----------------------------------------------------------------- TAP-INFO - An Internet newsletter available from listproc@tap.org ----------------------------------------------------------------- INFORMATION POLICY NOTES January 11, 1995 - On December 1, 1995, the staff of the Virginia Corporations Commission asked for a investigation into Bell Atlantic's costs of providing residential ISDN service. The Staff emphasized the importance of ISDN in giving Virginia consumers higher speed access to the Internet, and the Staff asked the Corporations Commission to consider a flat rate tariff. - On January 11, 1996, the CPT wrote the Virginia Commission, providing support for the investigation. A decision is expected soon. A copy of the CPT letter follows. - Consumers can write or fax the Virginia Commission as follows: Virginia State Corporation Commission, P.O. Box 1197, Richmond VA 23209 voice:804/371-9101;fax:804/371-9069 attn:Kathleen Cummings - The CPT Web page on ISDN tariffs has been spruced up a bit. It is available at http://www.essential.org/cpt/isdn/isdn.html the CPT letter follows. jamie (love@tap.org, 202-387-8030) BEFORE THE COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION Ex Parte, In re: Investigation of the pricing and provisioning of residential Integrated Services Case No. PUC950078 Digital Network offered by Bell Atlantic-Virginia, Inc. Comments of the Consumer Project on Technology in Support of the Commission Staff's Motion to Initiate Investigation The Consumer Project on Technology (CPT) was created by Ralph Nader in 1995 to represent the rights of consumers in the area of telecommunications and other issues. A more detailed description of CPT can be found on the Internet, at http://www.essential.org/cpt. We are active in efforts to prevent local exchange telephone companies from charging excessive prices for residential ISDN services. Like a growing number of consumers, telecommuncations experts and firms in the computer and telecommunications field, we believe that regulators have a important opportunity to vastly enhance public access to the information superhighway by insuring that residential ISDN services are widely deployed at reasonable prices. We applaud the Commission Staff's suggestion that there be an investigation into the ISDN rates proposed by Bell Atlantic-Virginia, Inc. ("BA"). We believe this is an important matter for the Commission to address for several reasons. - BA's proposed rates are not just and reasonable and due to the hefty prices, few Viriginia consumers will enjoy the benefits of high speed ISDN connections to the Internet. Indeed, because BA proposes to charge Virigina consumers for every minute they are using their ISDN connections, including every minute of local telephone calls, the service will be extremely expensive. Under the proposed BA tariff, 100 hours of ISDN use (when the full 128 Kbps is used), will cost consumers from $150 to $270 per month -- for calls in the local service area. We estimate that it will cost BA less than $20 per month to provide the service. - There are very important public policy reasons to get the pricing of ISDN technology correct. ISDN provides a potential "open platform" for a whole new generation of information services, delivered over the Internet's World Wide Web or in other ways. But this won't happen unless ISDN is priced as a mass market service. - There is tremendous consumer opposition to tariffs that rely upon per minute charges. Flat rate tariffs will encourage more network usage, which is more efficient, given the large fixed costs of the network. - The Commission staff and intervenors should be allowed to examine BA's costs, to determine a just and reasonable ISDN tariff. The CPT is prepared to present expert witnesses on the topic of BA costs of providing the service. - On January 9, 1996, the Washington State Utilities and Transportation Commission (WUTC) rejected a proposed US WEST ISDN tariff in order to give consumers, computer and software companies, and the online community a better opportunity to review the tariff. The WUTC allowed consumers to submit comments on the tariff by electronic mail. We urge the Commission to provide a similar opportunity for Virginia consumers. We would be happy to provide the Commission with assistance in setting up a system for doing so. - On December 12, 1995, the Washington DC Public Service Commission staff recommended that the BA ISDN tariff be set at a flat rate of $32 per month, with an installation charge of $34.50 (no per minute usage charges). This is far less than the tariff proposed by BA. In recommending the $32 flat rate tariff, the Washington DC PSC Staff noted that it was seeking to promote enhanced access to the information superhighway for Washington DC residents. We further recommend that the Commission consider a novel approach to the issue of ISDN tariffs. Specifically, we recommend that the Commission contact all BA region Commissions, to suggest that they undertake a joint investigation into the pricing of BA's ISDN service. Ideally, a single Administrative Law Judge (ALJ) could be appointed for all BA states, to conduct a unified discovery process, and to make initial recommendations, which could be adopted or modified by each individual commission. This has been done in some oil pipeline cases, to lower the cost of investigating just and reasonable tariffs. January 11, 1996 James Love Director, Consumer Project on Technology P.O. Box 19367, Washington, DC 20036 love@tap.org; http://www.essential.org/cpt 202/387-8030; fax 202/234-5176 Also, resident of Virigina (5900 N 5th Street, Arlington, VA 22203), Bell Atlantic consumer and sometimes telecommuter Todd Paglia Attorney, Consumer Project on Technology P.O. Box 19367, Washington, DC 20036 tpaglia@tap.org; http://www.essential.org/cpt 202/387-8030; fax 202/234-5176 +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ INFORMATION POLICY NOTES is a free Internet newsletter sponsored by the Taxpayer Assets Project (TAP) and the Consumer Project on Technology (CPT). Both groups are projects of the Center for Study of Responsive Law, which is run by Ralph Nader. The LISTPROC services are provide by Essential Information. Archives of TAP-INFO are available from http://www.essential.org/listproc/tap-info/ TAP and CPT both have Internet Web pages. http://www.tap.org/tap http://www.essential.org/cpt Subscription requests to tap-info to listproc@tap.org with the message: subscribe tap-info your name TAP and CPT can both be reached off the net at P.O. Box 19367, Washington, DC 20036, Voice: 202/387-8030; Fax: 202/234-5176 +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++