Glenn Blackmon of the WUTC announced on Jan 9th that US West's
proposal to triple ISDN rates in Washington has been denied.
The WUTC website
is a great example of government opening itself
for free public access via the internet. They even posted
Intel's protest and the comments received from the public!
Subject: Washington State ISDN Update
Date: Wed, 28 Feb 1996 15:27:16 -0500 (EST)
From: James Love
Reply-To: love@essential.org
To: Multiple recipients of list
According to the Washington State WUTC, US West filed a new tariff on last
Friday. " Yesterday the Commission rejected the filing because the company
had not provided the proper supporting documentation (cost studies) with
the filing."
The WUTC staff expects a new filing soon. I was told that the rejected
tariff included two proposals, one for $35 per month and one for $63,
with, I suppose, a metered usage charge (what it was wasn't clear). The
$63 tariff has an "allowance" for 200 hours of B channel usage (would be
100 hours if using both B channels). Apparently about $15 per month
more in rural areas.
jamie
From: Glenn Blackmon
Newsgroups: seattle.general,comp.dcom.isdn
Subject: WUTC denies increase in US West ISDN rate
Date: 9 Jan 1996 00:36:45 GMT
Organization: Washington Utilities & Transportation Commission
The Washington Utilities and Transportation Commission today decided
not to consider a request by US West to increase and restructure its
rates for ISDN service in Washington State.
Intel Corporation and an internet trade group, Commercial Internet
Exchange Association, had asked to intervene in US West's general rate
case (Docket No. UT-950200), in which US West had made its ISDN rate
proposals. For unlimited service, US West proposed to increase the
rate from $63 to $184 per month, a 200% increase. Customers using 200
hours of service per month would have paid $69. Other parties in the
case had testified that the existing $63 rate should be lowered.
The effect of the commission's decision is that no change will be made
in the current ISDN rate until US West files a new tariff for this
service and that tariff is considered by the commission.
The commission has been taking public comment on the ISDN issue since
Intel's petition was filed on Dec. 28. The e-mail address for those
comments is isdn@wutc.wa.gov.
A written order denying the ISDN rate increase will be posted on the
WUTC's web site (URL listed below) as soon as it becomes available.
Glenn Blackmon
Washington Utilities and Transportation Commission
http://www.washington.edu/wutc/
Date: Sun, 7 Jan 1996 01:42:50 -0500 (EST)
From: James Love
To: Multiple recipients of list
Subject: CPT on Intel's motion in WA ISDN case
here is what we filed the WA State ISDN proceeding in response to Intel's
motion to intervene on the notice issue. jamie (love@tap.org, 202/387-8030)
BEFORE THE WASHINGTON UTILITIES
AND TRANSPORTATION COMMISSION
WASHINGTON UTILITIES AND )
TRANSPORTATION COMMISSION ) Docket No. UT-950200
)
Complainant, )
)
v. )
)
US WEST COMMUNICATIONS, INC., )
Respondent. )
CONSUMER PROJECT ON TECHNOLOGY'S LIMITED INTERVENTION
TO RESPOND TO INTEL'S MOTION FOR CONTINUANCE/DEFERRAL
OF US WEST'S ISDN RATE INCREASE PROPOSAL
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 our organization 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 persons 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 recently learned that US WEST has pending before the
Commission a proposal to revise its current flat rate ISDN tariff
of $63 per month, and that the residential flat rate option would
be increase to $184 per month. We believe the rate increase is
excessive and would stifle deployment of ISDN services. ISDN is
an important technology representing the next step in the
evolution of the information superhighway, and US West's proposal
would prevent ISDN from reaching its potential in opening up new
services and telecommunication advances on the Internet.
In addition to the grossly overpriced rate proposal, US
West's tariff suffers from procedural irregularities. US West
failed to provide proper public notice of the ISDN rate proposal.
As a regulated public utility that wields enormous monopoly
power, and proposes drastic rate increases in important services,
US West should be required to adhere to strict compliance with
public notice obligations.
The public policy issues presented by the pricing of
residential ISDN are extremely important. ISDN is the most
efficient way to provide the general public with immediate
benefits in terms of a cost effective solution to higher speed
access to the Internet. Since residential ISDN can be delivered
over the existing copper wire infrastructure, which consumers
have already paid for, regulators have an opportunity to vastly
enhance public access to the information superhighway to a low
cost. Greater access will result, however, only if US West is
required to price the service in a just and reasonable way.
US West has tried to avoid a separate notice on the ISDN
issue. As a result, many persons who would have considered filing
various types of motions or comments before the Commission on the
residential ISDN tariff issue, never had an opportunity to do so.
Intel's suggestion that the broader computer, software, and
online community be given a real opportunity to comment on and
participate in the proceedings to modify the residential ISDN
tariff correctly identifies these groups as those that are
particularly important stakeholders in this matter.
For these reasons, which are more fully discussed below, we
support Intel's Motion For Continuance/Deferral of US West's ISDN
Rate Increase Proposal.
I. US West's Tariff Proposal is Overpriced
US West's rate increase from a flat rate of $63 per month to
$184 per month is clearly excessive. Several independent studies
on the incremental cost of providing ISDN service conclude that
the costs are much lower than the current US West tariff, and
many times less than the proposed $184 per month.
- A 1993 study by the Tennessee Public Service Commission
(TPSC) staff estimated the incremental cost of providing
ISDN service to be $9.77 (per month), including right-of-way
costs. This study is described in detail in John Borrows'
and William Pollard's "The National Regulatory Research
Institute's Review of Tennessee's Integrated Services
Digital Network Cost Studies," NRRI Quarterly Bulletin, Vol.
15, No. 1, March 1994, pages 125-139. The TPSC approved
flat rate residential ISDN tariffs of $21 to $26 per month.
- In an earlier 1991 study, the Massachusetts Department of
Public Utilities found that the "marginal cost" of ISDN
service was $7.40 (per month) over the cost of POTS service.
- In studies for the Consumer Federation of America, Mark
Cooper has estimated the marginal cost of an ISDN service
(over the cost of POTS) to be $2 to $4 per line (per month),
and falling.
- In an ISDN tariff currently pending before the District of
Columbia Public Service Commission, the PSC Staff has
undercut Bell Atlantic, Washington, D.C., Inc.'s tariff
proposal by recommending a flat rate of $32 per month.
While we believe that even the D.C. Public Service
Commission staff's recommendation is too high, it is more
closely tailored to the real costs that will be incurred in
providing ISDN service than the plainly excessive tariff
submitted by US West. It also demonstrates that far from
entertaining US West's proposed increase, its current ISDN
flat rate of $63 per month should be significantly reduced.
- Local Washington State software developer Bill Gates has
also commented on this issue. In his 1995 book, The Road
Ahead, Gates recommends a residential ISDN tariff of less
than $20 per month. He says:
ISDN was invented more than a decade ago, but
without PC-application demand almost no one
needed it. . . . The [ISDN] line costs vary
by location but are generally about $50 per
month in the United States. I expect this
will drop to less than $20, not much more
than a regular phone connection. We are
among companies working to convince phone
companies all over the world to lower these
charges in order to encourage PC owners to
connect, using ISDN. (page 101).
At present, the Washington US West ISDN flat rate tariff of
$63 per month is roughly four times the cost of POTS. This
tariff is unreasonable. The proposed changes in the tariff would
result in tariffs as high as $184 per month for residential ISDN
service -- more than ten times the cost of POTS. Such a pricing
proposal is a plain abuse of US West's monopoly position and
against the clear weight of the evidence pointing to the
relatively minor expenditures required to provide ISDN service.
The Commission must decide this issue consistent with the
independent studies and expert opinions noted, and encourage the
broad deployment and use of ISDN as the next step in facilitating
development of the information superhighway. To decide otherwise
and approve US West's rate hike would permit an abuse of monopoly
power and unnecessarily stifle development of this important
technology.
II. US West Failed to Comply with Procedural Notice Requirements
In pursuing its radical escalation of ISDN rates, US West
has not complied with mandatory notice requirements. This is a
serious breach in any rate case before the Commission, but it is
particularly egregious here considering the extreme rate increase
sought by a monopoly. The notice requirements of WAC-80-125
applicable to US WEST's 300% proposed ISDN rate increase include
a requirement that US WEST provide to the public a notice which
"shall . . . set forth the amount of the proposed increase
expressed in . . . total dollars and average percentage terms,"
and "shall be prepared in such a manner as to attract attention
to it and to distinguish it from other material simultaneously
distributed. A copy of such statement shall also be mailed or
delivered to one newspaper of general circulation, and at least
one radio station and at least
one television station, in the area or each of the areas
affected. The utility shall promptly file a copy of the
statement with the commission and certify it has complied with or
is in the process of
complying with these mailing and delivery requirements."
US WEST has not complied with any of these requirements with
respect to its proposed 300% ISDN rate increase. The Commission
should not set a precedent that allows a waiver of these
requirements for a monopoly utility, especially in the context of
a proposed 300% rate increase. The important procedural
protections found in WAC-80-125 are in place to protect consumers
from precisely this type of situation. The Commission must not
allow US West subvert the Commission's procedural requirements
and install an outrageous rate increase at the expense of
Washington's consumers.
III. Conclusion.
As noted above, the Consumer Project on Technology fully
supports Intel's request that the Commission order US WEST to
issue the appropriate public notices as required by law, and
defer the hearings on the ISDN issue in this docket, or
investigate and review the proposed ISDN rates in a separate
docket. In addition, we applaud the Commission staff for
establishing a mechanism to receive comments on the Intel motion
to intervene by electronic mail (isdn@wutc.wa.gov).
Date: January 4, 1996
submitted,
Todd J. Paglia, Esq.
Consumer Project on Technology
P.O. Box 19405
Washington, D.C. 20036
voice (202) 387-8030
fax (202) 234-5176
----------------------------------------------------------------------
James Love, love@tap.org
P.O. Box 19367, Washington, DC 20036; v. 202/387-8030; f. 202/234-5176
Consumer Project on Technology; http://www.essential.org/cpt/cpt.html
Taxpayer Assets Project; http://www.essential.org/tap/tap.html
Date: Wed, 3 Jan 1996 10:27:13 -0500 (EST)
To: Multiple recipients of list
Subject: New WUTC mailbox of ISDN commments
---------- Forwarded message ----------
Date: Tue, 02 Jan 96 11:20:00 PST
From: Jeffrey Showman
To: love
Subject: RE: Is the mailbox working?
Dear Mr. Love: Thanks for asking. I am one of the four "webmaster" folks
at the Washington Utilities Commission, and my mailbox is filling up with
ISDN comments. We've created a new mailbox especially for comments in
this case:
ISDN@wutc.wa.gov
I would be most appreciative if you could direct folks to this, thanks.
Excerpted from GovAccess.235:
By JAN 7TH! - Wash State Permits Email re USWEST Proposed 300% ISDN Rate Ripoff
Date: Fri, 29 Dec 1995 17:04:09 -0500 (EST)
From: James Love
To: Multiple recipients of list
Subject: Intel seeks to Intervene in WA USWEST ISDN tariff proceeding
-----------------------------------------------------------------
TAP-INFO - An Internet newsletter available from listproc@tap.org
-----------------------------------------------------------------
INFORMATION POLICY NOTES
December 29, 1995
- Intel files motion to Intervene in Washington State US West ISDN tariff
proceeding, where USWEST seeks $184 residential ISDN tariff.
- Intel asks WUTC to consider greater input from "PC industry
participants and the on-line community"
- Washington Utilities and Transportation Commission (WUTC)
to take comments by email on Intel Motion
send to:
webmaster@wutc.wa.gov
Public Comments must be received by January 8 at 8:30 am.
James Love (love@tap.org, 202/387-8030)
Consumer Project on Technology
December 29, 1995
Today Intel filed a motion to Intervene in the Washington State residential
ISDN tariff proceeding. Intel's motion sought "limited intervention" on the
question of the public notice and timing of the tariff proceeding. USWEST
sought to include a proposed 300 percent increase in its flat rate ISDN
tariff in an ongoing telephone rate proceeding. Intel argues that the
recent addition of the ISDN rate hikes required separate notice for the
ISDN pricing issues, and that the WUTC would benefit from greater
participation by the public, including "PC industry participants and the
on-line community."
<...> [The TAP posting had considerable additional info. --jim]
[Now -- how come Intel, home-based in Californica -- has not filed a
similar howl about Pacific Telephone's proposed 100% increase in
residential and business ISDN rates? --jim]
From: xxxxxxxxxxxxx@xxxxxxxxxxxx.com
Newsgroups: comp.dcom.isdn
Subject: WA: US West To Triple ISDN Rates In Washington State!!
Date: 14 Oct 1995 07:05:36 GMT
Organization: The Silicon Rainforest
ALERT TO ALL WASHINGTON STATE ISDN USERS AND WANNABEES
US WEST has made a rate proposal to the WUTC for increases in ISDN pricing.
They want to TRIPLE the cost of flat rate ISDN. Their new proposed rate would
increase from $63.00 / month (plus interstate subscriber charge and taxes) to
$184.00 / month (etc.).
GTE has also filed a new proposed ISDN tariff. It includes features similar to
the current US West tariff. They intend to charge approximately $72.50 / month
for flat rate services. The earliest it would go into affect would be 12/28/95.
Their tariff includes language which allows them to exclude customers who are
not already within 18,000 feet of a Central Office that supports ISDN. They
want to change 5.50 per mile, per month to customers without a Central Office
(local switch) that supports ISDN.
The GTE ISDN tariff is WN U-17 Section 7. Rates one sheets 87-89.
The US-WEST tarrif is WN U-31 Section 14 - Rates on sheets 18-21.
US West is sending me a copy of the proposed changes, that they presented in a
recent hearing before the WUTC. The changes are not part of the written
general US West rate proposal. The are only available in the minutes from the
hearing. US West is sending me a copy.
You should send your letters of comment, complaint and so on to:
Steve McLellen
Secretary of Washington Utiliities and Transportation Commision
Chandler Plaza Building
1300 Evergreen Park Drive S.
Olympia, WA 98504
For the GTE Filing Reference Docket: UT-951130.
I will get the US WEST docket number soon.
Regards,
Xxxxxxxx Xxxxx
========================
xxxxxxxxxxxxx@xxxxxxxxxxxx.com
Xxxxxxxx Corporation