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Fred Goldstein critique of Bell Atlantic ISDN Cost Studies



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Info-Policy-Notes - A newsletter available from listproc@tap.org
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INFORMATION POLICY NOTES
November 11, 1996

        This is Fred Goldstein's testimony to the Maryland Public Services
Commission on the ISDN tariff.  It contains a devastating critique of the
Bell Atlantic cost study for ISDN pricing. It is rather technical, but I
am posting it because of the importance of the critique of the Bell
Atlantic's statements regarding the Interent and network congestion. 

I am leaving for India tonight, and will not be back in the office until
November 20.  jamie


           BEFORE THE MARYLAND PUBLIC SERVICES COMMISSION

								
In the Matter of the Residential   )
Intellilinq BRI Service Offering   )    Case 8730
of Bell Atlantic, Maryland, Inc.   )


              REBUTTAL TESTIMONY OF FRED GOLDSTEIN
          ON BEHALF OF CONSUMER PROJECT ON TECHNOLOGY

November 5, 1996


PREPARED REBUTTAL TESTIMONY OF FRED GOLDSTEIN

	Q1.	Please state your name and business address, and 
summarize your professional qualifications.

A1.	My name is Fred Goldstein.  I am a Senior Consultant 
at BBN Corporation.  This testimony does not represent an 
official position of BBN Corporation.  It is prepared on 
behalf of the Center for the Study of Responsive Law's 
Consumer Project on Technology.  My business address is at BBN 
Corp., 50 Moulton St., Cambridge MA 02138.  I have worked in 
the telecommunications and data network field since 1977.  My
experience with ISDN dates back to 1985 when I became Digital 
Equipment Corporation's voting member of ANSI-accredited 
Technical Subcommittee T1D1 (later T1S1), which was 
responsible for producing North American ISDN standards.  I am 
the author of the book "ISDN In Perspective" (Reading MA:
Addison-Wesley, 1992) and have taught courses on ISDN for 
Northeastern University and National Technological University.  
I have also been a technical leader in BBN's ISDN acitivities 
as an Internet Service Provider. I hold three patents in the 
area of Broadband ISDN and Asynchronous Transfer Mode 
congestion management and switching.


	Q2. 	What is your opinion of the Bell Atlantic analysis 
used to support its residential tariff?

A2. 	The first testimony is that of Stephen A Reisinger 
[REIS].  The gist of this testimony seems to be that Internet 
Service Providers place a high load on the network, 
particularly when they use analog ports.  This is not even on 
point to Case 8730 concerning Residential ISDN rates, except 
by inference.  Reisinger begins [REIS at p. 2/ line  21] by 
stating that "far fewer R-ISDN lines can be accommodated on 
equivalent pieces of equipment."  This would imply that higher 
monthly recurring charges (MRCs) should be applied to ISDN.  
That ISDN MRCs are higher than analog MRCs are not in dispute; 
the application of measured-service charges to R-ISDN is in 
dispute.

	Reisinger then analyzes the incoming traffic to Internet 
Service Providers, none of whom are eligible for R-ISDN 
tariffs.  He points out congestion that occurs at Central 
Offices that receive calls.  These lines generate essentially 
zero calls.  In his attached Report to the FCC calling for 
higher charges to be placed on ISPs, he requests that ISPs 
bear a large multiple of the cost of the additional traffic 
generated by users calling them.  Yet the conclusion he is 
attempting to draw in Case 8730 is that R-ISDN rates should be 
metered at a contributory level in order to pay for the same 
thing.

	His examples are particularly off point.  They mostly 
concern analog dial-in ports to ISPs. The first example, 
Myersville, had 127 analog lines.  The second, Herndon, had 
1131 analog lines. Residential ISDN subscribers can not 
generally call analog lines!  They generally call ISPs who use 
ISDN PRI, which does not use any line unit, or sometimes BRI, 
which does not use the analog line unit.  In fact, his 
arguments are for increased migration to ISDN.  An analog line 
unit on a 5ESS has a maximum capacity of 512 lines and 64 time 
slots, or about 3.8 CCS/line if filled [REIS at 11/16].   But 
ISDN Line Units on a 5ESS have up to 256 time slots [REIS at 
13/footnote 8] to serve up to 512 Basic Rate lines, which can 
have up to 1024 B channels.  

	He states that a load of 8.6 CCS/line will limit an ISLU 
to 448 lines.  This would not be serious even if it were true, 
but it does not add up.  A full ISLU with 512 lines at 8.6 
CCS/line generates 4403 CCS.  From the Poisson table, this can 
be served by 149 time slots at P.01 blocking.   This is well 
below the 256 time slot limit. 

	Also, the 8.6 CCS/line number is derived from ISDN 
experience which is primarily Centrex.  Bell Atlantic actively 
markets ISDN Centrex as a service that provides unlimited 
calling within the Centrex group.  This invites users to 
"nail" channels.  Any tariff that does not provide totally 
unlimited usage will discourage nailed usage.  Since Centrex 
costs substantially less than Bell Atlantic's proposed rate 
for ISDN BRI with unlimited use ($249/month), users who plan 
to "nail" ISDN lines are likely to use their ISP's Centrex 
service, not R-ISDN.  Indeed the testimony of Curt Koeppen 
[KOEP] seems to contradict Reisinger, where it says, "The 
typical customer spends an average of 10-40 hours per month 
on-line."[KOEP at 5/13]  While this cannot be directly 
translated to CCS, it is in line with typical voice usage 
patterns, not ISDN Centrex.

	Given that the ISDN line unit has such greater capacity 
than the analog line unit, it becomes clear that high-traffic 
data users should be encouraged to migrate to ISDN.  Further, 
since analog dial-in traffic costs far more than PRI dial-in 
traffic (estimated by Reisinger at $50/month/channel vs. 
$75/month/channel), ISDN potentially reduces costs at both 
ends of the connection!  

	Reisinger also argues that ISDN incurs costs by requiring 
the installation of 64 kbit/sec clear-channel trunks, compared 
to "56 kb/s trunk" facilities used for voice.  While much of 
the embedded base of trunk facilities is not 64 kbit/sec 
"clear", most new facilities are.  Also, Bell Atlantic 
proposes charging the same usage rates for calls placed on 
older facilities, which can use either the speech/audio bearer 
capability or the 56 kbps data bearer capability.
A particularly bad scare tactic occurs in Reisinger's 
testimony about 911 service [REIS at 16/23].  He supposes that 
911 calls would be blocked if 64 analog users simultaneously 
nailed up calls on the same line unit.  Given a small 
percentage of "nailed" users, this is, of course, extremely 
improbable!  But it would be even more vanishingly improbable 
on an ISDN line unit, with its larger number of time slots.
It should be pointed out that the DMS-100 switch has even more 
favorable ISDN traffic characteristics.  An older-style 
analog-only Line Concentration Module (LCM) has 640 one-line 
card slots sharing a maximum of 180 time slots, assigned 30 at 
a time.  An ISDN-capable LCME has 480 card slots sharing a 
maximum of 480 time slots.  This allows non-blocking use of 
one B channel at a time, or approximately 34 CCS/line total.
Robert Terry's testimony is not quantitative; it simply 
asserts that ISDN should be regulated as discretionary.  But 
he notes that "existing demand for ISDN service is less than 
1% of BA-MD's total customer base and is forecast to be about 
3% by the end of the decade."  This is a self-fulfilling 
prophecy.  Higher penetration rates have already been achieved 
in Germany.  BA-MD's application of measured rates to R-ISDN 
will dramatically suppress demand.

	The testimony of John Pehta [PEHT] demonstrates various 
reasons why the MRC of R-ISDN is higher than the MRC of POTS.  
This is undeniable; however, it does not affect usage costs.  
He notes that data calls have an average holding time of 20 
minutes [PEHT at 13/15], but this is meaningless:  The  
average CCS and average monthly hours of use are what consume 
traffic capacity.  Data calls may be on average longer but 
they are fewer in number, and thus incur lower  call setup 
costs (including processor usage and Signaling System 7 
network utilization).  He then states, "Because of the 
expected additional usage per line for R-ISDN customers, the 
average concentration ratio for a switch is expected to be 4 
to 1 which allows for a switching module/line unit to provide 
service to only 256 customers."  This is based on having 64 
time slots per line unit, which is the case for analog line 
units on a 5ESS.  ISDN line units have up to 256 time slots.  
And the situation on the DMS-100 is even more favorable.
He then states that concentration ratios will "move closer to 
1 to 1" [PETH at 14 /10], which implies an average ISDN usage 
of over 500 hours/month.  This is more than an order of 
magnitude above Bell Atlantic's own estimates [KOEP at 5/13].  
He then says that one ISDN switching module/line unit has 64 
time slots, contradicting Reisinger's testimony.  Again the 
problems he ascribes to ISDN users are in fact problems caused 
by analog data users.

	The net cost per minute of an ISDN data call, which I did 
not see because it is expurgated, is perhaps higher than the 
cost per minute of an ISDN voice call, due to the use of newer 
trunks.  However, it is probably lower than the cost of an 
analog voice or voiceband data call, because it avoids the 
analog line units.  The Reisinger-written Report to the FCC 
[BELL] states that an analog ISP port costs $75/month for its 
traffic load, versus $50/month for a PRI channel, with an 
average load of 608 minutes per day.  This translates to 
$.0041 per minute for analog usage vs. $.0028 for PRI audio-
bearer usage.  

	Curt Koeppen's testimony[KOEP] seemingly seeks to 
contradict the other testimonies.  He tries to show that Bell 
Atlantic's proposed tariff is really quite low.  This follows 
from his assertion that the typical user's volume is quite 
low.  This low volume usage is in fact consistent with other 
telco's experiences.  Pacific Bell, for instance, cites in its 
current ISDN filing before the California PUC (docket A.95-12-
043) requesting a cap on off-peak hour unlimited usage) an 
average usage of 47 hours/month, which includes some 
percentage of "nailed" users and a majority of users 
originating under 20 hours/month.  This is the result of a 
tariff that has unlimited usage except on Monday to Friday 
from 8 AM to 5 PM.  He also cites average Internet and on-line 
service usage studies in the range of 9.9 to 47.3 hours per 
month, and says Bell Atlantic's own studies "show that typical 
residential Internet/On-line usage is only 10 to 40 hours per 
month" [KOEP at 27].  If this is the case, then why all the 
fuss about high traffic levels?

	Koeppen cites the recent Bell South filing [KOEP at 38/11] 
which caps "flat" rate at 200 hours per month, with 1 cent per 
overtime minute, as a means to discourage "nailed" users.  
Bell Atlantic certainly could use a similar mechanism to 
achieve nearly-flat rates for R-ISDN.  This would be more 
palatable to the residential market.  Indeed the Maryland 
public is so displeased with the possibility of mandatory 
measured service that legislation was passed to outlaw it.  
Under Bell Atlantic's proposal, then, users wanting flat rate 
or even nearly-flat-rate service would be encouraged to use 
analog lines. 

	Koeppen also uses unsound reasoning in developing 
contribution margins.  He states, "in deriving our margin 
above direct costs, our cost calculation for usage included 
only 90% utilization of the package usage allotment."[KOEP at 
37/6]  Thus someone who subscribes to the 60-hour package is 
expected to use 54 hours.  This is clearly not valid.  
Subscribers generally do not know ahead of time their exact 
calling patterns, and Bell Atlantic's proposed rate structure 
gives positive incentives to buy a larger than necessary 
Callpack, because the overtime rate does not decline with 
usage.  Thus a 35-hour user might be better off with a 60-hour 
Callpack, as 15 hours at 2c/minute costs $18/month, versus a 
$14 marginal cost for Callpack 60 over Callpack 20.   A 90-
hour user will be better off with Callpack 140 than with 
Callpack 60, even if all usage is off peak, as the former 
would cost $60 and the latter ($45+60*.01*30=) $63.   Thus the 
average Callpack will be much less than 90% utilized.  
Experience also shows that residential users favor 
predictable, "flat" rates over measured rates, even if the 
latter are slightly lower.  This will cause residential users 
to favor analog over ISDN, Centrex ISDN over R-ISDN, and 
larger Callpacks over "optimal" Callpacks that have a risk of 
overtime.

	Q3.	Does this conclude your testimony?
	A3.	Yes.

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