TELECOM Digest     Thu, 20 Oct 94 16:22:00 CDT    Volume 14 : Issue
403
 
Inside This Issue:                           Editor: Patrick A. 
Townson
 
     FCC Q & A on Broadband PCS Auctions (Bob Keller)
     "The Road to Banning Encryption" (Gordon Jacobson)
     AT&T 800 Directory Release (Monty Hoyt)
     Comparison of Missouri Intrastate Rates (Will Martin)
 
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----------------------------------------------------------------------
 
Date: Thu, 20 Oct 1994 13:37:54 EDT
From: Bob Keller <rjk@telcomlaw.com>
Subject: FCC Q & A on Broadband PCS Auctions
 
 
ANSWERS TO QUESTIONS CONCERNING BROADBAND PCS AUCTIONS
 
In late August, 1994, the Commission conducted a series of seminars to
familiarize the public with the rules that will apply to the upcoming
auctions of licenses to provide Personal Communications Services in
the 2 GHz band (broadband PCS).  Attendees were invited to submit
written questions to the Commission, which many did.  In addition,
over the last several weeks the Commission has received numerous
informal inquiries concerning our auction rules for broadband PCS.  In
this Public Notice, the Commission hopes to provide guidance to
prospective bidders on broadband PCS licenses.  Some issues regarding
the Commission's broadband PCS auction rules are addressed in the
recently released reconsideration order (see Fourth Memorandum Opinion
and Order in PP Docket No. 93-253, FCC 94-264 (released October 19,
1994)) while others are still subject to reconsideration. These issues
are not treated in this Public Notice.
 
Some of the inquiries we received have posed similar questions in
slightly different ways that reflect the questioner's particular
circumstances. Rather than provide specific guidance to some but not
all questioners, the Commission has recast the questions in general
language that incorporates the most commonly asked questions.
Questions and answers are grouped in the following categories: general
questions, questions pertaining to the auction process, and questions
pertaining to designated entity applicants.
 
 
General Questions
 
Q: How will applicants be notified if there is a problem with their
Form 175 short-form applications?
 
A: Shortly after the deadline for submission of Form 175 applications,
the Commission will issue a Public Notice informing applicants of
their status.  That Public Notice will identify applications that are
accepted, those that contain minor defects that may be resubmitted,
and those that are rejected.  It is each applicant's responsibility to
review that Public Notice to determine the status of its Form 175
application. The Commission will not individually notify applicants of
defects that may be corrected through resubmission.
 
Q: Can an individual participate in the auction?
 
A: In the broadband PCS auction for licenses in frequency blocks A and
B, which is scheduled to begin on December 5, 1994, individuals may
participate freely as applicants or as investors in applicants.  The
same will be true of our third broadband PCS auction -- for licenses
in frequency blocks D and E. However, in the second auction, for
licenses in frequency blocks C and F, only individuals who meet the
eligibility requirements set forth in our Rules may participate.
 
Q: What is the FCC doing to ensure that businesses acquiring licenses
have the capital necessary to provide service and that they do not
fail?
 
A: The FCC does not provide any guarantees of success in the
marketplace to winning bidders.  Applicants are required to certify as
part of their Form 175 short-form applications that they are
financially qualified.  The FCC does not require that applicants make
a showing of their financial qualifications; however we take all
certifications very seriously, and penalties for a false certification
could include loss of any auction payments made, loss of other
licenses held by the applicant, disqualification from future auctions,
and possible criminal prosecution.
 
Q: Where can I obtain information and maps regarding what area is
within each BTA and MTA?
 
A: On September 22, 1994, the FCC issued a Public Notice listing of
all of the counties contained in each BTA and all of the BTAs
contained in each MTA.  This Public Notice (Report No.  CW-94-02) is
accessible on the Internet through anonymous ftp@fcc.gov, and copies
of the Public Notice can be obtained through the FCC's copy
contractor, International Transcription Service, by calling (202)
857-3800.  The information contained in the Public Notice is based on
material copyrighted by Rand McNally and Company.  Maps of BTAs and
MTAs can be obtained from the Personal Communications Industry
Association (PCIA) under a licensing agreement PCIA has entered with
Rand McNally & Company.
 
Q: How will bidders be able to submit bids on broadband PCS licenses?
 
A: On-site bidding will take place at The Postal Square Building, 2
Massachusetts Avenue, N.E., Washington, D.C.  (adjacent to Union
Station). Bidders will also be able to submit bids through bid
assistants via telephone, with bid confirmation transmitted via
facsimile.  The Commission is considering whether to enable bidders
also to participate in the auction through remote computer access via
a value added network.  In a future Public Notice, the Commission will
inform prospective bidders of the procedures if the latter option is
to be made available.
 
Q: What happens to a PCS license after the 10-year license term?  Will
the licensee have to be subjected to another auction?
 
A: The legislation authorizing the FCC to conduct auctions
specifically limits this authority to "initial" licenses, so renewal
applications will not be subject to auction. The Commission has not
yet set forth standards for renewal of PCS licenses.  In the cellular
services, however, licensees who have operated cellular systems in the
public interest, and who have met all applicable performance
requirements, are entitled to a renewal expectancy at the expiration
of their initial license term.
 
Q: What does it mean when the FCC says that no one can have more than
40 MHz of PCS spectrum in one area?
 
A: This restriction, contained in Section 24.229(c) of the
Commission's Rules, provides that no entity may be licensed to provide
PCS to any particular geographic area over more than 40 MHz of
spectrum.  In addition, no person or entity is permitted to hold an
attributable interest in PCS licensees that, when considered together,
are licensed to provide PCS on more than 40 MHz of spectrum.  This
rule was promulgated to further the development of a competitive
post-auction PCS market structure by ensuring that no entity could, in
effect, "corner the market" on PCS spectrum.
 
Q: Will the FCC grant all PCS licenses at the same time or will
licenses be issued in the order in which they are auctioned?
 
A: The FCC currently does not plan to delay the grant of any PCS
license so as to coincide with the grant of any other PCS license.  To
do so would contravene our stated policy designed to foster the rapid
initiation of new competitive services to the public.  The time that
will be required to review an auction winner's long-form application
for a license will vary depending on the complexity of the information
submitted, the resources available to the Commission for processing,
whether any petitions to deny have been filed against the application,
and the complexity of the issues raised in any such petitions.
 
Q: If an auction winner defaults on its payment obligation, what would
be the procedure for someone else to acquire that license?
 
A: If an auction winner to whom a license has been granted defaults,
the license will automatically be cancelled.  The license will then
revert to the Commission, and the Commission will re-auction the
license in a later auction event.  The public would be informed
through public notices if licenses are to be re-auctioned.
 
Q: Many of the likely applications of PCS technology involve direct
interconnection with local exchange equipment and switches.  Does this
create an advantage for the local exchange carriers who are bidding on
PCS licenses in the wireline service areas? What is the FCC doing to
address the interconnection issue?
 
A: If a LEC also owns a cellular system in its wireline service area,
it is ineligible to own more than 10 MHz of PCS spectrum in that area.
Thus, as a PCS operator, it would not be in a position to benefit from
its LEC status vis-a-vis a competing 30 MHz PCS operator.  The FCC has
instituted a proceeding in which we are asking whether interconnection
rates should continue to be set by agreement or by tariff.  The
Commission will use its authority under Title II of the Communications
Act to monitor what is happening to make sure that non-RBOC licensees
will not be discriminated against and we will be vigilant in our
efforts to prevent abuses from arising.
 
 
Questions Pertaining to the Auction Process
 
Q: Why did the FCC choose such a complex auction process?
 
A: The simultaneous multiple round auction design the FCC is using for
PCS auctions has a couple of important advantages over the simpler,
sequential auction design.  First, the simultaneous multiple round
design conveys to bidders the most information about the true value of
licenses during the course of the auction, thereby improving bidders'
confidence and enabling them to minimize the "winner's curse" (i.e.,
the tendency to overbid).  In addition, in a sequential auction, the
results of later auctions will likely tell a bidder too late that it
should have bid (or not bid) on an earlier-auctioned license.  By
offering all substantially identical or complementary licenses at the
same time, bidders will be better able to effectuate their aggregation
strategies.  This will tend to result in the creation of more
efficient service that will bring greater competition, better service
and lower prices to consumers.
 
Q: The activity rules force bidders to bid in each round.  Why should
this be required?
 
A: If there were no requirement that bidders place bids in each round
of the auction, bidders would naturally tend to hold back, waiting to
see what others bid.  If a substantial number of bidders adopt this
strategy, the Auction might proceed exceedingly slowly, or it might
close prematurely.  Activity rules are necessary to ensure that
auctions progress at a reasonable pace and that useful information
about the value of licenses is conveyed to bidders throughout the
auction.
 
Q: How will the FCC determine what licenses I may bid on in the
auction?
 
A: Bidders will be allowed to place bids only on licenses for which
they applied on their FCC Form 175 application, but the precise amount
of bidding eligibility (i.e., the amount of bids, in terms of
MHz-pops, that a bidder may place in any round) will be determined by
the amount of upfront payment submitted by the bidder prior to the
auction.  The FCC will translate the dollar amount of the upfront
payment into a MHz-pop figure, and the computer system will not allow
a bidder to enter a set of bids if the total number of MHz-pops
represented by the licenses on which bids are placed exceeds the
number of MHz-pops to which its upfront payment translates.  If the
bidder's eligibility drops during the course of the auction (due to
bidding below the required activity level), the revised eligibility
will be applied by the computer system. Therefore, in order to avoid
having its eligibility reduced, a bidder must pay attention to the
number of MHz-pops associated with each license on which it places
bids, and ensure that its bidding in each round of the auction exceeds
its required activity.
 
Q: Could you explain the activity rules in terms a layman can
understand?
 
A: As explained above, each bidder's upfront payment will determine
its "required activity level."  The term "required activity level"
refers to the number of MHz-pops on which a bidder must be "active"
(i.e., submit a valid bid or hold the high bid from the previous
round) to avoid having its eligibility reduced in future rounds.  In
stage I of the auction, each bidder must be active on of the MHz-pops
on which it is eligible to bid.  In stage II of the auction, each
bidder must be active on of the MHz-pops on which it is eligible to
bid.  In stage III, each bidder must be active on all of the MHz-pops
on which it is eligible to bid.  Unless an activity rule waiver is
applied, the following eligibility reduction will occur if a bidder's
activity falls below the required activity level in a round:
 
    Auction Stage I:  Loss of 3 MHz-pops in eligibility for
        each MHz-pop below required level
 
   Auction Stage II:  Loss of 1.5 MHz-pops in eligibility for
        each MHz-pop below required level
 
  Auction Stage III:  Loss of 1 MHz-pop in eligibility for each
        MHz-pop below required level
 
The Commission has retained the discretion to reduce the required
Stage III activity level by Public Notice in advance of each auction,
but in no event will a bidder's required activity level in Stage III
be less than 95 percent of the MHz-pops on which it is eligible to
bid.
 
Q: How do activity rule waivers work?  Can an activity rule waiver be
submitted by the bidder, or is it only entered automatically by the
FCC if a bidder does not bid or if its bids fall below its required
activity level?
 
A: When a bidder's activity in a round falls below its required
activity level, a waiver will automatically be applied if the bidder
has a waiver available.  In this event, however, a bidder will be
offered the option of overriding the automatic waiver mechanism,
enabling it to intentionally reduce its eligibility and save the
waiver for later use.  Bidders also will be able to submit an activity
rule waiver "proactively".  A bidder may wish to do so if it is unable
or does not desire to bid in a particular round of the auction and
wishes to ensure that the auction will not close in that round.
(Submission of a proactive waiver keeps the auction open even if no
other valid bids are submitted, but application of an automatic waiver
will not.)
 
Q: Is a bidder who withdraws a high bid in a round considered to be
"active" on that license in the next round?
 
A: Yes.  Withdrawal of a high bid does not negate the fact that the
bid was made and that it was the high bid.  Bidders should keep in
mind, however, that they may be required to pay a penalty if they
withdraw a high bid.
 
Q: How will bidders know when a round is over?
 
A: The FCC will announce at the beginning of each round when the bid
submission period will end.  After the round results from the bid
submission period are posted, we will announce the bid withdrawal
period.  This information will be available both at the auction site
and over any value added network created for remote bidding.  A
countdown clock also will be provided to inform bidders as to the time
remaining in each period.
 
Q: How will auction results be made public?
 
A: Results from each round of the auction will made available 1) at
the auction site, 2) on the Internet, and 3) to bidders over the FCC
BIDDER ONLINE value added network, if the FCC decides to offer the
option of remote electronic bidding.  Prospective bidders interested
in the remote electronic bidding option must register with Business
Information Network by November 15, 1994 by calling (800) 336-9246.
Charges of $200 for the Set-up Kit and software and $23 per hour of
online access will apply. Results posted on the Internet can be
accessed at the following Internet address: anonymous ftp@fcc.gov
 
 
Questions Pertaining to Designated Entity Applicants
 
Q: What provisions are available for small businesses, rural telephone
companies and businesses owned by minorities and/or women (the
"designated entities") in the auction for MTA licenses on frequency
blocks A and B?
 
A: The FCC did not adopt special payment provisions to benefit
designated entities in the bidding itself in this first auction.
Thus, the bidding credits and installment payment plans that will be
available in the auction for licenses on frequency blocks C and F (the
"Entrepreneurs' Blocks) are not available in the auction that begins
on December 5, 1994.  The Commission's tax certificate policy,
however, will apply to sales of block A and B licenses and to
investments in certain applicants for these licenses.  In addition,
the FCC's partitioning policy with respect to rural telephone
companies will apply to the MTA license auction.  Rural telephone
companies will be able to be licensed for partitioned broadband PCS
service areas in one of two ways: 1) they may form consortia to bid on
MTA licenses, with the license to be partitioned among the consortia
members in the post-auction licensing process; or 2) through private
post-licensing negotiation with an MTA licensee, they may obtain
licenses for partitioned areas that are reasonably related to their
wireline service areas.  A proceeding is currently pending to
determine whether the partitioning policy should be extended to
businesses owned by minorities and/or women. See Further Notice of
Proposed Rule Making in PP Docket No. 93-253, FCC 94-198 (released
August 2, 1994).
 
Q: What are tax certificates and how do they benefit designated
 
@FROM   :telecom@delta.eecs.nwu.edu
(Continued from last message)
entities?
 
A: Under Section 1031 of the Internal Revenue Code, the Commission may
upon request grant tax certificates.  A tax certificate enables the
grantee to defer recognition of gain For tax purposes on the sale of
an investment in a communications property.  With respect to
designated entities bidding on PCS licenses, the tax certificate
policy could work in two ways.  First, an investor in a minority- or
women-owned PCS licensee would be able to defer the payment of capital
gains tax upon the sale of its investment, if it satisfies certain
conditions regarding reinvestment of the gain.  Second, a non-
designated entity PCS licensee would be entitled to deferral of gain
if it transfers its license to a business owned by minorities and/or
women, again subject to reinvestment conditions.  The tax certificate
policy is intended to serve both to attract investment capital to
entities that have historically faced discrimination in gaining access
to capital, and to encourage sales to minority- and women-owned firms.
 
Q: How can a designated entity licensee avoid having to pay penalties
if its owner dies during the holding period, causing the licensee to
lose its designated entity status?
 
A: In the event of the death of a designated entity owner, the
licensee could make a request with the Commission for a waiver of the
holding rule requirements and the unjust enrichment provisions
applicable to installment payments and bidding credits.
 
Q: If a license obtained with a bidding credit is transferred more
than 10 years from the date of the initial license grant, would the
bidding credit have to be refunded?
 
A: No.
 
Q: Has the FCC prepared a Designated Entities FCC Auction Guidebook?
If so, how can I obtain a copy?
 
A: The FCC has not prepared such a document.  Law firms or trade
associations such as the Personal Communications Industry Association
(PCIA) may have developed such guidebooks.
 
Q: Are there any "designated" financial institutions that will
provide/offer funding to designated entities?  Are there qualified
brokers and/or consultants who are reputable, who can assist with the
process?
 
A: The FCC is not in a position to recommend specific potential
sources of financing to prospective bidders.  However, our Office of
Communications Business Opportunities (formerly the Office of Small
Business Activities) is available to provide assistance to individuals
or groups seeking to enter the PCS industry. OCBO's telephone number
is (202) 418-0990.
 
Q: Are advance payments also discounted like the actual bid?
 
A: The upfront payment for all entities bidding in the entrepreneurs'
blocks is $0.015 per MHz pop.  That is a 25 percent discount from the
$0.02 per MHz pop required in the other auctions.  In addition, the
down payment for small businesses and minority and women-owned
businesses will be calculated based on the bid price after the bidding
credit is subtracted.  So, if a small minority-owned firm bid $1
million, its total payment would be $750,000 after subtraction of the
25 percent bidding credit.  The 10 percent down payment would be
$75,000, one-half payable five business days after close of the
auction and the other half due five business days after grant of the
license.
 
Q: Does a university (a non-profit institution) which applies for an
"Entrepreneurs' Block" license it intends to use in training students
in the development and use of PCS technology qualify as a designated
entity?
 
A: If the university meets our gross revenue and total assets tests it
may qualify as an entrepreneur or as a small business.  The Commission
has adopted no PCS rules specifically benefitting universities or
entities that wish to acquire licenses for training purposes.
 
Q: Does the FCC have any guidelines regarding the incorporation date
or length of time a minority- or women-owned business must have been
in existence in order to bid in an auction?
 
A: There are no requirements regarding the length of time a designated
entity business must have been in existence before the auction.  All
affiliates of a new business will be counted toward applicable
financial caps, however.
 
Q: Can a designated entity use a limited partnership or a limited
liability company or any other lawful structure, so long as control
mechanisms are equivalent and within FCC guidelines?
 
A: Yes.  In fact, in the Fifth Report and Order the Commission has
specified various guidelines for limited partnership applicants.
 
Q: Can a major telecommunications company provide debt in any amount
to a designated entity?
 
A: Debt is not attributable unless it appears to be equity disguised
as debt.  Factors such as the interest rate and length of the
repayment period would have to be considered.
 
Q: Can a major telecommunications company enter into agreements with a
number of designated entity applicants around the country for bidding
purposes, so long as each designated entity remains in control?
 
A: The rules applicable to investment in designated entities would
apply to each such investment, and assuming that none of the
designated entity applicants had applied for licenses in any of the
same markets, the rules do not restrict such arrangements.
 
Q: Can designated entities bid at the A and B band PCS auction? If so,
do they receive any special benefits?
 
A: Designated entities are free to bid in any auction.  The only
benefit available in the non-entrepreneurs blocks, however, is the tax
certificate program for businesses owned by minorities and women.
 
Q: Is there minimum capitalization needed for a designated entity?
 
A: No, although designated entities must be prepared to pay half of
the 10 percent down payment five business days after the auction
closes.
 
  - FCC -
 
Robert J. Keller, P.C. (Federal Telecommunications Law)
<rjk@telcomlaw.com> Tel: 301-229-5208 Fax: 301-229-6875
4200 Wisconsin Ave NW #106-261 Washington DC 20016-2146
finger me for info on F.C.C. Daily Digests and Releases
 
------------------------------
 
Date: Thu, 20 Oct 1994 13:35:37 -0400
From: gaj@portman.com (Gordon Jacobson)
Subject: The Road to Banning Encryption
 
 
Pat -
 
         I got this from David Farber.  It sure is a telling tale!  
Let
me know what you can do about posting it.
 
 
[TELECOM Digest Editor's Note: Yes, it is interesting. I thought the
readers might enjoy seeing it today.   PAT]
 
 
CyberWire Dispatch // Copyright (c) 1994 //
 
Jacking in from the "Sooner or Later" Port:
 
Washington, DC -- If private encryption schemes interfere with the
FBI's ability to wiretap, they could be outlawed, according to recent
comments made by the agency's Director Louis Freeh.
 
Freeh told attendees here at the recent conference on Global
Cryptography that if the Administration's Escrowed Encryption System,
otherwise known as the Clipper Chip, failed to gain acceptance, giving
way to private encryption technologies, he would have no choice but to
press Congress to pass legislation that provided law enforcement
access to all encrypted communications.
 
If, after having pushed Digital Telephony through Congress (which
hadn't yet happened when Freeh spoke at this conference), all the
Bureau ended up with during wiretaps were the scratchy hiss of digital
one's and zeros being hurled back and forth, Freeh made it clear that
he would seek a congressional mandate to solve the problem.
 
In other words:  Roll your own coded communications;  go to jail.
 
Freeh's comments, made during a question and answer session at the
conference, are the first public statements made by an Administration
official hinting at a future governmental policy that could result in
the banning of non-governmental, unbreakable encryption methods.
 
Freeh's remarks were first reported on the WELL by MacWorld writer and
author Steven Levy.  The FBI confirmed those statements to Dispatch.
 
The Administration, however, continues to state that it has no plans
to outlaw or place any restrictions on private encryption methods.
 
A White House official said there are "absolutely no plans" on the
table to regulate domestic encryption "at the present time." He
wouldn't comment, however, as to whether the Administration would back
an FBI attempt for such legislation.  "Freeh doesn't seem to need a
lot of White House support," to get things done, the official said.
 
FBI sources said any moves to approach Congress about regulating
private encryption are "so far out there" time wise, that the subject
"doesn't merit much ink," as one FBI source put it. "We've got to make
sure the telcos rig up their current networks according to the new
[digital wiretap] law before we go worrying about private encryption
stuff," he said.
 
An FBI spokesman confirmed Freeh's position that the Bureau would
aggressively seek to maintain what the spokesman called "law and order
objectives."  If that meant getting laws passed so that the Bureau's
"authorized wiretap activities" couldn't be thwarted by "criminal
elements using non-governmental" encryption schemes, "then that's what
he [Freeh] would do," the spokesman said.
 
When the Administration went public with its Clipper Chip policy, it
stressed that the program would be mandatory.  Many civil liberties
groups wondered out loud how long it would be before private
encryption was banned altogether.  The White House, anxious for the
public to buy into its one-trick pony the Clipper Chip, said that
wouldn't happen.
 
But the Administration hedged its bet.
 
Buried in the background briefing papers of the original Clipper
announcement, is a statement that the White House doesn't consider the
public's right to use private encryption methods are protected
anywhere in the Constitution.
 
Meeks out ...
 
                   -------------------
 
Regards, - GAJ
Home Page: http://www.seas.upenn.edu/~gaj1/home.html
 
------------------------------
 
Date: Thu, 20 Oct 1994 09:28:11 GMT
From: montyh@attmail.com (Monty Hoyt)
Subject: AT&T 800 Directory Now on Internet
 
 
Patrick,
 
  AT&T issued two Internet-related events yesterday.  We
announced AT&T's own World Wide Web Internet server, 
http://www.att.com/,
that will be the primary "home page" for visitors to AT&T on the Web.
This site will carry information about the company and its operations
and will have hotlinks to AT&T business units, many of which will
support their own home pages.
 
      AT&T also announced a separate Web site, http://att.net/dir800,
and an initial offering of a service giving access to the AT&T 800
Directory.  This site will be the primary AT&T location on the Web for
customer services.  The release for this directory service is
attached.
 
*****************************
 
Monty Hoyt
908-221-8789 (office)
908-953-9172 (home)
 
Susan Reiche
908-221-4855(office)
908-233-4357 (home)
 
 
AT&T INAUGURATES 800 DIRECTORY ON THE INTERNET
 
FOR IMMEDIATE RELEASE:  WEDNESDAY, October 19, 1994
 
  BASKING RIDGE, N.J. -- Consumers and business people anxious
to find toll-free 800 numbers for travel reservations, catalogs or
other services can now locate that information easily on the Internet,
thanks to a new directory source from AT&T.
 
  AT&T announced today that through the new AT&T 800 Directory
on the Internet more than 150,000 listings from AT&T's business and
consumer yellow-page 800 directories are now found on the Internet's
World Wide Web.  The Internet is the global information superhighway
that links thousands of public and private computer networks.
 
  An estimated 30 million Internet users can look up numbers by
company name or category, or browse through the directory
alphabetically.  With each free inquiry, users will receive the
company name, 800 number and main corporate location.
 
  "While some companies have posted advertising and self-promotional
materials on the Internet, AT&T has moved ahead with a practical,
universal application -- a national directory source that enables
millions of Internet users, for the first time, to look up 800 numbers
for their favorite products and services," said Kathryn Sullivan, AT&T
marketing vice president for new business services.
 
  "This directory is literally a gateway to the national
marketplace.  And this is just the beginning.  In the near future, our
electronic 800 directory on the Internet will contain display ads like
those shown in the printed directories.  These ads will provide
valuable information on a myriad of products and services being
offered by the business community -- and the toll-free numbers to
reach them," Sullivan said.
 
  Early in 1995, the AT&T Internet directory will compensate for
misspelled company names entered by users, and provide multiple
choices on look-ups if there are several company listings with the
same or similar names.
 
  To access the AT&T 800 Directory, which is situated on the
Internet's World Wide Web, users should key in the address:
"http://att.net/dir800" Users will then be able to conduct a company
or category search for the appropriate 800 numbers.  The 800 numbers
listed are reachable only when dialed within the United States.
 
  Listings in the AT&T 800 Directory on the Internet are updated
monthly, making it a convenient, up-to-date source for current
national 800 number listings.  Future versions of the service will
enable AT&T Internet directory advertisers to update messages in their
ads to reflect current promotions, sales or new business offerings.
 
  Consumers or advertisers with questions about the AT&T 800
Directory on the Internet should call 1-800-562-2255.
 
------------------------------
 
Date: Wed, 19 Oct 94 13:18:42 GMT
From: Will Martin <wmartin@STL-06SIMA.ARMY.MIL>
Subject: Comparison of Missouri Intrastate Rates
 
 
I just did a little research and thought I'd share the results of it
with the group. Recently, Southwestern Bell lost a battle with the
Missouri PUC over a mandated rate reduction. (At least, that was the
public front on it; I'm not privy to the back-room info that might
show that they really didn't "lose" anything, since most telco-vs-PUC
affairs are really stage shows and the results are probably
orchestrated by the powers that be in any case ...)
 
Anyway, I had just received a flyer from an alternative LD outfit
called "Budget Call LD, Inc." (based in Rochester, NY) that uses 10368
as their prefix.  The ad touted great savings over AT&T rates, but
what we are interested in is savings over Southwestern Bell rates for
the weekly long-duration intrastate call my wife makes from St. Louis
to her aunt in Warrenton, MO. We've been using "Show-Me Long Distance"
(prefix 10778) for that for over a year now and I've been wondering if
the new reduced SW Bell rates would eliminate such savings.
 
So I called SW Bell, Budget Call, and Show-Me for rate quotes. Here
they are:
 
For a call from 314-351-XXXX to 314-456-XXXX
 
    First minute Subsequent minutes
SW Bell:
 
Day         $0.37  .23
 
Evening    .296  .184 (80% of Day rate)
 
Night    .2405  .1495 (65% of Day rate)
 
Budget Call LD:
 
Day    .3875  .225
 
Evening    .3075  .18
 
Night    .2525  .145
 
Show-Me LD:
 
Day    .3649  .2136
 
Evening    .2919  .179
 
Night    .2372  .1388
 
So you can see that not only are savings from the alternates rather
slim, in some cases it looks like Budget Call is actually a smidge
higher that SW Bell. Show-Me still comes out lowest, but there isn't
much distinction any more. We call on Sunday so the Night rate
applies.
 
I called the MO PUC a while back and asked them if they were going to
try to get these alternate LD providers to lower their intrastate
rates at least by the same percentages as SW Bell has, but the person
I spoke with didn't appear to know much about the issue and didn't
indicate that such reductions would be likely. SW Bell is being
required to give refunds to customers that made calls during the
earlier part of this year, because the new rates are actually
retroactive -- they had been ordered imposed a long while back and the
telco fought a delaying battle, with monthly notices in the bills
about the need for customers who left to provide addresses for the
possible later mailing of refunds.  I haven't seen any credits show up
on the bill yet, though.
 
It would be nice if the same thing could be done with the alternate
carriers, but I have no idea what authority, if any, the Missouri PUC
has over these companies, especially if they are based out-of-state.
 
I do note that the advertising text NEVER claims a percentage savings
over SW Bell rates -- only over AT&T rates, with side-references to
Sprint & MCI. But if AT&T cannot carry the call (and that seems to be
the case for these St. Louis <-> Warrenton intrastate calls), that
comparison is meaningless.
 
If anyone out there has any suggestions for alternate LD services that
WOULD provide significant savings in this circumstance, I'd like to
hear about it. We've even investigated the possibility of getting my
wife's aunt a number that would be local to St. Louis, and paying for
that premium charge above her regular phone-bill rate ourselves in
lieu of paying for these LD calls, but it seems that isn't possible.
One big hurdle is that Warrenton is in a GTE (I think) enclave within
normally-SW-Bell territory. We don't make other LD calls to any
extent, so we'd only be interested in intrastate savings.
 
 

Regards,
 
Will     wmartin@st-louis-emh2.army.mil
 
 
[TELECOM Digest Editor's Note: As happens so often, it appears the 
choice
of carrier for your calls is an application-driven thing based in 
large
part on the time of day/day of week the call is made. If you study the
rates listed above, there can be some differences and possibly some 
savings
based on the carrier if your calls are mostly at night and weekends. 
On
the other hand, if you make mostly daytime calls during business 
hours,
the best carrier might be totally different.  Probably the most 
effecient
and least expensive arrangement would be to use a computer program 
which
examined the dialed digits then sent the call by one carrier or 
another
depending on the time of day and the inter/intrastate destination, 
etc.
But software and hardware designed to route calls like that is itself
rather expensive, and I don't know at what point it would be amortized
or justified.  Pennies do add up to be sure, but I think for the 
average
user these days, cost-comparisons on long distance are of little real
value. Just pick a carrier and go with it. Make switches based on 
other
things that matter (unless nothing but money matters to you!) such as
customer service, reliability and political/social considerations (the
presence/absence of a labor organization for workers, etc).    PAT]
 
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End of TELECOM Digest V14 #403
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