Washington

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

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TAP-INFO - An Internet newsletter available from listproc@tap.org
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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