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CPT to Virginia Corporations Commission on BA ISDN tariffs (fwd)

  TAP-INFO - An Internet newsletter available from listproc@tap.org
  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)
  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
       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
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