W8SDZ@SIMTEL20.ARPA (Keith Petersen) (08/16/87)
TO: Telenet Customers
FROM: Phil Walker
SUBJECT: Sample Format for Comments/Reply Comments in FCC
Access Charge Proceeding
A number of Telenet customers have requested information
concerning the proper format for filings with the FCC regarding
the access charge issue, Docket 87-215. Such filings can take
the form of either a formal legal pleading (Comments and/or
Reply Comments) or an informal letter to the Chairman of the
FCC. In either case, a copy should be sent to your
Congressman, your two Senators and the Chairmen of the House
and Senate telecommunications subcommittees, with a cover
letter asking them to urge the FCC not to proceed with its
proposal.
Attachment 1 to this memo is a sample format for formal
Comments and/or Reply Comments. Please note that the first
three pages (cover sheet, summary and table of contents) are
required by the FCC Rules only if the body of your pleading
exceeds 10 pages in length.
You may attach as exhibits or appendices whatever
material would be helpful to support your arguments -- e.g.,
price lists for your on-line services, market studies, economic
impact analyses, statements from your management and/or
customers, etc. A short affidavit (sworn statement) from one
of your key executives stating that he or she has read the
pleading and it is accurate to the best of his/her knowledge is
a helpful addition, but is not really necessary.
Your pleading should be typed on 8 1/2 x 11 paper,
double-spaced (except for summary page, which may be
single-spaced if you prefer). A signed original and 5 copies
should be sent to the Secretary, Federal Communications
Commission, Washington, D.C. 20554, in time to arrive by the
respective due dates --
September 24, 1987 for Comments
October 26, 1987 for Reply Comments
Also, copies should be mailed to each of the three FCC staffers
shown on the attached Certificate of Service.
If you choose to write a letter to the FCC instead of
submitting formal legal comments, it should contain essentially
the same sort of recitation of your concerns and arguments.
Any useful documents can be attached. Attachment 2 to this
letter is a sample format for such a letter.
Attachment 3 is a sample format for your cover letter to
the Congressional recipients, and Attachment 4 is a list of
U.S. Senators for each state.
Also, please send us a blind copy of whatever documents
or letters you prepare, so we will be aware of it in our
lobbying efforts. A self-addressed envelope is enclosed for
this purpose.
Please feel free to give me a call at (703)689-5656 if
you have any questions.
Attachments (4)
ATTACHMENT 1
NOTE: This cover page is
required only if body of
the pleading exceeds 10
pages in length.
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Amendments of Part 69 ) CC Docket No. 87-215
of the Commission's Rules )
Relating to Enhanced Service )
Providers )
To: The Commission
COMMENTS [or Reply Comments]
OF [Name of Your Organization]
Respectfully submitted,
By: [signature]
[Typed name and address of
your attorney, or whoever
will sign the pleading]
[Date of the filing] Its Attorney [delete this if
pleading not signed by a
lawyer]
NOTE: This summary is
required only if body of
the pleading exceeds
10 pages in length.
SUMMARY
[Insert here a brief summary of the key points made in the
body of the pleading -- including a summary of any important
data you submit to support your points, such as an impact
assessment.]
[This summary should be no more than a page or two in
length. If you prefer to keep it to one page, it may by
single-spaced if necessary.]
(ii)
NOTE: Table of contents
is required only if body
of the pleading exceeds
10 pages in length.
TABLE OF CONTENTS
Page
Summary ii
I. Introduction 1
II. [First Topic Heading]
III. [Second Topic Heading]
IV. [etc.]
V. Conclusion
Appendix 1
Appendix 2
etc.
(i)
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Amendments of Part 69 ) CC Docket No. 87-215
of the Commission's Rules )
Relating to Enhanced Service )
Providers )
To: The Commission
COMMENTS [or Reply Comments]
OF [Name of Your Organization]
[Name of your organization] hereby submits its Comments [or
Reply Comments] in response to the Commission's Notice of
Proposed Rule Making in the above-captioned proceeding,
released July 17, 1987.
I. Introduction
[Begin by providing a description of your organization, and
the enhanced services you provide and/or use -- e.g., VAN
network service, electronic mail, database access. Explain
that local exchange dial-in access is essential to your
provision or use of such services, and that your costs (and
thus your prices, if you provide computer services) would be
significantly affected by the FCC's access charge proposal.]
II. [Heading for First Topic] (Underline heading)
[Text of your first topic -- e.g., a discussion of the
impact of the proposed price increases upon your business, your
user base, usage levels and future growth rates, and the like.
Refer to any attachments that will help to make your points.]
III. [Heading for Second Topic] (Underline heading)
[Text of your second topic -- e.g., a discussion of the
discrimination inherent in singling out enhanced service
providers for access charges, while all other users of the
local exchange pay ordinary business dial rates.]
IV. [Heading for Third Topic] (Underline heading)
[Text for third topic. There can be as many
topics/arguments as you wish to make.]
V. Conclusion (Underline)
[Short concluding statement, urging that the FCC reject the
access charge proposal for enhanced service providers.
Reiterate harmful impact and other policy problems which this
proposal would create.]
Respectfully submitted,
[NAME OF YOUR ORGANIZATION]
By: [signature]
[Typed name and address of
your attorney, or whoever
will sign the pleading]
[Date of the filing] Its Attorney [delete this if
pleading not signed by a
lawyer]
CERTIFICATE OF SERVICE
I, [name of your secretary], do hereby certify that the
foregoing Comments [or Reply Comments] of [Name of your
organization] were sent by first-class U.S. mail, postage
prepaid, this day of , 1987 to the following:
Gerald Brock, Chief Thomas Sugrue, Chief
Common Carrier Bureau Policy Division
Federal Communications Common Carrier Bureau
Commission Federal Communications
1919 M Street, N.W., Room 500 Commission
Washington, D.C. 20554 1919 M Street, N.W., Room 544
Washington, D.C. 20554
Ruth Milkman, Attorney Advisor
Policy Division
Common Carrier Bureau
Federal Communications
Commission
1919 M Street, N.W., Room 544
Washington, D.C. 20554
[Insert names of any other parties you wish to formally serve
copies of your filing upon. For initial Comments, there is no
requirement that anyone outside the FCC be served. For Reply
Comments, everyone filing initial Comments should be served,
but in all likelihood many parties will not comply with this
requirement due to the large number of parties involved.]
[signature of your secretary]
[typed name of your secretary]
ATTACHMENT 2
[Your letterhead]
[Date]
The Honorable Dennis R. Patrick, Chairman
Federal Communications Commission
1919 M Street, N.W.
Washington, D.C. 20554
RE: CC Docket 87-215, Amendments of Part 69
of the Commission's Rules Relating to
Enhanced Service Providers
Dear Chairman Patrick:
[Insert text. Content should be similar to that suggested
for formal comments, but perhaps less detailed. Begin with a
short description of your organization and the enhanced
services you provide/use. Emphasize impact of the FCC proposal
upon your business, your users, etc. Discuss other policy
arguments against the FCC proposal, such as the discrimination
against computer services and their users which it would
create.]
Sincerely,
cc: The Honorable James H. Quello
The Honorable Mimi Weyforth Dawson
The Honorable Patricia Diaz Dennis
Gerald Brock, Chief, Common Carrier Bureau
Thomas Sugrue, Chief, Policy Division,
Common Carrier Bureau
Office of the Secretary, for inclusion in Docket file
[NOTE: Addresses for all these individuals are the same as
shown above.]
ATTACHMENT 3
[Your letterhead]
[Date]
Separate letters addressed to each of the following:
1. Your Congressman:
The Honorable
United States House of Representatives
Washington, D.C. 20515
2. Each of your two Senators:
The Honorable
United States Senate
Washington, D.C. 20510
3. Each of the subcommittee chairmen:
The Honorable Edward J. Markey, Chairman
Subcommittee on Telecommunications and Finance
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515
The Honorable Daniel K. Inouye, Chairman
Subcommittee on Communications
Committee on Commerce, Science and Transportation
U.S. Senate
Washington, D.C. 20510
Dear Congressman [or Senator ]:
[Explain briefly who you are, and that you are concerned with
the FCC's proposal to impose carrier access charges on enhanced
service providers. Note that you have filed comments with the
FCC opposing this proposal, and that a copy of your filing is
attached.
Briefly summarize the key points from your FCC filing, and urge
the Member of Congress to express his concern to the FCC.]
Sincerely,
[Attach copy of your FCC filing]
ATTACHMENT 4
U.S. SENATORS
ALABAMA
Heflin, Howell (Dem.)
Shelby, Richard C. (Dem.)
ALASKA
Murkowski, Frank H. (Rep.)
Stevens, Ted (Rep.)
ARIZONA
DeConcini, Dennis (Dem.)
McCain, John (Rep.)
ARKANSAS
Bumpers, Dale L. (Dem.)
Pryor, David H. (Dem.)
CALIFORNIA
Cranston, Alan (Dem.)
Wilson, Pete (Rep.)
COLORADO
Armstrong, William L. (Rep.)
Wirth, Timothy E. (Dem.)
CONNECTICUT
Dodd, Christopher J. (Dem.)
Weicker, Lowell P. (Rep.)
DELAWARE
Biden, Joseph R. (Dem.)
Roth, Jr., William V. (Rep.)
FLORIDA
Chiles, Lawton (Dem.)
Graham, Bob (Dem.)
GEORGIA
Fowler, Jr., Wyche (Dem.)
Nunn, Sam (Dem.)
HAWAII
Inouye, Daniel K. (Dem.)
Matsunaga, Spark M. (Dem.)
IDAHO
McClure, James A. (Rep.)
Symms, Steve (Rep.)
INDIANA
Lugar, Richard G. (Rep.)
Quayle, Dan (Rep.)
ILLINOIS
Dixon, Alan J. (Dem.)
Simon, Paul (Dem.)
IOWA
Grassley, Charles E. (Rep.)
Harkin, Tom (Dem.)
KANSAS
Dole, Robert J. (Rep.)
Kassebaum, Nancy L. (Rep.)
U.S. Senators
Page 2
KENTUCKY
Ford, Wendell H. (Dem.)
McConnell, Mitch (Rep.)
LOUISIANA
Breaux, John B. (Dem.)
Johnston, J. Bennett (Dem.)
MAINE
Cohen, William S. (Rep.)
Mitchell, George J. (Dem.)
MARYLAND
Mikulski, Barbara A. (Dem.)
Sarbanes, Paul S. (Dem.)
MASSACHUSETTS
Kennedy, Edward M. (Dem.)
Kerry, John F. (Dem.)
MICHIGAN
Levin, Carl M. (Dem.)
Reigle, Donald W. (Dem.)
MINNESOTA
Boschwitz, Rudy (Rep.)
Durenberger, Dave (Rep.)
MISSISSIPPI
Cochran, Thad
Stennis, John C. (Dem.)
MISSOURI
Bond, Christopher S. (Rep.)
Danforth, John C. (Rep.)
MONTANA
Baucus, Max S. (Dem.)
Melcher, John (Dem.)
NEBRASKA
Exon, J. James (Dem.)
Karnes, David (Rep.)
NEVADA
Hecht, Chic (Rep.)
Reid, Harry M. (Dem.)
NEW JERSEY
Bradley, Bill (Dem.)
Lautenberg, Frank R. (Dem.)
NEW HAMPSHIRE
Humphrey, Gordon J. (Rep.)
Rudman, Warren (Rep.)
NEW MEXICO
Bingaman, Jeff (Dem.)
Domenici, Pete V. (Rep.)
NEW YORK
D'Amato, Alfonse M. (Rep.)
Moynihan, Daniel Patrick (Dem.)
NORTH CAROLINA
Helms, Jesse A. (Rep.)
Sanford, Terry (Dem.)
U.S. Senators
Page 3
NORTH DAKOTA
Burdick, Quentin N. (Dem.)
Conrad, Kent (Dem.)
OHIO
Glenn, John (Dem.)
Metzenbaum, Howard M. (Dem.
OKLAHOMA
Boren, David L. (Dem.)
Nickles, Don (Rep.)
OREGON
Hatfield, Mark O. (Rep.)
Packwood, Bob (Rep.)
PENNSYLANIA
Heinz, John (Rep.)
Specter, Arlen (Rep.)
RHODE ISLAND
Chafee, John H. (Rep.)
Pell, Claiborne (Dem.)
SOUTH CAROLINA
Hollings, Ernest F. (Dem.)
Thurmond, Strom (Rep.)
SOUTH DAKOTA
Daschle, Thomas A. (Dem.)
Pressler, Larry (Rep.)
TENNESSEE
Gore, Albert, Jr. (Dem.)
Sasser, Jim (Dem.)
TEXAS
Bentsen, Lloyd (Dem.)
Gramm, Phil (Rep.)
UTAH
Garn, Jake (Rep.)
Hatch, Orrin G. (Rep.)
VERMONT
Leahy, Patrick J. (Dem.)
Stafford, Robert T. (Rep.)
VIRGINIA
Trible, Paul S. (Rep.)
Warner, John W. (Rep.)
WASHINGTON
Adams, Brock (Dem.)
Evans, Daniel J. (Rep.)
WEST VIRGINIA
Byrd, Robert C. (Dem.)
Rockefeller, John D. IV (Dem.)
WISCONSIN
Kasten, Bob (Rep.)
Proxmire, William (Dem.)
WYOMING
Simpson, Alan K. (Rep.)
Wallop, Malcolm (Rep.)