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Re: CPT on FCC universal service proceeding (fwd)

  James Love wrote:
  > -----------------------------------------------------------------
  > TAP-INFO - An Internet newsletter available from listproc@tap.org
  > -----------------------------------------------------------------
  > INFORMATION POLICY NOTE - Universal Service Proceeding
  > April 12, 1996
  >                        Before the
  >                   Washington, D.C.  20554
  > ___________________________________
  >                                    )
  > COMMENTS ON FEDERAL                )
  > UNIVERSAL SERVICE                  )
  > NOTICE OF PROPOSED RULEMAKING      )  CC Docket No. 96-45
  > AND ORDER ESTABLISHING             )
  > JOINT BOARD                        )  FCC  96-93
  >                                    )
  > To: Chief, Common Carrier Bureau   )
  > ___________________________________)
  Very interesting and well thought-out comments, although I personally 
  don't agree 100%....
  It is clear that deregulation artifacts such as the CCL are 
  inappropriate and illogical. They encourage inefficiency of the RBOCs by 
  awarding a revenue flow totally without cost basis.  That is to say, 
  there is essentially no per-minute cost associated with the routing of a 
  call to an IEC, all the costs are related to fixed capital investment 
  which would logically be recovered on a per/line/per/month basis.  The 
  CCL is a "skim."  Whenever an entity receives a flow of income which has 
  no costs associated with it's production, incentive to increase 
  efficiency is reduced.  And there are many such "entitlements" in the 
  Common Carrier rate structure which undermine effective operation of 
  market forces.
  The same regulatory mindset is apparent in the ISDN tariffs:  the LECs 
  have a capability of current value, and they want to squeeze as much 
  revenue as they can from it.  This is reasonable.  However, the crux of 
  the problem is that ISDN is not as valuable as they believe; if it were, 
  there would be 80-90% penetration by now.  The reality of the situation 
  is that the LECs have let their oligopolistic heritage cloud their 
  thinking in this competitive marketplace.  They can't make service/rate 
  decisions for next week based on market research done by BTL a decade 
  ago.....it doesn't hold up to public scrutiny and expectation.
  Well, I feel better now that that's off my mind!
  Keep up the good fight, Jamie!
  Bob Monaco