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000038_isdn-distribution-owner_Wed May 26 04:25:46 1993.msg
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Date: Fri, 14 May 1993 04:40:49 -0400
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From: " (Robert Berger)" <rberger@cerf.net>
Message-ID: <9305140819.AB05423@nic.cerf.net>
To: isdn@list.prime.com, isdn@teknologi.agderforskning.no
Subject: Final Version: Letter to CA PUC concerning PRI Tariff
X-Sender: rberger@nic.cerf.net
X-Attachments: :System & Development Disk:3145:PRI PUC Complaint.txt:
Attached is the final version of the letter to the California Public
Utilities Commission concerning the current Primary Rate Interface tariff.
Though this is somewhat California specific, I suspect that the other
Regional Bells are in similar places and people there should look into it.
People on the list outside of the US may be interested in seeing some of
the details of how the US is far behind much of the rest of the world in
terms of ISDN deployment and promotion.
I have tweaked the text, added a paragraph describing what the Internet is
(its hard in single paragraph!) and most importantly corrected the T1
pricing which is now a bit lower than the original posting. Also attached
is a list of people who have been CC'd.
I encourage everyone who has an interest in seeing ISDN succeed, to add
their voice to this and other issues around ISDN tariffing. I have found
the Pacific Bell folks very receptive. The current tariff is from 1989 or
so and was designed in the context of the PBX voice marketplace and little
understanding of the Data applications. Sam Ramani, the Pacific Bell PRI
product manager is working to improve the PRI tariff. The most immediate
change will be a request for a provisional tariff that will mostly lower
the installation costs. This will be placed on the PUC agenda very shortly.
They are also working on a brand new PRI tariff to be introduced to the PUC
by October that will bring the PRI installation and monthly costs into line
both in terms of BRIs and IXC competition.
The phone number for Robert Feraru, Public Advisor at the PUC is:
415-703-2074, FAX: 415-703-1758 if you would like to give your input.
The Chair of the Utilities and Commerce of the California Assembly is Gwen
Moore acn can be contacted at 916-445-8800, FAX: 916-324-6862.
Robert J. Berger
InterNex Information Services
935 College Ave. Menlo Park, CA 94025
Voice: 415-327-6038 FAX: 415-327-6416
Internet: rberger@cerf.net
InterNex
Information Services
935 College Avenue
Menlo Park, California USA 94025
Voice: 415-327-6038 FAX: 415-327-6416
Internet: rberger@cerf.net
Mr. Jack Leutza
Chief, Telecommunications Branch, CACD
California Public Utilities Commission
505 Van Ness Avenue Room 3203
San Francisco, CA 94102
Dear Mr. Leutza:
InterNex is a new company formed to offer Internet access to individuals and
small businesses via ISDN. The combination of low cost ISDN connectivity and the
Internet could become a key mechanism in providing information infrastructure
that will enable a whole range of new businesses and thus new jobs.
Our service will provide One-Stop-Shopping for non-technical customers. We will
supply the Terminal Adapters, NT1, software and even resell the ISDN BRI line
for Pacific Bell. Thus the customer does not have to be the system integrator.
InterNex would then supply a dialup gateway that allows the customers to access
the Internet with the bandwidth of 1 or 2 B channels.
The Internet is a worldwide network of networks that share a common IP protocol
and a wide range of information services. With over 1.3 million nodes and 13
million users, the Internet is quickly emerging as the network to be connected
to if you are involved with education, technology, communications or virtual
corporations. Internet connectivity to individuals and small businesses looks to
be a killer app that will drive ISDN demand as ISDN offers 10x the bandwidth of
the conventional analog phone line.
Unfortunately, the current tariffs are acting as roadblocks to making such a
service viable. There are currently no economies of scale that would allow us to
offer an affordable service. For our service to be successful, we need to be
able to support hundreds to thousands of simultaneous 1B and 2B calls into and
out of our gateway service.
The tariff for ISDN PRI (23 B Channels) is particularly absurd (the numbers
may be off slightly, but they do convey the issue):
PRI Installation PRI Monthly Fees
TI $1475 T1 $233
PRI Service 1500 PRI Service 545
Access 1610 Access 287
ISSAC 250 ISSAC 730
----------------- -----------------
Total $4835 Total $1795
Besides the fact that these prices are just plain too expensive, the absurdity
truly comes to light when the prices for a PRI is compared with the price of
the proposed SDS IS BRI which contains 2 B channels:
BRI Installation
Line $70 ($150 ISDN service fee waived for 2 year commitment)
BRI Monthly Fees
SDS IS $28.50
It takes 12 BRI lines (each line has 2 B channels) to form the equivalent
bandwidth of a PRI line. So if I ordered 12 BRI lines it would installation
would cost: $840 vs. the $4835 for a PRI and the monthly fees for 12 BRIs is
$342 vs. $1795 for the PRI. Even if the SDS IS installation fee wasn't waived,
12 BRIs installation costs are about 1/3 of the single PRI.
This is what I call negative economies of scale! I suspect that it does not cost
Pacific Bell 5.2 times more to deliver bandwidth over a single T1 than 12
individual lines. If anything, it must cost them less to deliver it on the T1.
Its not a technical issue, its a tariff issue. My understanding is that Pacific
Bell would like to see this issue corrected, I would like to see this corrected,
and I'm sure other users would like to see it corrected. For ISDN to have any
success as a data distribution system, this situation must be corrected as soon
as possible.
Please let me know if I have misunderstood the situation or what else I can do
to help to rectify things. Correction of this negative economy of scale is
critical to the success of my business as well as ISDN in general.
Sincerely,
Robert Berger
cc: Robert Feraru Public Advisor, California PUC
Gwen Moore Chair, Utilities and Commerce, California State Legislature
Randy Chinn Consultant, Utilities and Commerce, California State Legislature
Mitch Kapor Chairman, Electronic Frontier Foundation
Daniel J. Weitzner Senior Staff Counsel, Electronic Frontier Foundation
Robert Metcalfe Publisher, InfoWorld
John Gilmore Founder, Cygnus Inc.
Sam Ramani PRI Product Manager, Pacific Bell
Ella Spradley ISDN Marketing, Pacific Bell
Scott Rockwell Account Executive, Pacific Bell
Stephen Mulready System Design Consultant, Pacific Bell
Internet ISDN Mailing List (isdn@list.prime.com)
USENET ISDN Newsgroup (comp.dcom.isdn)