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NJ ISDN Proceeding
- To: isdn@tap.org
- Subject: NJ ISDN Proceeding
- From: James Love <love@tap.org>
- Date: Mon, 11 Mar 1996 17:50:30 -0500 (EST)
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TAP-INFO - An Internet newsletter available from listproc@tap.org
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INFORMATION POLICY NOTE - NJ ISDN proceeding
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
designed).
- 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:
selaya@pilot.njin.net
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,
R-ISDN-TT-9509453
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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
http://www.essential.org/cpt
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
R-ISDN-TT-9509453
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
LISTPROC@ESSENTIAL.ORG. The CPT Web page is at
http://www.essential.org/cpt.
Sincerely,
Todd Paglia James Love
Staff Attorney Director
tpaglia@tap.org love@tap.org
Attachment: CPT March 8, 1996 Survey of Residential ISDN
tariffs.
Note: The CPT ISDN survey is a available on the Internet at:
http://www.essential.org/cpt/isdn/survey.txt
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