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NJ ISDN Proceeding

  TAP-INFO - An Internet newsletter available from listproc@tap.org
  March 11, 1996
  -    The State of New Jersey agrees to accept comments on Bell
       Atlantic's proposed residential ISDN tariffs by electronic
       mail or by fax.  The NJ Board of Utilities will decide on
       March 13, 1996, if it should review the Bell Atlantic tariff
       filing.  The NJ State ratepayer advocate and several
       consumers have written to ask the Board to require Bell
       Atlantic to provide reasonably priced residential ISDN
       services.  The CPT comments on this are given below.  Bell
       Atlantic's residential ISDN tariffs are among the highest in
       the country.  For example, it would cost more than $1,200
       per month to use a residential ISDN connection for a
       personal Web page server, and about $200 per month for 100
       hours of 2B+D service.  By charging by the minute, and by
       channel (ISDN service can be split into two 64 k channels),
       consumers be discouraged from using the service as it was
  -    In contrast, Ameritech, Bellsouth and Northern Arkansas
       Telephone Company offer flat rate residential ISDN service
       in Arkansas, Illinois, Michigan, Ohio, Tennessee, and
       Wisconsin for $17.90 to $34.50 per month.
  -    Comments on the NJ ISDN case may be sent by electronic mail
       to NJ Board of Public Utilities staffer  Jose A. Selaya, at:
       The fax number for the Board is 201/777-3330.
       You should indicate that your comments are in reference to:
  Bell Atlantic's proposed residential ISDN tariff,
  CPT March 9, 1996 letter to NJ State Board of Public Utilities
  regarding Bell Altantic's proposed residential ISDN tariffs.
                           Consumer Project on Technology
                           P.O. Box 19367, Washington, DC 20036
                           Voice: 202/387-8030
  March 9, 1996
  Herbert Tate, President
  New Jersey Board of Public Utilities
  2 Gateway Center
  Newark, NJ 07102
  RE:  Bell Atlantic's proposed residential ISDN tariff
  Dear Mr. Tate:
       We are writing regarding the Integrated Services Digital
  Network ("ISDN") tariff filed by Bell Atlantic which is on the
  Board of Public Utilities agenda for Wednesday March 13, 1996. 
  The Consumer Project on Technology ("CPT") was created by Ralph
  Nader in 1995 to represent the rights of consumers on
  telecommunications and other technology intensive matters, and we
  have been active in advocating reasonable flat rates for high
  speed Internet access via ISDN.  We believe Bell Atlantic's
  proposed ISDN tariff is exorbitantly priced and will lead to
  limited use of this technology which represents the next step in
  bringing to fruition the promise of the information superhighway. 
  No other service offers ubiquitous high speed Internet access on
  a proven technology.  We urge the Board of Public Utilities to
  hold hearings on the tariff and require Bell Atlantic to offer
  reasonable ISDN rates on a flat rate basis. 
       Bell Atlantic has based its pricing not upon ISDN service
  costs, but on how much they can extract from a handful of
  upper-income users.  As you know, ISDN is delivered to consumers
  over the existing copper wire infrastructure, and most of its
  costs are the fixed sunk costs of the existing local loop.  We
  have never seen an independent study of residential ISDN
  deployment costs that would support as much as $10 per month in
  terms of the incremental cost of the service.  If residential
  ISDN is deployed as a second line, the cost to Bell Atlantic is
  even lower.  Further evidence of the low cost of providing ISDN
  is found in a filing by US West, where the company estimated that
  the non-traffic sensitive cost for an ISDN line is $18.52.  This
  was only $1.18 more than the company's estimate for the cost of
  providing a POTS line. [In the Matter of End User Common Line
  Charges, FCC Docket No. 95-72, Appendix A (filed June 29, 1995)]
       Attached is a survey of various ISDN tariffs which
  demonstrates that other local exchange companies (LECs) that are
  similarly situated to Bell Atlantic have implemented affordable
  ISDN rates. [http://www.essential.org/cpt/isdn/survey.txt] For
  example, in six states, Arkansas, Illinois, Michigan, Ohio,
  Tennessee, and Wisconsin,residential ISDN is available at a flat
  rate for $17.90 to $34.50 per month.  These include tariffs by
  Bellsouth, Ameritech, and Northern Arkansas Telephone Company. 
  Moreover, in the District of Columbia, the Public Service
  Commission is considering an Office of People's Counsel
  recommendation for a flat rate ISDN tariff for Bell Atlantic of
  $32 per month, and the states of Maryland and Virginia have
  written Bell Atlantic requesting that the company file an
  affordable flat rate option.
       In our analysis, we calculated the cost to the consumer of
  using an ISDN line for 100 hours of 2B+D service, or as a full
  time connection, such as if the line was used as a server for a
  home web page.  The Bell Atlantic tariff would cost the consumer
  $198 per month for the 100 hours of service, or $1,206 per month
  for the full time connection.  These rates are clearly excessive,
  and will prevent NJ consumers from benefiting from broader
  deployment of ISDN technology.  In his book, The Road Ahead,
  Microsoft founder Bill Gates says that ISDN is the most important
  here and now technology for getting Americans on the information
  superhighway, and that the LECs should price the service below
  $20 per month, flat rate.[page 101].  At least one LEC, NATCO,
  has deployed the service below $20 per month to residential
  consumers.  Clearly $198 or $1,206 per month, our estimate of the
  cost to various consumers under Bell Atlantic's proposed tariff,
  is unreasonable.
       Someday consumers may have access to alternative methods of
  obtaining fast connections to the Internet.  As you know,
  telephone companies are experimenting with fast ADSL services,
  and cable television companies are experimenting with cable
  modems.  Both of these technologies are promising, yet neither
  are widely available.  Moreover, even under the most optimistic
  deployment scenarios, analysts expect that for large
  portions of the population, ISDN delivered over the existing
  copper wire infrastructure, will be the only available high
  bandwidth connection to the Internet for five to ten years. It is
  important that residential ISDN be priced correctly for those
  consumers who will have to wait many years for the newer and
  still unproven alternatives.  As such, we urge the Board of
  Public Utilities to call hearings and establish a reasonable flat
  rate option for ISDN service. 
       For more information on this topic, the Consumer Project on
  Technology is the sponsor of an Internet discussion list on ISDN
  pricing, and publishes a Web page on the Internet with additional
  information about ISDN and other high bandwidth technologies. 
  The discussion list ISDN is available for subscription from
  Todd Paglia                   James Love
  Staff Attorney                Director
  tpaglia@tap.org               love@tap.org
  Attachment:    CPT March 8, 1996 Survey of Residential ISDN
  Note: The CPT ISDN survey is a available on the Internet at:
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