

data

4 over voice. Everybody's going around what you're

doing

5 in your ISDN data right now. It's not going to get

6 better. You're either going to have to slap it on the

7 voice thing with some tariff or throw it all away

with

8 the pricing.

9 Right now I avoid long-distance calls by

10 having call forwarding at your special points where

11 people can do two-county calling and stuff like that.

12 People do this all the time.

13 THE HEARING EXAMINER: Say that

again?

14 MR. CITROLO: That came up before.

15 MS. GAGHAN: Well, I guess part of --

16 well, I guess people can use the analogue network to

17 have that kind of constant accessibility to InterNet

18 and on line. And as I mentioned earlier, if more

and

19 more people start to do that, that will have adverse

20 effects on the rest of our network so that we'll have

21 to engineer it more robustly. And I guess your

pricing

22 structure was an attempt to make sure that people

who

23 have a need for certain capabilities pay for the

24 benefit of those capabilities and not have other

people

51

1 in the general population foot the bill, which is

2 essentially what is happening by folks -- I'm trying

3 to think of the right word -- overutilizing the

4 analogue facilities from the way they were rated and

5 provisioned because the price you pay for an

analogue

6 circuit today is based on primarily voice traffic

7 assumptions which have very short connect times and

the

8 costs are far in excess of what you're actually paying

9 for when you use that.

10 So I guess the issue is we're trying to

11 price new services and hopefully in looking at our

12 existing services so that they do reflect the actual

13 cost of the facilities. And we have in deploying

ISDN

14 on a major basis attempted to cover those costs and

15 only have those people who use the service pay for

it.

16 People will always try to get around the rules and

get

17 the most for the least they can pay. I can't really

do

18 much about that. We're just trying to offer services

19 at affordable rates that also cover our costs of doing

20 business.

21 MR. LECUYER: Well, the InterNet isn't

22 going to go away tomorrow. That is what people

want is

23 conductivity all the time. People will want 24-hour

24 conductivity all the time. Many systems, many

more

52

1 private people will want it. Many people will

continue

2 to call out. But many other people will be providing

3 these InterNet services and they'll be sitting there on

4 the POTS lines with their analogue setups 24 hours a

5 day. I do it already. And eventually either you're

6 going to have to decide that maybe we want to

make the

7 ISDN lines work for an intrastate rate or not.

Because

8 you say people are bending the rules. They're not.

9 They're using the same rules. They're not bending

the

10 rules. They're using what's there, what's available

to

11 them. You're creating a problem for yourself

because

12 people will not pay for that if they can avoid it.

13 MS. GAGHAN: I would tend to agree

that

14 people will do whatever they can to avoid paying

the

15 charges. The only thing I can say is that some of

the

16 companies that provide InterNet services and

enhanced

17 access services like ISDN support do not offer those

at

18 intrastate rates. They do charge usage above a

certain

19 level because they also have cost issues and concerns

20 about things being nailed up, taking up those

limited

21 facilities.

22 I understand with the analogue there

are

23 some network companies that, or InterNet

companies that

24 do offer an intrastate rate unlimited and you can

use

53

1 it all the time. They also have the ability, from

2 having talked to one of them, to monitor customers'

3 lines. And if they detect an idle facility and they

4 need that facility for peak traffic requirements, they

5 have told us that they disconnect those customers

and

6 force you to log back in if you're not using the

7 service. So they have ways that they can work

around

8 some of the traffic problems that we encounter,

which,

9 you know, we can't do the same thing that they do.

10 And I guess all I can tell you is the

11 services that you're using today to have that very

12 affordable unlimited access to the InterNet is priced

13 and engineered for uses that are very different from

14 what you're using them for today. And you're

getting a

15 real bargain.

16 MR. GUMERMAN: May I ask a

question?

17 THE HEARING EXAMINER: Certainly.

18 MR. GUMERMAN: What would it cost

spread

19 out over the universe of ISDN users to simply have

20 intrastate rate pricing, given that some will use it as

21 a maintained connection? Others, if the setup and

22 teardown times are short, there's no point in doing

23 that and people won't do it. So that, you know,

24 technology will help you, obviously. But what

would it

54

1 cost compared to the 28.90 to support intrastate rate

2 usage? I know I would be willing to pay more than

3 28.90, but not two to $300 a month.

4 MS. GAGHAN: Well, right now, we

don't

5 know what it would cost to spread it over a whole

base

6 of users. We have certain assumptions about possible

7 customers. But one of, as I mentioned earlier, one of

8 the main reasons we went out with the structure we

did

9 is so we could learn more about those usage

10 requirements and patterns so we could evaluate our

11 options like that.

12 MR. GUMERMAN: But your rate

structure

13 that you've set up is going to influence what you

see

14 very strongly. It's going to influence the usage

15 decisions.

16 MS. GAGHAN: True. Just as if you

didn't

17 charge for it, it would influence usage decisions. So

18 you have to start somewhere. So at least this way

we

19 will know the people who have a very strong

requirement

20 for the service and feel the value is there over and

21 above what they have for an analogue service. I

mean,

22 the performance is exceptional. The response time

23 makes a big difference in accessing a lot of the

24 applications. I guess based on the costs of our

55

1 network and the service, we couldn't in all good

2 conscious go out and offer a service below the costs

we

3 have to provide it. And ISDN is a service that not

4 everybody needs or will want. But that -- I don't

5 know what else to say.

6 THE HEARING EXAMINER: I have just

one.

7 I guess I shouldn't be asking questions at this stage,

8 but I do have one. And that has to do with the

rates

9 as you described them on the record.

10 Is there any other costs that a customer

11 will have to undergo besides the 28.90 plus usage?

12 MS. GAGHAN: Well, there's an

13 installation charge to actually put the service in. Is

14 that the kind of charge or do you mean on a

monthly

15 basis or in general?

16 THE HEARING EXAMINER: If I came

to you

17 and wanted ISDN service, would I only have to pay

the

18 28.90 a month?

19 MS. GAGHAN: You pay the 28.90 a

month

20 plus usage charges for the rates I quoted or for data

21 usage. If you are using the service for voice, the

22 existing rates in Delaware are three cents for the

23 first three minutes and half a cent for each

additional

24 minute which is basically 32 cents an hour for voice.

56

1 MR. GUMERMAN: Pardon?

2 THE HEARING EXAMINER: Just a

minute. So

3 now I will be paying usage for voice?

4 MS. GAGHAN: Correct. Actually ISDN

--

5 the ISDN features sit on top of a local measured

6 service line. And the local measured service line

7 charges are what are already in effect in Delaware,

the

8 existing tariffs.

9 THE HEARING EXAMINER: So if right

now

10 I'm paying an intrastate rate for voice.

11 MS. GAGHAN: Yes.

12 THE HEARING EXAMINER: If I

change to

13 ISDN, I will now have measured service?

14 MS. GAGHAN: Correct. And part of

the

15 reason we were doing that is to, one, deter people

from

16 working around the system and, two, to get a true

gauge

17 of usage, whether it be voice or data. And to be

18 honest, we figured that given the benefits of ISDN,

19 that voice usage would be very limited. People are

20 buying it for data.

21 MR. GUMERMAN: You might want to

tell

22 your representatives at your 800 number, your ISDN

23 answer line about the measured voice calls. I spoke

24 with them two days ago and was told nothing

about --

57

1 MS. GAGHAN: Which group, do you

2 remember?

3 MR. GUMERMAN: Bell Atlantic

residential

4 ISDN group.

5 MS. GAGHAN: You did call the --

6 MR. GUMERMAN: Yeah. They knew

nothing

7 about that.

8 MS. GAGHAN: That's standard.

9 MR. GUMERMAN: They told me only

about

10 data charges. Nothing at all about measured. I

mean,

11 I had intrastate rate voice.

12 MS. LEONETTI: Delaware is one of the

few

13 states that still offers an intrastate rate coverage.

14 And probably they assumed, which they should not

have,

15 that you knew voice would also be measured.

16 MS. GAGHAN: See, ISDN as we filed

it is

17 on a measured rate local service line. So I'm sorry.

18 I thought you did know that.

19 THE HEARING EXAMINER: Now,

does one need

20 additional equipment to take ISDN service?

21 MS. GAGHAN: Yes.

22 THE HEARING EXAMINER: Is that

free of

23 charge?

24 MS. GAGHAN: Oh, no. This is

basically

58

1 the equivalent of your having a modem to work

with your

2 computer. It's called an ISDN terminal adapter. And

3 it basically allows nonISDN compatible equipment

like

4 your PC or your plain old phone at home to work

over an

5 ISDN line and to talk to our network.

6 THE HEARING EXAMINER: And what

is the

7 cost?

8 MS. GAGHAN: It depends on what type

of

9 equipment you buy. But we have been able to

negotiate

10 with a few vendors to get the price below $300,

which

11 is in the ballpark of what a high-speed 28.8 modem

was

12 about six months ago, I guess, 200, 250. Now, it's

13 much cheaper, but ISDN gives you much better

14 performance. So there are higher cost products,

15 depending on what you want, that can range as

high as a

16 thousand dollars. But there are full-function ISDN

17 terminal adapters that are less than $300.

18 THE HEARING EXAMINER: Are there

any

19 other charges that one will have to pay? Is there an

20 installation charge?

21 MS. GAGHAN: There is installation.

22 That's $125 for the ISDN line plus for the ISDN

23 capabilities and $35.96 which is the charge if you

are

24 installing an additional line into your home and not

59

1 just converting an existing line that's there. So if

2 you're putting a new line into your home, that

would be

3 for running the local service line.

4 THE HEARING EXAMINER: Would I

need to

5 put in a new line?

6 MS. GAGHAN: You do not have to.

You're

7 perfectly able to use an existing facility in your

8 home. We do not recommend your making it your

only

9 line in your home for a couple of reasons which are

10 technology-oriented right now. ISDN is locally

11 powered, meaning that it drives its power source

from

12 your home. So if you plug the service in and you

lose

13 your power in your home, you also lose your phone

14 service. So that means you can't dial 911, you can't

15 dial zero. So we do not recommend it at this point

for

16 your primary line in your home.

17 Fortunately, the main driver for ISDN

has

18 been data and on-line usage and most people have

19 additional lines for that purpose if they are serious

20 users, anyway. So it's been primarily a second line.

21 THE HEARING EXAMINER: Okay.

Thank you.

22 Ms. Stowell, do you have any

questions,

23 comments?

24 MS. STOWELL: No questions.

60

1 THE HEARING EXAMINER: Mr.

Citrolo.

2 MR. CITROLO: No, Mr. Examiner. I

think

3 it was answered, though, if I could get a clarification

4 on the voice.

5 MS. GAGHAN: Certainly.

6 MR. CITROLO: The voice will be

measured

7 and billed but according to the measured rates that

are

8 tariffed.

9 MS. GAGHAN: Correct.

10 MR. CITROLO: That was the only

11 clarification. So even a person who chooses an

12 intrastate voice plan will lose it with ISDN?

13 MS. GAGHAN: Correct.

14 MR. CITROLO: Okay.

15 MS. GAGHAN: In our tariff for ISDN,

we

16 specify that it needed a measured rate local line

17 arrangement.

18 MR. CITROLO: Okay. And if I could

just

19 clarify a couple things, Mr. Hearing Examiner, with

the

20 rates that were discussed earlier. That seems to be a

21 lot of the problem is the confusion with the rates,

22 what the 19.50 exactly gets you per month. And I

have

23 a tariff page in front of me what I interpret the

base

24 rate starts at 17.50. You pay a dollar for circuit

61

1 switch voice.

2 MS. GAGHAN: Or data.

3 MR. CITROLO: An additional dollar for

4 circuit switch data and then an additional dollar to

5 have simultaneous transmission of both.

6 MS. GAGHAN: No. The way that the

tariff

7 reads, it's a base of 17.50, and depending how you

want

8 each of the B channels configured, it's an incremental

9 dollar per B channel. So if I wanted to have one B

10 channel of circuit switch voice, it would be a dollar

11 for that B channel. And if I wanted the other to be

12 circuit switch data, it would be a dollar for that

13 channel. But if I wanted them to be configured to

14 support either voice or data, it would only be a

dollar

15 total for each channel. It's sort of like an either/or

16 proposition. You can have it support voice only,

data

17 only or both. And whatever you pick for those B

18 channels, it's a dollar no matter what. So the worst

19 you could end up paying is $2 on top of the 19.50

20 because the most you could pay is a dollar per B

21 channel, and there are two B channels, on top of the

22 17.50.

23 MR. CITROLO: This clearly says each -

-

24 THE HEARING EXAMINER: Excuse

me. I want

62

1 to make sure I understand this. You said the most

you

2 can pay is $2?

3 MS. GAGHAN: On top of the 17.50 to

4 configure the service.

5 THE HEARING EXAMINER: Or you

can pay $1

6 for each channel.

7 MS. GAGHAN: No, no, no. Oh.

8 THE HEARING EXAMINER: Which is

also $2.

9 MS. GAGHAN: Oh, well that's true. No

10 matter what you do, it still comes out to 19.50. We

11 just happened to price it the same because, in

essence,

12 the costs to provision it any of those three ways is

13 the same but we just needed to know when you

order the

14 service how you want it configured. And so when

you

15 tell us, it just has an automatic dollar increment

16 associated with it. I'm sorry.

17 MR. CITROLO: Those who subscribe to

18 residence ISDN, and I want to only activate one B

19 channel but I want simultaneous transmission voice

and

20 data. What would my monthly recurring rate be?

21 MS. GAGHAN: In the tariff, we did

not

22 make one be an option for the consumer. Primarily

23 because, again, in response to the requirements, all

of

24 the customers that wanted to use the service never

63

1 found a need for only one B channel and they always

2 wanted to get the most out of the service as possible,

3 which was to do the two B 120 kilobit data wherever

4 they could; or in the work-at-home environments, to

be

5 able to have one line for their voice and the other

for

6 their data.

7 MR. CITROLO: Even under that

scenario, I

8 still read that it would be -- let me come back to

9 that. Then if I have to activate both B channels and

I

10 want to transmit at 128 kbs, I would pay four cents

a

11 minute, 7 a.m.-7 p.m. and two cents off beat because

I

12 would pay two cents per B channel.

13 MS. GAGHAN: That's correct. So that

14 comes out to $2.40 an hour in peak two B usage, or

15 $1.20 an hour in off peak two B use or 60 cents and

16 $1.20 if it's one B for nonpeak versus peak. So, yes,

17 it is per B channel.

18 MR. CITROLO: Okay. On the

intrastate

19 recurring charge, I pay 17.50. That gives me

multiple

20 access residential IntellilinQ-BRI. An extra dollar.

21 MS. GAGHAN: Correct.

22 MR. CITROLO: Gives me alternate

circuit

23 switch and voice and data service per service

provider.

24 MS. GAGHAN: Per service provided.

64

1 MR. CITROLO: I'm at 18.50, right?

2 That's only an extra dollar.

3 MS. GAGHAN: Right, for one of the B

4 channels. Per service provided means per B channel.

5 MR. CITROLO: Right. That right there

6 tells me, though, if I want simultaneous transmission

7 on both B channels, I'm at 19.50 right there.

8 MS. GAGHAN: Correct.

9 MR. CITROLO: Okay. Now --

10 MS. GAGHAN: Which is the most.

11 MR. CITROLO: I can activate one

channel

12 for voice and one channel for data.

13 MS. GAGHAN: Right. And you're still

14 19.50.

15 MR. CITROLO: Let's say I do that.

I'm

16 at 19.50. I activate one channel for circuit switch

17 voice, one channel for data.

18 MS. GAGHAN: Okay.

19 MR. CITROLO: Now I'm on-line. I

want to

20 send a fax. I can't do it.

21 MS. GAGHAN: You're on line with

your

22 computer?

23 MR. CITROLO: Say I'm with America

On

24 Line Prodigy.

65

1 MS. GAGHAN: And you want to send

a fax?

2 MR. CITROLO: I want --

3 MS. GAGHAN: You can do that on the

voice

4 channel. That would be like an analogue -- anything

5 you can do over your phone line today if it's

6 configured for voice is what you can do if it's

7 configured for circuit switch voice.

8 MR. CITROLO: Simultaneously?

9 MS. GAGHAN: Correct.

10 MS. STOWELL: And how much would

that

11 cost per month?

12 MS. GAGHAN: Per minute? If you're

13 sending it over as a voice call, which is what most

14 faxes would be considered, that would be at the

voice

15 rates which would be 32 cents an hour.

16 MR. CITROLO: My question really

then is

17 according to the tariff pages, why would I do

anything

18 else but pay a dollar per B channel for option C

which

19 is an alternate circuit switch voice and data service?

20 I mean, I'm paying the same rate, 19.50, but I have

21 simultaneous transmission on each B channel for the

22 same price.

23 MS. GAGHAN: No, no. You get that

with

24 the -- either way. To be -- I guess the confusion is

66

1 that we broke the elements out more from a

provisioning

2 perspective rather than a capabilities perspective.

3 You have the same capabilities -- if you have one --

4 I'm trying to think. If you have your line configured

5 for circuit switch data or for one B channel and you

6 have your line, your other B channel configured for

7 circuit switch voice, you can get the same benefit as

8 if you had either one of them configured for circuit

9 switch voice or data. You get the same functionality

10 over the two B channels regardless of how you

provision

11 each B channel, if that makes any sense.

12 MR. CITROLO: I'm not arguing with

the

13 logic of the transmission. I'm arguing with the

logic

14 of the tariff pages. This leads me to believe that if

15 I want to subscribe to residential IntellilinQ-BRI

16 service, I want to activate two B channels and have

17 simultaneous transmission of voice and data on each

18 channel.

19 MS. GAGHAN: Right.

20 MR. CITROLO: I would pay a dollar

to

21 activate voice per channel, a dollar to activate

22 circuit switch data per channel and a dollar for the

23 simultaneous on each. And I'm up to 18.50, 19.50,

24 20.50, 21.50, 22.50, 23.50.

67

1 MS. GAGHAN: No. I guess we didn't --

2 MS. GAGHAN: It's confusing.

3 MR. CITROLO: That seems to be what

this

4 says where the 19.50 always comes off as an absolute

5 minute.

6 MS. GAGHAN: It's actually the

maximum

7 and the minimum, basically. No matter how you

8 configure it, it's the same rate. And I guess by

9 breaking it out by how you could possibly configure

the

10 service, we made it more confusing. We probably

should

11 have said it's 19.50, but you need to specify how

you

12 want the service used instead of -- so it's probably

13 just how it's presented. It has no cost or

14 implementation difference.

15 MR. CITROLO: How I interpret it is if

16 someone were to ask me what the rate is and I read

17 this, 19.50 still is a minimum.

18 MS. GAGHAN: And a maximum.

19 MR. CITROLO: As the way I read this.

I

20 understand what you're saying.

21 MS. GAGHAN: It never will be any

more.

22 It's basically that it's not clear.

23 THE HEARING EXAMINER: We can't

both talk

24 at the same time, for the court reporter. She can't

68

1 record two voices. I know this is getting you all

2 excited.

3 MS. GAGHAN: No. It's there.

4 MR. CITROLO: Because then I don't see

5 where you say if it's 19.50 for option A and B.

6 MS. GAGHAN: And C.

7 MR. CITROLO: Or, well, then, just C.

8 Because I read C to say alternate circuit switch voice

9 and data service per service provided, $1. That's --

10 MS. GAGHAN: Per B channel.

11 MR. CITROLO: I have to activate both

B

12 channels for residence.

13 MS. GAGHAN: Correct.

14 MR. CITROLO: So we're at $2. Option

B

15 says circuit switch data service per service provided,

16 $1.

17 MS. GAGHAN: That'll be on one of

your B

18 channels. If you did it on both, that would be $2.

19 MR. CITROLO: But the per service

20 provided clause clearly implies that it's $1 per

21 channel.

22 MS. GAGHAN: It is.

23 MR. CITROLO: So it's two, four, six

when

24 you read this. I mean, that's -- I mean, it's clear to

69

1 me what you said, but this has per service provided.

2 THE HEARING EXAMINER: I think this

issue

3 is one that perhaps can be clarified between now and

4 when we hold the evidentiary hearing. This is more

of

5 a discovery type of thing that should be --

6 MS. STOWELL: Maybe what needs to

be done

7 is the tariff rewritten.

8 MS. GAGHAN: That would probably

make it

9 easier.

10 MS. STOWELL: So that it says

11 multiple --

12 THE HEARING EXAMINER: I mean,

it's clear

13 on the record that there is a lot of confusion about

14 the way the tariff obviously appears. I mean, this is

15 not an evidentiary hearing and so, you know, we

16 shouldn't get into the formality of it. But I think

17 this is something that the Company and the Staff

and

18 the OPA can look at informally and when we get to

the

19 formal hearings at some point before I get back to

the

20 Commission, I would like to see the language in the

21 tariff cleared up so the customers and the

Commission

22 will understand exactly, you know, what the price is

23 that's being offered for this service.

24 MR. CITROLO: I just had one

comment for

70

1 the first gentleman who spoke. Are you a BRI

2 subscriber right now?

3 MR. GUMERMAN: No.

4 MR. CITROLO: There are effective the

5 31st of this month will be discounted block programs

6 for BRI. I don't know if that brings it more on line

7 than what your comparison was about the rate

8 structure.

9 MR. GUMERMAN: My comparison was

that if

10 you had a 56K leased line costing, you know,

somewhere

11 between 150 and 250, $300 a month, ISDN is a very

nice

12 solution to replacing that, bringing the cost down.

13 And as technology moves forward, the cost should

come

14 down. And it struck me that Bell seems to be

resisting

15 the advancing technology that they want to bring it

out

16 but they don't want to bring it out in case it might

17 disrupt their other existing infrastructure.

18 MS. GAGHAN: Well, the crossover

point

19 with those services is so high.

20 MR. GUMERMAN: Not if you're

talking

21 about a 56K leased line. You were comparing it to

a

22 T1.

23 MS. GAGHAN: Well, actually --

24 MR. GUMERMAN: Which it's not.

71

1 MS. GAGHAN: Our DCS which is a 56

2 kilobit leased line service is $205 per month per end

3 which means it's $410 for a 56 kilobit circuit. With

4 ISDN, you get two 64 kilobit circuits which would

be

5 twice that which would be about $820 per month.

We

6 have switched 56 service which is $150 per month for

a

7 56 kilobit circuit which times two to equate to a two

B

8 ISDN which would be $300 a month. But there's

usage on

9 top of that of 14 cents a minute. So, really, the

10 crossover point is pretty --

11 THE HEARING EXAMINER: Just a

minute,

12 please.

13 (A brief recess was taken.)

14 MR. GUMERMAN: I did want to ask

what is

15 the logic, and perhaps you're not the right person to

16 ask, but what is the logic behind having an

intrastate

17 rate tariff for POTS voice service, just standard

voice

18 service available and not having it available if the

19 delivery method is ISDN?

20 MS. GAGHAN: Well, with our voice

21 service, we have lots of history and experience in

22 understanding the use and requirements of people in

23 that arena. So we've been able to offer it as a rate

24 that is universally affordable. It's also a subsidized

72

1 service. It does not cover its cost today. Other

2 services are paying for the usage of that service or

3 the facilities in our network to support that service.

4 So its intent and goal was to provide universal voice

5 availability for our customers for basic phone

6 requirements and it was priced based on certain

7 assumptions. And because of the use of those

8 facilities for other things than what they were

9 originally rated for, basically we're incurring much

10 more substantial costs than really are actually

getting

11 less and less to cover those costs because people are

12 using those facilities when they should be using

13 something else that is better suited to the

14 requirements that covers that network requirements

for

15 that service.

16 I probably didn't answer that very

well,

17 but --

18 MR. GUMERMAN: Surely there must

be some

19 calculations of costs that explain the difference in

20 the tariff going back to the regular voice for

measured

21 service versus intrastate rate service. And --

22 MS. GAGHAN: All of the rates are

based

23 on certain usage assumptions and customer base

24 assumptions. I mean, voice is universal. It's a

73

1 hundred percent of our -- or almost virtually a

hundred

2 percent of our 12 million households have voice

3 service. And because of public policy needs and

4 requirements, we have made that service available at

a

5 very affordable rate that actually is being paid for by

6 other services that Bell Atlantic offers, whether they

7 be business services or value-added residential

8 services. And so that was geared for very different

9 objectives and assumptions.

10 When we introduced new services, we

have

11 different sets of assumptions that these new services

12 in almost, I guess, every single case are geared

toward

13 meeting enhanced requirements or needs of our

customers

14 beyond basic phone access. So they have emergency

15 access or lifeline service. And so we have a policy

16 that we will introduce services that cover their costs

17 and that bring a reasonable return to the company

to

18 help pay for that other base of universal service.

19 And so they're very different objectives

20 and assumptions and we've tried to price any new

21 service to meet the requirements of the users of

those

22 services as best we can and still cover the costs of

23 providing them. It's just very different needs being

24 met. And when services that were geared toward

one set

74

1 of objectives, namely universal voice access, are being

2 used for other things, that kind of puts in jeopardy

3 that overall model. If anything new comes out that

4 also is being subsidized that builds that base of costs

5 that have to be covered somewhere, it makes it

bigger

6 and bigger. And I guess as a business, we can't

afford

7 to do that indefinitely or eventually we'll go out of

8 business.

9 MR. GUMERMAN: I can understand

that.

10 All I can say is that if you want to build ISDN,

come

11 up with an intrastate rate and you will build it

12 quickly. And it doesn't have to be a giveaway rate.

13 But, you know, the question of not knowing what

it's

14 going to cost me and especially not being able to

use

15 that, use a B channel for a voice line and have it be

16 the same as what I'm paying now, why should I

change?

17 MS. GAGHAN: Well, I assume you

probably

18 wouldn't buy ISDN for voice because you can get

19 perfectly acceptable voice service and enhanced

20 features over the plain old telephone network today

at

21 very affordable rates. So I guess given that our

22 orientation is that ISDN is beneficial primarily for

23 data and image and video capabilities, that it is at a

24 reasonable rate for the performance and the value of

75

1 that service. But may I ask a question?

2 MR. GUMERMAN: Sure.

3 MS. GAGHAN: I don't know if I'm

allowed

4 to do that.

5 From a customer perspective and a

6 perspective user of ISDN, when you talk about

7 intrastate rates, I mean, packages for certain volumes

8 that give you a break that you could predict monthly

be

9 acceptable in your mind or are you looking for

10 something that has just an unlimited potential for a

11 fixed rate? Because there's ways with a package

that

12 can make a service rate much more affordable on a

13 monthly basis than if you have it open-ended where

it

14 could be literally 24 hours a day, you know.

15 MR. GUMERMAN: Well, like you, I

want to

16 be experimenting with ISDN. I can't right now. I

17 don't know if the uses that I will have will be

18 amenable to setting up and tearing down

connections and

19 using it that way or whether I'm really going to

need

20 to be up 24 hours. I won't be sending a lot of data.

21 I'm pretty sure of that. I don't expect a lot of

22 traffic but I do need to be able -- I need the

23 conductivity one way or another.

24 And you could sell so much of this

stuff,

76

1 it would be -- I think you would be surprised if you

2 price it differently.

3 MS. GAGHAN: Do you have an idea of

what

4 you would consider reasonable under that type of a

5 scenario?

6 MR. GUMERMAN: For an intrastate

rate, I

7 would easily pay two, two-and-a-half times this rate

8 and be -- and I think a lot of people would rather

than

9 have a bill that they don't know what it's going to

10 be.

11 MS. GAGHAN: Okay. Is it that you

need

12 to be physically connected 24 hours a day because

your

13 application won't allow things to be deposited like a

14 central E-mail server or something?

15 MR. GUMERMAN: Yes.

16 MS. GAGHAN: It has to have your PC

on.

17 MR. GUMERMAN: We're talking on

the

18 InterNet here, which means if I'm a web site, it

needs

19 to be -- it needs to answer when someone calls.

20 MS. GAGHAN: Okay.

21 MR. GUMERMAN: And if we can do

that by

22 setting up and tearing down connections, that

would be

23 great.

24 MS. GAGHAN: Okay. From what I

77

1 understand, there are ways to make the equipment

that's

2 talking to each other basically do that automatically

3 without having to keep the circuit nailed up all the

4 time so that you're basically getting the benefit of

5 the access when you need it but it's not physically

6 tying up one of our facilities through the network so

7 that nobody else could use it, which is a concern of

8 ours because if you do have 24-hour-a-day tie-up

even

9 though you're not sending data out, that's facilities

10 tied up for us. That's our concern for rating it so

11 you don't leave it up when you're not using it

because

12 that hurts us and the rest of our customers.

13 Is this structure or a package structure

14 that unappealing to you? It's just that it's measured

15 from the get-go that is least appealing or if you had

16 something that would equate to what your real on-

line

17 time was for a reasonable rate, would that meet

your

18 requirements?

19 MR. GUMERMAN: Measured rates

from the

20 get-go bother me because like everybody in this

room, I

21 have when you pick up the phone and you pay

your

22 monthly cost for it and that's it. I can understand

23 that Bell might want to change that. But it's

24 going -- it's going to be a big fight. I can see

78

1 that.

2 MS. GAGHAN: Well, I mean, we don't

want

3 to change it for our voice customers because that is

4 something, at least -- well, I should say we want to

5 be able to provide universal access for our voice

6 customers, but the network is no longer being used

for

7 voice or as predominantly for voice as it used to be.

8 And so there are going to have to be other models to

9 help us reflect today's use of the facilities versus

10 the old model. I like the model today but a lot of

the

11 use of it anymore is not covering the cost of those

12 facilities.

13 MR. GUMERMAN: Yeah. I guess I

would be

14 very interested to know at what point in this

monthly

15 tariff would it be feasible to make it truly intrastate

16 rate because I think as a matter of public policy

even,

17 there are a lot of advantages, even if it costs

another

18 10 or 15 or $20 a month just to get it period, there's

19 a lot, I think there's a lot of advantages to

20 encouraging this rather than trying to -- rather than

21 discouraging it. And this tariff, I think this is

22 discouraging.

23 MS. GAGHAN: It's a fine line to draw

to

24 have a service that really opens up the potential for

79

1 customers to take full advantage of the network

versus

2 potentially setting up a whole host of private lines

3 through our network, which is a very real possibility.

4 The more people like yourselves and ourselves that

5 really get hooked on using the better facilities

6 through the network and we have to be very careful

that

7 we're not defeating the whole purpose of a public

8 switch service. So it's kind of like a balancing act

9 between how to make it as affordable and conducive

to

10 usage as possible, but without basically building a

11 private network for everybody who wants to use

the

12 service.

13 So we're trying to balance where you

14 cover the costs and incent usage at the same time

and

15 we went out the door with a structure that basically

16 covered costs and tried to make that base starting

17 point as low as possible and then you just pay for

what

18 you use. I think that was a good starting point but

19 we're working on other things.

20 MR. GUMERMAN: Okay. Thank you.

21 MS. GAGHAN: Because we didn't

know what

22 point to pick that would meet the requirements

you're

23 talking about and not blow our network out of the

24 water.

80

1 THE HEARING EXAMINER: Are there

any

2 other comments?

3 (No response.)

4 THE HEARING EXAMINER: I guess

not. So

5 we'll adjourn at this time and there's another public

6 comment session scheduled for Thursday night at

seven

7 in Wilmington. Thank you.

8 (The public comment session was

adjourned

9 at 8:17 p.m.)

81

4

C E R T I F I C A T E

ANNETTE PACHECO,

14 Notary Public-Reporter

15

Volume 3 82

1 PUBLIC SERVICE COMMISSION

2 STATE OF DELAWARE

3 In the matter of the tariff :

filing of Bell Atlantic - : P.S.C. Docket

4 Delaware, Inc. for the : No. 95-014T

implementation of residence :

5 ISDN service :

6

The above matter came on for public hearing

7 on Tuesday, January 18, 1996, at 7:00 p.m. in the

Elbert N. Carvel State Building, N. French Street,

8 Wilmington, Delaware.

9

BEFORE:

10

G. ARTHUR PADMORE, The Hearing Examiner

11

12 APPEARANCES:

13 On behalf of Public Service Commission

Staff:

14 BARBARA MacDONALD, ESQ., Staff Rate

Counsel

JOHN CITROLO, Public Utilities Analyst

15

16 On behalf of Bell Atlantic - Delaware:

17 DOUG SMITH

LINDA GAGHAN

18 GINNY LEONETTI

19

On behalf of Office of the Public Advocate:

RAJNISH BARUA

WILCOX & FETZER

24 1330 King Street - Wilmington, Delaware 19801

(302) 655-0477

83

1 THE HEARING EXAMINER: Good

evening.

2 This is an evening public comment session in Docket

No.

3 95-014T and it concerns the Bell Atlantic application

4 to provide our residents ISDN service. The tariff has

5 already gone into effect as of November and the

6 Commission is having an investigation into the rates

to

7 determine whether or not they are just and

reasonable.

8 And the purpose of this hearing is to receive public

9 comment concerning the Bell Atlantic service; after

10 which the Commission will then have a formal

hearing so

11 that the parties may present evidence for or against

12 the proposed rates.

13 Bell Atlantic has representatives here.

14 I'll ask them to introduce themselves for the record.

15 MR. SMITH: I'm Doug Smith, director

of

16 regulatory affairs.

17 MS. GAGHAN: I'm Linda Gaghan,

product

18 and marketing manager for residential ISDN.

19 MS. LEONETTI: Ginny Leonetti, filing

20 manager, Bell Atlantic Delaware.

21 THE HEARING EXAMINER: And the

Commission

22 is also represented.

23 MS. MacDONALD: I'm Barbara

MacDonald,

24 Staff rate counsel.

84

1 THE HEARING EXAMINER: As is the

office

2 of the Public Advocate.

3 MR. BARUA: Rajnish Barua for the

Office

4 of the Public Advocate.

5 THE HEARING EXAMINER: And we

have one

6 member of the public present, Mr. Stewart Dickson

who

7 wishes to make some comments concerning the Bell

8 Atlantic tariff and service. But before you begin,

9 Mr. Dickson, I'll let a representative from Bell

10 Atlantic give a brief overview of what's involved

and

11 then you may speak.

12 I'm taking these comments to become

part

13 of the record of this proceeding and so I would ask

you

14 when you speak to confine your remarks to the

subject

15 matter at hand which is the ISDN service and the

16 proposed rates.

17 MR. SMITH: Thank you, Mr. Hearing

18 Examiner. At this point we've got some brief

remarks

19 prepared by Linda Gaghan.

20 MS. GAGHAN: Good evening, ladies

and

21 gentlemen. I'm here this evening to answer

questions

22 about residential ISDN. And for those of you who

are

23 not as familiar perhaps with the service, I wanted to

24 just highlight some of the aspects of the service.

85

1 ISDN service is like getting two phone

2 lines over a single pair of wires into your home, the

3 same kind of wires that you have running into your

home

4 today. It can be used to make normal voice or fax

5 calls but, more importantly, to send and receive

6 information much faster from your computer.

7 Assuming the folks in the audience

today

8 are current on-line or InterNet users, then you're

9 probably using a high-speed modem to access these

10 services today. But with ISDN, you would be able

to

11 access these services much faster, up to eight times

12 faster if you use a 14.4 modem or four times faster

if

13 you have a 28.8 modem. I have handouts that I

have

14 with me that show a few real life examples that we

15 clocked of the speed difference between ISDN and

the

16 highest speed analogue modem. And the more

graphical

17 or video intensive the application, the greater the

18 benefits of ISDN.

19 One example that's listed is we accessed

20 CNN, the Cable News Network's InterNet site and

pulled

21 up a news story, an audio clip and a video clip

which

22 took less than three minutes with ISDN and almost

23 11-and-a-half minutes with a 28.8 modem which is

the

24 fastest. And the difference would have even been

86

1 greater if you had a slower modem.

2 We believe this particular benefit will

3 be appealing to the growing base of home InterNet

and

4 on-line services users which already number in the

tens

5 of millions and to the growing and large 64 million

6 base of individuals who work from home in some

7 capacity.

8 As our initial entry into the market

with

9 the residential ISDN, we've positioned the service so

10 that it is as widely affordable as possible and as fair

11 as possible to the broadest number of people so that

12 only the users of the service are paying for the cost

13 of the service and that each individual only pays for

14 what they use. No more, no less.

15 This way ISDN as a service stands on

its

16 own. It covers its own costs and is not being

17 subsidized by any other service or group of

customers

18 in Bell Atlantic. Also, this way the smaller users

19 don't end up subsidizing the heavy users.

20 Our proposed pricing structure, in

order

21 to subscribe to ISDN, it will cost you $19.50 per

month

22 for the ISDN capabilities; $125 to install the ISDN

23 line. There are data usage rates of two cents per

24 minute per B channel during peak times which are

Monday

87

1 through Friday, 7 a.m. to 7 p.m., and nonpeak rates

of

2 one cent per minute per B channel, which is all other

3 times in the evenings and on weekends which is

when

4 most residential users would be using the service.

5 These rates are on top of a local

6 measured rate dial tone line which, in Delaware, is

7 $9.40 a month; plus, if this is a new line going into

8 your home, there is an installation charge of $35.96.

9 If you're converting an existing line in your home,

10 that charge does not apply. There are voice usage

11 charges associated with this line of three cents for

12 the first three minutes and half a cent for each

13 additional minute.

14 As we gather more information about

usage

15 of ISDN and customer requirements for the service,

we

16 do plan to introduce other pricing options that will

17 meet different users' requirements. This is

something

18 we're working on actively right now and plan to

19 introduce by no later than the end of this year and

20 hopefully much sooner.

21 Now I'd like to just open the floor for

22 your comments and questions.

23 MR. DICKSON: Okay. I'm a

professional

24 visual artist and a technical expert in telephony and

88

1 computer networks. I will attach my resume to my

2 written comments when I hand those in.

3 As far as my research has shown me, it

4 looks like Bell Atlantic's current ISDN tariff for the

5 state of Delaware is in violation of the principle of

6 universal access as guaranteed by the

Communications

7 Act of 1934. Bell Atlantic's pricing looks

8 anticompetitive to me. It widens the gap between

the

9 technological haves on the national information

10 infrastructure and the have-nots who cannot afford

to

11 get on line. Word on the street is that ISDN is

12 prohibitively expensive and no one is buying it for

13 that reason.

14 High pricing discourages the

exploration

15 and development of electronic commerce by small

16 businesses in the state of Delaware when consumers

17 cannot afford to get on line. I believe that small

18 businesses are going to be the ones employing more

19 people in Delaware than a giant communications

20 corporation would contribute to the employment

base.

21 Competitive pricing, on the other hand,

22 of high-speed data communications could promote

23 telecommuting from offices in the home and

alleviate

24 automobile congestion on Delaware's streets and

89

1 highways.

2 Pricing ISDN service by the minute does

3 not reflect the real cost of providing the wire

4 connection and the switching service. In fact, there

5 are technical reasons. And I attach a footnote to the

6 end of my comments explaining these technical

reasons

7 why pricing by the minute could actually consume

more

8 of Bell Atlantic's switching resources than a flat-rate

9 pricing would. Flat-rate pricing could actually reduce

10 the cost to Bell Atlantic of providing ISDN service

and

11 I can support this claim from my own experience.

12 I've been an ISDN user since March

1995.

13 In June '95, I relocated from Thousand Oaks,

14 California, to the Pike Creek Valley in Delaware.

15 Somehow for the three months I lived in California

16 using ISDN, GTE California was able to wire its

service

17 area many times larger both in population and in

miles

18 of wiring than the entire state of Delaware and

provide

19 two B channels of ISDN service for a flat rate of

$41 a

20 month.

21 In Delaware in six months, I have

already

22 paid Bell Atlantic more than I would have paid for

five

23 years of service in California. I have paid this for a

24 local telephone call covering 11 miles of distance

from

90

1 the Pike Creek Valley to Wilmington. And I have

2 received for my money half the data transmission

speed

3 I had in California. In Delaware, only one B channel

4 is more than I can reasonably afford. I think this is

5 unfortunate because I believe I have valuable

6 information to provide, to share with the public.

7 I am an originator of a technique to

8 create physical sculpture of computer-generated

9 abstractions called scientific visualization using

10 direct 3-D mechanical printers, and I've documented

11 this work on the InterNet. I can bring computer

12 pictures out from behind the computer screen and

allow

13 you to hold them in your hands. I can let a person

14 experience computer graphics for whom images on a

15 cathode-ray tube provide no information. These

would

16 be blind people and those with cognitive disabilities.

17 Networked computers can provide this experience.

No

18 television will ever do this. No corporation has

done

19 this. It took the efforts of an individual on an

20 individual's budget to do this.

21 The InterNet is a collective of

somewhere

22 over four million individuals. The InterNet is like

23 truly democratic multimedia publishing. The

InterNet

24 is currently owned by everyone and every InterNet

site

91

1 is its own information center. On the InterNet, the

2 media is not them, it is us. Letting the InterNet fall

3 into the hands of a communications giant will turn it

4 into the same old us-and-them situation we have in

our

5 current electronic media. In the InterNet, we have a

6 chance to build a future world which is better than

7 past worlds. Flat-rate pricing for local telephone

8 connection will promote this.

9 And if you're interested, I can go into

10 the technical reasons that I was talking about. The

11 way I did things in California were substantially

12 different from the way I'm doing things in

Delaware

13 over the wires and I believe I saved GTE California

14 some load on their equipment the way we were

able to

15 run there that I'm not saving Bell Atlantic by the

way

16 we have to run -- with the way we're forced to run

17 here. If you'd like me to go into that, I'd be glad

18 to.

19 MS. GAGHAN: Sure. I'd like to hear

20 what you have to say.

21 MR. DICKSON: Okay. I used an

InterNet

22 word router to run my wide-area network over

ISDN.

23 It's called an ascend communications pipeline 50.

It's

24 a bridge between a users local-area network and the

92

1 wide-area network which would be the first top

2 connection to the user's upstream InterNet access

3 provider.

4 The time required to connect an ISDN

call

5 is very short. It's imperceptible to the user of a

6 desk-top InterNet application like a worldwide web

7 router. The ascend pipeline 50 has features to

8 automatically connect a call when the local area

9 network requests packet transmission to the wide-

area

10 network. Similarly, the pipeline 50 also has a user

11 configurable timer which governs how long the

router

12 will maintain the ISDN call after the last packet has

13 been transmitted or received.

14 After this time has expired, the router

15 hangs up the call and waits for the next packet to

16 originate from the local-area network. In a

telephone

17 economy in which money is charged per minute of

18 connection, the information consumer can set the

router

19 time out very short to save money when the user is

not

20 actively transmitting. In a situation which is billed

21 by the minute, the InterNet access provider will

never

22 originate a call to the end user even to transact

23 electronic mail because the provider will incur a

24 per-usage cost while he is most likely charging his

93

1 customer a flat monthly rate.

2 Even though modern electronic mail uses

a

3 direct sender to receive transfer protocol, InterNet

4 access providers often revert to the old store and

5 forward approach in order to provide service without

6 incurring per-use costs from the telephone company.

If

7 an end user wishes to serve information to the

InterNet

8 from his home computer, an economy which bills per

9 minute does not work. When the access provider's

10 router receives packets from the InterNet destined

for

11 the end user, the end user's computer and the

12 information he means to publicly serve are simply

not

13 available. If the end user wishes to be available, he

14 must set his router so that a call is always

connected

15 regardless of whether or not data is flowing.

16 In a flat rate ISDN telephone economy,

it

17 costs the InterNet access provider nothing extra to

18 originate calls to an end user when requests from

the

19 InterNet are made to the user. Calls can be set up

on

20 request in either direction and terminated minutes

21 after the data flow stops. A virtual data connection

22 will not consume switching channels when no data

is

23 actually flowing. I believe this scheme actually uses

24 less of a telephone company's resources than a

scheme

94

1 which bills for time.

2 And ISDN is really a pretty reasonable

3 approach for an information server when you

compare it

4 something to switch 56 which at least over a few

years

5 ago cost a lot extra in terms of the routing hardware

6 and installation and monthly. And it's twice the

band

7 width of switch 56. And it still is about a fifth of

8 the cost of a -- I mean, ISDN is still about a fifth of

9 the cost of a T1 trunk. But it's not real peachy yet.

10 Thank you.

11 THE HEARING EXAMINER: Thank

you,

12 Mr. Dickson.

13 Further comment from Bell Atlantic?

14 MS. GAGHAN: Well, I guess just one

15 comment I might like to make about the uses of

public

16 switch network services such as the final telephone

17 network or ISDN. They're designed to provide

broad

18 conductivity to a large number of customers and

with

19 the cost of those services shared over a broad

number

20 of people. And we engineer our network so that

any

21 given facility is shared by multiple people. And

that

22 helps drive the cost down because you don't have a

23 one-to-one relationship in the service network with

24 every user that might want to take advantage of the

95

1 service.

2 In our voice network, we engineer eight

3 individuals to share a single facility through the

4 network. And for ISDN, for residential service, we

5 engineer it four to one. And we deploy facilities to

6 support that kind of usage of the network and we

price

7 it to cover the costs of those facilities necessary to

8 support it.

9 And whenever any individual or group

of

10 individuals use the facilities beyond how they've

been

11 engineered, they're basically taking those facilities

12 out of the mix for other people to get access to

which

13 more quickly escalates when we'd have to add

additional

14 equipment and very quickly you're getting to a

point

15 where it's a one-to-one relationship between users

and

16 network facilities, which is essentially a private-line

17 network. And that becomes very cost-prohibitive

for

18 individuals of moderate levels of usage that may

like

19 to take advantage of the feature benefits of a service

20 like ISDN or the analogue voice network, but they

just

21 can't afford it if it's being -- the network's being

22 engineered to be shared on a one-to-one basis for

23 individuals that want to use it all day long. It

24 really sounds like if you need that 24-hour a day

96

1 conductivity, that is a -- you're basically saying you

2 need a facility that's only available for your use that

3 nobody else can share because you need it tied up all

4 day for you. And that's really not what public

switch

5 network services are designed to do.

6 So there are crossover points at which

7 the volume is so substantial that a public switch

8 network is just cost-prohibitive and then you would

9 typically migrate to something else.

10 And when we set our pricing for ISDN,

we

11 drove that base down to 19.50 to the lowest that we

12 could reasonably do to cover our costs and then

charged

13 on a metered basis until we could gather more

market

14 and usage intelligence so that we could then set

other

15 packages out there that would give volume breaks

to

16 people based on their needs without jumping right

to a

17 flat rate of a certain amount which would then

18 automatically put everybody who used a volume

less than

19 that would cover at a disadvantage and basically

paying

20 for the folks who exceeded that volume level.

21 So when we went out in our initial

22 offering, we wanted to have it so that you paid for

23 exactly what you used and as we learn more about

the

24 requirements, we want to offer other things that

would

97

1 perhaps better suit your requirements on the

2 high-volume end. But for an initial offering, we

3 didn't want to discriminate against the smaller guys

at

4 the expense of the very high-volume folks who do

have

5 other service options available, albeit they're a

6 little more expensive, but they're more in keeping

with

7 the kind of usage of the network and the types of

8 facilities that are being provided which are very high

9 value. One hundred twenty kilobits of data speed is

10 pretty nice for a public switch service. And with a

11 digital quality, you get quite nice results.

12 MR. DICKSON: Okay. Right now I'm

more

13 of a line hog than I need to be. I'm keeping pretty

14 good records of my usage and my peak hours are

probably

15 after midnight. My only real low dip is about 5

a.m.

16 And I think the weekdays are pretty, you know,

moderate

17 and I think things go up really after business hours.

18 MS. GAGHAN: Just a question if you

19 don't mind. Are you currently a user of our

business

20 ISDN service? It sounded like --

21 MR. DICKSON: Residential.

22 MS. GAGHAN: Because at most, you

would

23 be paying two cents a minute.

24 MR. DICKSON: Well, my rates just

went

98

1 down when it was -- when the residential rate was

2 informally instituted in November. Okay? My bills

3 were $640 a month and now they're down to about

320.

4 MS. GAGHAN: Okay. I'm also curious.

5 With the ascend pipeline 50 which is a very nice

piece

6 of equipment, if it -- I thought it could be

7 programmed so that it could automatically detect

when a

8 call was being made in or out or when it needed to

make

9 a call out.

10 MR. DICKSON: Except I'm paying a

flat

11 rate to my upstream provider who is Performance

Systems

12 International. They don't -- they don't -- they

13 never call me when packets come from the InterNet

to

14 me. I have to -- I can only connect a call when I

15 call them and I never know when something is

going to

16 be coming back.

17 So if I want to be available on the

18 InterNet, I have to keep the call nailed up all the

19 time. I'm keeping it nailed up the first half hour of

20 every hour and then after that, I assume that packet

21 flow is going to keep it up the rest of the hour.

22 Otherwise, if there's no flow like at five in the

23 morning, the call is down from 5:30 to six.

24 MS. GAGHAN: Okay. So it sounds

like

99

1 you're running like an information server in your

2 home?

3 MR. DICKSON: Yes, ma'am.

4 MS. GAGHAN: Like a little bit where

you

5 publish information?

6 MR. DICKSON: It's not business. It's

7 art. I have specific reasons for doing this. I'm

8 doing experimental interactive art works that I

9 wouldn't ask any information provider to put on his

10 computer. I wouldn't ask him to take the security

risk

11 because I can't guarantee that these applications are

12 bulletproof. Okay?

13 So I need to have my own server in

my own

14 place and have access to it to develop these --

develop

15 these things. I have this relationship with my

public

16 where I need the constant interaction. I'm building

a

17 thing called a regenerative InterNet-driven

18 philosophical engine which is going to make

hopefully

19 some conclusions about the population of the

InterNet.

20 THE HEARING EXAMINER: Okay.

There's

21 another gentleman here. Are you here to make

comments,

22 sir?

23 MR. SHAW: Well, I don't know who is

24 representing who on that panel up here.

100

1 THE HEARING EXAMINER: Well, these

are

2 the representatives from Bell Atlantic and these are

3 the representatives from the Commission and a

4 representative from the Public Advocate.

5 MR. SHAW: All right. I've spoken to

you

6 today. My only interest -- I'm a residential user

7 and --

8 THE HEARING EXAMINER: Please

identify

9 yourself for the record.

10 MR. SHAW: Reggie Shaw.

11 THE HEARING EXAMINER: And your

address?

12 MR. SHAW: You mean my street

address?

13 THE HEARING EXAMINER: Where do

you

14 live?

15 MR. SHAW: Wilmington, Delaware.

16 THE HEARING EXAMINER: Fine.

17 MR. SHAW: And like I said, I'm just a

18 residential user of the InterNet and I've been

19 following the rate tariff conversations on the

20 InterNet. And it just seems like what Bell Atlantic's

21 offering is too expensive for the average consumer.

22 You know, you get a separate line. You're paying

your

23 InterNet service provider about $30, $15 for the line,

24 their meter charge and it can go -- you know, I only

101

1 use it maybe two hours an evening and it would

cost me

2 probably over a hundred dollars a month.

3 MR. DICKSON: Can I --

4 THE HEARING EXAMINER: No. Just a

5 minute. This is being transcribed so it's very

6 difficult if I have two or three people speaking at

7 once. When he gets through.

8 MR. SHAW: No. I'm just concerned

about

9 the rate, you know. I'd like to see it more

10 affordable. Then you'd have -- more people would

be

11 able to use it. That's all.

12 THE HEARING EXAMINER: Thank

you. Do you

13 have anything further?

14 MR. DICKSON: I wanted to correct the

15 record on upstream InterNet access charges for ISDN

16 service. Performance Systems International charges a

17 $500 setup and $250 a month available in three-

month

18 installments for ISDN level service. It's not 20 or

19 $30 a month. That's analogue modem rates that he

was

20 quoting, 20 or $30 a month.

21 MS. GAGHAN: Not for PSI. For a

typical

22 dial-up ISDN user that's just accessing their service

23 using their interramp service which covers ISDN

and

24 their dialogue analogue, they still charge you only

$30

102

1 for 30 hours of use or they have a $9 for 9-hour use

2 package, as well. They're not charging the private

3 line or special rates, unless you're doing something

on

4 a business level where you may need to interact

which

5 might be akin to what your application is. But

normal

6 dial-up use is still only $30 a month.

7 THE HEARING EXAMINER: Is this PSI,

is it

8 a service offered by Bell Atlantic?

9 MS. GAGHAN: No. No. Performance

10 Systems International is an international access

11 provider who has a point of presence in Delaware.

12 THE HEARING EXAMINER: I see.

That's

13 interesting, but not relevant.

14 Yes.

15 MR. SHAW: I'm also concerned about,

I

16 guess, Bell Atlantic, their cost analysis was sealed.

17 It's not open to the public to see it. I mean, how

are

18 we to determine what's fair or not, you know, when

it's

19 under seal?

20 THE HEARING EXAMINER: Would

you like to

21 answer that?

22 MR. SMITH: I'd be happy to. The

Company

23 has an arrangement with the Public Service

Commission

24 and the Office of Public Advocate also has a role in

103

1 the state of Delaware to protect the interests of the

2 consumers. They have access to our proprietary

3 information and they, in fact, have a representative

4 sitting right in front of you whose sole intent is to

5 protect your interests and has access to that

6 information. Unfortunately, we can't provide that

7 information to every member of the public because it

8 is, in fact, proprietary to our business. And since it

9 is a competitive service, it just wouldn't be the right

10 thing for our business to do to make that available

to

11 just anybody.

12 MR. SHAW: How's it competitive?

Who

13 else is offering ISDN besides yourself?

14 MR. SMITH: ISDN-like services are

15 available through other vendors, which we were just

16 talking about PSI. There are a number of them in

17 Delaware. I forget the count. Twenty-eight?

18 MS. GAGHAN: Yes.

19 THE HEARING EXAMINER: Well, just

to

20 confirm that the Commission does have access to

this

21 information as does the Public Advocate. But the

law

22 also requires that a private company has -- there's

23 certain information that is proprietary that they

have

24 the right to keep it under seal and the law provides

104

1 for that. That's why you have agencies like the

2 Commission and the Public Advocate to try to

protect

3 the interests of private consumers, of residential

4 consumers, in fact.

5 MR. SHAW: Well, I haven't heard any

of

6 their recommendations on whether they think it's a

fair

7 proposal or not, you know.

8 THE HEARING EXAMINER: Well, Mr.

Barua is

9 here.

10 MR. BARUA: We're still investigating

11 this filing, and at the appropriate time of hearings,

12 eventually, we'll be collecting more information and

at

13 that time we'll formulate our position. But you are

14 welcome to, you know, stop by our office and

discuss

15 with the Public Advocate your concerns.

16 MR. SHAW: Was this advertised in the

17 paper, this meeting tonight?

18 THE HEARING EXAMINER: Yes, it

was.

19 If there's nothing further, then we will

20 adjourn. There will be an evidentiary hearing on

21 March 29th, right, here on the third floor conference

22 room B beginning at 9:30. Members of the public

may

23 attend. They may not, of course, participate, but

they

24 may attend and hear the positions of the Public

105

1 Advocate as well as the Commission Staff and the

2 Company on the issues involved in ISDN service.

3 Thank you very much for participating.

I

4 wish there had been more because it's many times

when

5 we have these public input sessions, it affords all of

6 the parties to hear how the public feels about a

7 particular utility's service and that way all of the

8 parties have an opportunity to modify whatever

9 positions they have taken on these issues. And your

10 comments have been very constructive and, as I

said,

11 they will be relayed to the Commission when it

comes

12 time for a final decision. Thank you.

13 (The hearing was concluded at 7:30

p.m.)

14 - - - - -

106

C E R T I F I C A T E

ANNETTE PACHECO,

14 Notary Public-Reporter

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