Date: Thu, 11 Jan 1996 20:32:22 -0500 (EST)
From: James Love 
To: Multiple recipients of list 
Subject: CPT to Virginia Corporations Commission on BA ISDN tariffs (fwd)

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

BEFORE THE COMMONWEALTH OF VIRGINIA 
STATE CORPORATION COMMISSION


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
                         Investigation

     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

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
INFORMATION POLICY NOTES is a free Internet newsletter sponsored
by the Taxpayer Assets Project (TAP) and the Consumer Project on
Technology (CPT).  Both groups are projects of the Center for
Study of Responsive Law, which is run by Ralph Nader.  The
LISTPROC services are provide by Essential Information.  Archives
of TAP-INFO are available from

http://www.essential.org/listproc/tap-info/

TAP and CPT both have Internet Web pages.

http://www.tap.org/tap
http://www.essential.org/cpt

Subscription requests to tap-info to listproc@tap.org with
the message:  subscribe tap-info your name

TAP and CPT can both be reached off the net at P.O. Box 19367,
Washington, DC  20036, Voice:  202/387-8030; Fax: 202/234-5176
+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++