W8SDZ@SIMTEL20.ARPA.UUCP (08/15/87)
Telenet Communications Corporation
12490 Sunrise Valley Drive
Reston, VA 22096
THE FCC PROPOSAL TO IMPOSE ACCESS CHARGES
ON ENHANCED SERVICE PROVIDERS
ISSUE ANALYSIS
I. Background
Under the FCC's rules adopted in the Second Computer Inquiry (often
called Computer II) in 1980, computer-based services such as value-added
networks; database services; timesharing and other remote computing
services; electronic mail; and voice messaging services were defined as
"enhanced services," and firms providing such services to the public were
"enhanced service providers" (ESPs). The FCC's rules provided that
enhanced services were not a common carrier activity, ESPs could not be
regulated as carriers at either the federal or state level, and, thus,
ESPs did not pay carrier access charges.
In contrast, long-distance common carriers (e.g., AT&T, MCI, and US
Sprint) paid carrier access charges for their use of the local exchange
dial network to access their customers. Carrier access charges were
introduced in tandem with the AT&T divestiture to replace the longstanding
system of "settlements and division of revenue" wherein revenues for long-
distance telephone service were allocated within the pre-divestiture Bell
System and shared with the independent telephone companies.
II. Summary of the FCC's Proposal
As stated in the attached Notice of Proposed Rule Making (NPRM), the
FCC now proposes to apply its carrier access charges to all enhanced
service providers (ESPs) who utilize local exchange dial lines to originate
or terminate interstate traffic. The FCC's "enhanced service" definition,
as discussed above, would encompass value-added networks (VANs) such as
Telenet and any type of host-based services provided to external users
for a fee.
III. Financial Impact on Telenet and PC Pursuit Customers
The FCC's rate structure for carrier access charges includes two
components: "traffic-sensitive" (TS) and "non-traffic sensitive" (NTS) rate
elements. The TS charge varies from one exchange to another, averaging
3.12 cents per minute nationwide. The NTS charge is currently fixed at
4.33 cents per minute for "terminating" access and 0.69 cents per minute
for "originating" access. Although most ESP networks, such as Telenet,
primarily involve dial-in rather than dial-out traffic (i.e., they operate
in an "originating" mode), under the FCC access charge rules ESPs would be
charged the higher "terminating " NTS rate. "Originating" rates are only
available for traffic that also terminates using dial access -- which
ordinary long distance (MTS) calls do, but most ESP traffic does not.
Thus, under the FCC's proposal, most ESPs would be subject to total charges
of 3.12 + 4.33 = 7.45 cents per minute, or $4.47 per hour, for dial-in or
dial-out access to the ESP's network.
IV. Policy Arguments
A number of compelling arguments can be made against the FCC's access
charge proposal. These include the following:
A. Impact on Information Services Industry
1. The access charge proposal would greatly increase the cost of on-
line computing and information services --hitting users of low-cost
services (especially in the home and educational markets) particularly
hard. Development of the market for such low-cost services would be
stifled, depriving U.S. consumers of affordable information services. In
addition, access charges would have a devastating affect on the Bulletin
Board System (BBS) community due to the cost-increase caused by access
charges.
2. Access charges would have serious indirect effects on the emerging
"information economy" and upon U.S. competitiveness in world markets. Such
charges would affect the viability and capability of the information
service infrastructure that supports U.S. industrial and commercial
activities.
3. Access charges would also have a direct negative effect on the
U.S. balance of trade. The information services industry is a bright spot
in the U.S. industrial trade picture, but its vitality, and thus its
ability to continue strong export sales, would be harmed by undermining its
domestic market.
4. Contrary to the FCC's claim, ESPs and their customers would
experience massive "rate shock" if access charges were applied to them --
just as in 1983, when the FCC noted this effect and decided not to take
such action.
5. Imposition of interstate access charges by the FCC would be an
open invitation for the state PUCs to do likewise for intrastate ESP
traffic. This would further increase the adverse financial impact upon
ESPs and their users. In addition, the FCC proposal has undesirable re-
regulatory implications, particularly at the state level.
B. Impact on Telephone Rates
There would be virtually no offsetting benefit to the consumer if
access charges were imposed on ESPs. There would be no change in the
price of local exchange services, and due to the enormous volume of
MTS/WATS traffic relative to ESP traffic, there would be only a tiny
potential reduction --estimated at less than one percent -- in the price of
long distance voice service.
C. Discrimination
1. The FCC proposal singles out computer services from all other non-
carrier users who pass interstate traffic through the local exchange. This
is clearly discriminatory. Moreover, there is no rationale for sweeping
any users of the network into the access charge pool.
2. The massive increase in the cost of VAN service would lead large
data communications users to consider alternative means of meeting their
needs. Large users with high traffic densities would implement private
networks which -- although perhaps more costly than their current VAN
service -- would avoid access charges. To the extent VANs lost traffic
from such users, their overall unit costs would increase. This would
impact small users who have no alternative but VAN service, thereby
exacerbating the large-vs-small user discrimination.
ACTIONS FOR PC PURSUIT CUSTOMERS
FCC Procedures and Recommended Actions for Telenet Customers and Their Users
As indicated in the attached NPRM, the FCC's access charge proposal is
the subject of a new rulemaking proceeding, CC Docket 87-215. The FCC has
scheduled two rounds of written comments in this docket. The Comment
period has been extended to September 24 with Reply Comments due on or
before October 26. Both before and after these filing dates, any
interested parties may discuss the issues with the FCC Commissioners and
staff. In addition, interested parties should consider contacting their
Congressional delegations and members of the House and Senate
Telecommunications Subcommittees since members of Congress can also
influence the FCC on behalf of their constituents.
A. Written Comments
Letters should be addressed to The Honorable Dennis Patrick, Chairman,
Federal Communications Commission, Washington, DC 20554, with copies to
the Secretary, Mr. William J. Tricarico; the Chief, Common Carrier Bureau,
Mr. Gerald Brock; and to each of the other three Commissioners:
Commissioner James Quello
Commissioner Mimi Weyforth Dawson
Commissioner Patricia Diaz Dennis
On the letter, indicate "RE: CC Docket 87-215".
In addition, we strongly recommend that you send copies of your
comments/reply comments and/or any correspondence to the FCC on this matter
to your Congressman, your two Senators, and the Chairmen of the House and
Senate Telecommunications Subcommittees. (The names and addresses of your
Congressional representatives can be obtained from your local library,
Chamber of Commerce or your local Democratic or Republican headquarters.) A
cover letter should be attached, stressing the importance of this issue and
asking the Member of Congress to express his/her concerns to the FCC. The
subcommittee chairmen are:
The Honorable Edward J. Markey, Chairman
Subcommittee on Telecommunications and Finance
Committee on Energy and Commerce
U.S. House of Representatives
Washington, DC 20515
The Honorable Daniel K. Inouye, Chairman
Subcommittee on Communications
Committee on Commerce, Science and Transportation
U.S. Senate
Washington, DC 20510
xxxx Please also forward a copy to Telenet's Regulatory Affairs Dept.
(12490 Sunrise Valley Dr., Reston, VA 22096), so that we will be aware of
it in our lobbying efforts.
B. Lobbying
Interested parties may discuss the issues in this docket with the FCC
Commissioners and staff at any time prior to the FCC's issuance of a
"Sunshine" notice stating that it plans to consider the matter at its next
Public Meeting --which will probably occur sometime in November or
December. It is perfectly appropriate to contact the FCC now if you have
any questions about this matter, but meetings and telephone calls for the
purpose of lobbying your views are generally most effective after the two
rounds of written comments are completed -- i.e., after October 26.
If you choose to follow-up your letter with a telephone call, such
contacts should be focused on the four Commissioners, the Common Carrier
Bureau Chief, and the Chief of the Bureau's Policy Division. Their phone
numbers are:
Chairman Dennis Patrick 202-632-6600
Commissioner James Quello 202-632-7557
Commissioner Mimi Dawson 202-632-6446
Commissioner Patricia Dennis 202-632-6996
Gerald Brock, Chief, Common Carrier Bureau 202-632-6910
Thomas Sugrue, Chief, Policy Division, Common Carrier Bureau
202-632-9342W8SDZ@SIMTEL20.ARPA.UUCP (08/15/87)
Telenet Communications Corporation
12490 Sunrise Valley Drive July 23, 1987
Reston, Va. 22096
THE FCC PROPOSAL TO IMPOSE ACCESS CHARGES
ON ENHANCED SERVICE PROVIDERS
ISSUE ANALYSIS
I. Background
--------------
Under the FCC's rules adopted in the Second Computer Inquiry (often
called Computer II) in 1980, computer based services such as protocol
conversion (an integral part of Telenet's public packet network service),
database access, time-sharing and other remote computing services, home
banking/shopping services, electronic mail, and voice messaging services are
defined as "enhanced services," and firms providing such services to the
public are "enhanced service providers" (ESPs). The FCC's rules provide that
enhanced services are not a common carrier activity, and ESPs may not be
regulated as carriers at either the federal or state level. Thus, ESPs are
treated by local exchange carriers (LECs), i.e., local telephone companies,
the same as any other non-carrier user of the local exchange; that is, ESPs
pay ordinary business telephone rates for the local exchange dial lines (often
called 1MB or B-1 lines) that they utilize. Such dial lines are typically
connected to an ESP's equipment in a particular locality (e.g., a packet
switch or data concentrator) for dial-in access to the ESP's private-line
network and/or host computer(s), and typically carry a mixture of interstate
and intrastate traffic.
In contrast, long-distance common carriers (e.g., AT&T, MCI and US
Sprint) pay "carrier access charges" for their use of the local exchange dial
network to access their customers. Such carriers pay FCC-imposed access
charges for their interstate traffic and they pay access charges imposed by
the various state public utility commissions (PUCs) for their intrastate
traffic. In both cases, the charge is levied on a per-minute-of-use basis,
unlike the flat rates charged for 1MB business telephone lines.(1)
Carrier access charges were introduced in 1984 by the FCC, concurrent
with the AT&T divestiture, to replace the long-standing system of "settlements
and division of revenue" wherein revenues for long-distance telephone service
were allocated within the pre-divestiture Bell System and shared with the
independent telephone companies. Such access charges also replaced an interim
system of charges for local access paid by the new competitive long-distance
carriers such as MCI and Sprint.
The FCC's initial access charge plan, issued in 1983, would have
applied such charges to ESPs, on the theory that ESPs - like the long-distance
carriers - utilize the local exchange network to originate or terminate their
interstate traffic. However, on reconsideration the FCC decided not to apply
such charges to ESPs, recognizing that private voice and data networks
operated by corporations, government agencies, etc., also "leak" interstate
traffic to/from the local exchange. The FCC expressed the desire to impose
carrier access charges on all such traffic, but noted that there is no way for
the LEC to measure the interstate minutes-of-use on dial lines connected to an
ESP or "leaky PBX", and thus no effective way to apply a per-minute access
charge to such traffic.(2)
The FCC's 1983 decision, as modified, applied carrier access charges
only to long-distance carriers providing MTS/WATS-equivalent services via
their own interstate facilities.(3) Subsequently, in Docket 86-1, the FCC
applied carrier access charges to other interstate common carriers, such as
WATS resellers (firms which use WATS service in lieu of their own facilities,
to provide MTS-type service) and telex carriers.
II. Summary of the FCC's Proposal
----------------------------------
As stated in the attached Notice of Proposed Rule Making (NPRM), the
FCC proposes to apply its carrier access charges to all ESPs who utilize local
exchange dial lines to originate or terminate interstate traffic. Such access
charges would be in lieu of the 1MB rates currently paid by ESPs, effective as
of January 1, 1988. The FCC's "enhanced service" definition, as discussed
above, would encompass VANs, such as Telenet, and any type of host-based
services provided to external users for a fee. (That is, an organization
providing computer services solely to its own employees would not be
considered an ESP, as we understand the FCC's intent.)
In short, the carrier access charges would apply to:
* All interstate traffic utilizing local dial access on public
packet-switching networks such as Telenet;
* All interstate traffic utilizing local dial access on a "private"
network operated by an ESP to provide host-based services - e.g., where a firm
providing database services utilizes an interstate private line with a remote
data concentrator equipped with dial-in ports; and
* The portion of traffic from "external" users on a private network
such as the previous case, where the network serves a mixture of "internal"
and "external" users.
Thus, access charges would affect not only VANs such as Telenet, but all
organizations providing database services, electronic mail, transaction
processing and other on-line services via interstate private lines with dial
access.
III. Financial Impact on Telenet and Its Customers
---------------------------------------------------
The FCC's rate structure for carrier access charges includes two
components: "traffic-sensitive" (TS) and "non-traffic sensitive" (NTS) rate
elements.(4) In theory, the TS rate element - which is composed of several
sub-elements - recovers the LEC's actual cost of providing dial access to the
long-distance carrier whereas the NTS rate element is primarily a subsidy
mechanism, used to fund a portion of the costs of local exchange service. The
NTS charge, together with the FCC-imposed Subscriber Line Charge (SLC) on each
business and residence exchange line, provides a pool of funds that are
distributed to the LECs to subsidize the price of residential local telephone
service.(5)
The TS charge varies from one exchange to another, averaging 3.12
cents per minute nationwide. The NTS charge is currently fixed at 4.33 cents
per minute for "terminating" access and 0.69 cents per minute for
"originating" access. Although most ESP networks, such as Telenet, primarily
involve dial-in rather than dial-out traffic (i.e., they operate in an
"originating" mode), under the FCC access charge rules ESPs would be charged
the higher "terminating" NTS rate. "Originating" rates are only available for
traffic that also terminates using dial access - which ordinary long distance
(MTS) calls do, but most ESP traffic does not.(6) Thus, under the FCC's
proposal, an ESP would be subject to total charges of 3.12 + 4.33 = 7.45 cents
per minute, or $4.47 per hour, for dial-in or dial-out access to the ESP's
network.
Although Telenet has made no firm decisions on the matter, it is
unlikely that we could absorb any significant portion of such an enormous cost
increase; thus we would have to pass the increase on to our customers. Since
Telenet's current daytime dial-in rates typically range between $4 and $8 per
hour - with actual figures for a particular customer depending on several
factors such as monthly volume and mix of A/B/C city traffic - this could
amount to a 60-100 percent price increase.
The impact on our evening/weekend rates would be much more dramatic.
Such rates are heavily discounted and amount to less than $1 per hour for
high-volume Nightline customers. Since there is no time-of-day discount in
the carrier access charges, the FCC's proposal would increase these Telenet
prices by more than 500 percent.
IV. Policy Arguments
---------------------
A number of compelling arguments can be made against the FCC's access
charge proposal. These include the following:
A. Impact on Information Services Industry
1. The access charge proposal would greatly increase the cost of
on-line computing and information services - hitting users of low-cost
services (especially in the home and educational markets) particularly hard.
Development of the market for such low-cost services would be stifled,
depriving U.S. consumers of affordable information services.
2. Access charges would have serious indirect effects upon the
emerging "information economy" and upon U.S. competitiveness in world
markets. Such charges would affect the viability and capability of the
information service infrastructure that supports U.S. industrial and
commercial activities.
3. Access charges would also have a direct negative effect upon the
U.S. balance of trade. The information services industry is a bright spot in
our industrial trade picture, but its vitality and thus its ability to
continue strong export sales would be harmed by undermining its domestic
market.
4. Contrary to the FCC's claim (NPRM, para. 9), carrier access charges
remain nearly as high as when they were introduced in 1984. The NTS
terminating rate (which ESPs would pay) has fallen only 18%, and the TS rates
are essentially unchanged; the total average rate has fallen only 11%. The
current total rate is approximately 15 times higher than the average price of
1MB line, and ESPs would still experience massive "rate shock" if access
charges were applied to them - just as in 1983, when the FCC noted this effect
and decided not to take such action.
5. Imposition of interstate access charges by the FCC would be an open
invitation for the state PUCs to do likewise for intrastate ESP traffic. This
would further increase the adverse financial impact upon ESPs and their
users. Moreover, the ability of the FCC and the state PUCs to single out ESPs
for an access charge "tax" increases the probability of their imposing other
regulatory requirements on such firms in the future. In other words - in
addition to its direct financial impact - the FCC proposal has undesirable
re-regulatory implications, particularly at the state level.
B. Impact on Telephone Rates
There would be virtually no offsetting benefit to the consumer if access
charges were imposed on ESPs. The total size of the NTS subsidy pool would
not increase; rather, the pool would be spread over a slightly larger base of
usage minutes. Thus, there would be no change in the price of local exchange
service. Due to the enormous volume of MTS/WATS traffic relative to ESP
traffic, there would be only a tiny potential reduction - estimated at less
than one percent - in the price of long distance service.
C. Discrimination
1. In attempting to cure alleged discriminatory treatment of
long-distance carriers vis-a-vis ESPs, the FCC would be merely substituting
one form of discrimination for another: ESPs would be singled out from all
other non-carrier users who pass interstate traffic through the local exchange
and would be forced to pay drastically higher rates for identical service.
2. The massive increase in the cost of VAN service would lead users to
consider alternative means of meeting their needs. Large users with high
traffic densities could implement private networks which - although perhaps
more costly than their current VAN service - would avoid the access charges.
To the extent VAN lost traffic from such users, their over all unit cost of
service would increase. This would impact the small users who have no
alternative but VAN service, thereby further exacerbating the large-vs.-small
user discrimination.
D. The FCC's "Equity" Argument; Purpose of Access Charge
The FCC apparently feels that because long-distance carriers pay access
charges for their use of the local exchange, ESPs should pay likewise. But
this ignores the fact that users and carriers have always paid differently for
their use of the local exchange - with carriers first paying through the
pre-divestiture system of settlements and division of revenues, and then
paying access charges. The historical purpose of charging carriers these
above-cost rates has been for long distance telephone service to subsidize
local telephone service; nothing has changed which would warrant changing this
basic principle and sweeping users of the network into the access charge pool.
E. Bypass of the Local Exchange
Another effect of the access charge proposal would be to exacerbate the trend
towards bypass of the local exchange - an outcome that the FCC has sought to
minimize. VANs and other ESPs would look for alternative network technologies
and configurations to avoid using dial access, such as local digital radio and
terminal concentrators on dedicated lines. To the extent such bypass
alternatives are more costly than the true cost of local dial service, they
represent a loss to the economy due to the FCC's artificial pricing barriers.
F. Traffic Measurement and Enforcement
Today as in 1983, the LECs have no ability to measure interstate ESP traffic
(i.e., to determine which dial calls to an ESP will leave the state via the
ESP's private-line network and which will not). Nor can they determine which
entities are ESP's in whole or in part. Consequently, the proposed rule would
be impossible to enforce fairly and evenly. Many entities which "should" pay,
at least for a portion of their traffic, would escape; and entities seeking in
good faith to comply with the rule would presumably have the burden of
measuring their own "interstate enhanced service" traffic, and would be
subject to potential liability for any errors.
ACTIONS FOR TELENET CUSTOMERS AND THEIR USERS
-----------------------------------------------
Although any of the above arguments could be made by any party, users
and providers of enhanced services - such as the Telenet customer and his
users - are particularly well-suited to address topic A (impact on computing
and information services and the indirect consequences for the U.S. society
and economy) and topic C (discrimination among different classes of users of
the local exchange). We urge you to give these topics special attention in
your comments to the FCC.
In particular, please note the information requested in paragraph 10
of the NPRM regarding "rate shock" issues - particularly the impact of the
proposed access charges upon demand and revenues for enhanced services and
growth of the industry. If you feel that the FCC proposal would have a
material effect upon user demand for any enhanced services you may provide, I
would urge you to submit whatever data is publicly available regarding your
rates, revenues and growth rate, and how these might be affected by access
charges.
FCC Procedures and Recommended Actions
for Telenet Customers and Their Users
As indicated in the attached NPRM, the FCC's access charge proposal is
the subject of a new rulemaking proceeding, CC Docket No. 87-215. The FCC has
scheduled two rounds of written comments in this docket - initial comments,
due August 24, 1987, and reply comments, due September 14, 1987. Both before
and after these filing dates, any interested parties may discuss the issues
with the FCC Commissioners and staff. In addition, interested parties should
consider contacting their Congressional delegations and members of the House
and Senate Telecommunications Subcommittees, since members of Congress can
also influence the FCC on behalf of their constituents.
A. Written Comments
Written comments addressed to the FCC can take two forms: formal
legal briefs, and informal correspondence (with relevant attachments, in
either case). Formal briefs are preferred if you have an attorney available
to prepare them, because they tend to be taken more seriously by the FCC, but
an informal letter signed by senior management of your organization and
expressing the same points can also be quite effective.
Your initial submission should be made by the August 24 deadline, with
the September 14 filing (which is optional) reserved for a reply in support or
rebuttal of the initial comments filed by other parties. The FCC is somewhat
flexible about this, however, and parties who have not filed comments by the
first-round due date often submit "reply" comments containing whatever
arguments they wish to make.
If you file formal comments and/or reply comments, they should be
typed on 8 1/2 x 11" paper, double-spaced, and should have a caption on the
first page the same as that shown at the top of the lNPRM to identify the
docket. An original and five copies should be submitted to the Secretary,
Federal Communications Commission, Washington, DC 20554, by the respective
due dates. A copy should also be sent to Gerald Brock, Chief, Common Carrier
Bureau, at the same address.
If you prefer to write a letter, it should be addressed to The
Honorable Dennis Patrick, Chairman, at the same address, with copies to the
Secretary, to Mr. Brock, and to each of the other three Commissioners:
Commissioner James Quello
Commissioner Mimi Weyforth Dawson
commissioner Patricia Diaz Dennis
On the letter, indicate "RE: CC Docket 87-215".
In additional, we strongly recommend that you send copies of your
comments/reply comments and/or any correspondence to the FCC on this matter to
your Congressman, your two Senators, and the Chairmen of the House and Senate
Telecommunications Subcommittees. (The names and addresses of your
Congressional representatives can be obtained from your local library, Chamber
of Commerce or your local Democratic or Republican headquarters). A cover
letter should be attached, stressing the importance of this issue and asking
the Member of Congress to express his/her concerns to the FCC. The
subcommittee chairmen are:
The Honorable Edward J. Markey, Chairman
Subcommittee on Telecommunications and
Finance Committee on Energy and Commerce
U.S. House of Representatives
Washington, DC 20510
The Honorable Daniel K. Inouye, Chairman
Subcommittee on Communications
Committee on Commerce, Science and Transportation
U.S. Senate
Washington, DC 20510
Please remember to send to Telenet's Regulatory Affairs Dept. (12490
Sunrise Valley Dr., Reston, VA 22096) a blind copy of whatever you file with
the FCC, so that we will be aware of it in our lobbying efforts.
B. Lobbying
Interested parties may discuss the issues in this docket with the FCC
Commissioners and staff at any time prior to the FCC's issuance of a
"Sunshine" notice stating that it plans to consider the matter at its next
Public Meeting - which will probably occur sometime in October or November.
It is perfectly appropriate to contact the FCC now if you have any questions
about this matter, but meetings and telephone calls for the purpose of
lobbying your views are generally most effective after the two rounds of
written comments are completed - i.e., after September 14.
At that time, we suggest that you call or visit as many of the key FCC
decision-makers as possible, to follow-up on your written comments and make
your views known in person. Such contacts should be focused on the four
Commissioners, the Common Carrier Bureau Chief, and the Chief of the Bureau's
Policy Division. Their phone numbers are:
Chairman Dennis Patrick 202-632-6600
Commissioner James Quello 202-632-7557
Commissioner Mimi Dawson 202-632-6446
Commissioner Patricia Dennis 202-632-6996
Gerald Brock Chief, Common Carrier Bureau 202-632-6910
Thomas Sugrue, Chief, Policy Division,
Common Carrier Bureau 202-632-9342
Such discussions with FCC personnel are known as exparte contacts and
are discussed in paragraphs 15-16 of the NPRM. The key point is that if you
make a presentation including arguments not covered in your previously-filed
written comments, the rules require that a short summary of the presentation
be sent to the Secretary's office for inclusion in the docket file, with a
copy to the FCC personnel to whom the presentation was made. Copies of any
handout material from presentations to FCC personnel are normally sent to the
Secretary's office even when the material covered was discussed previously in
written comments.
FOOTNOTES:
-------------
1. The FCC's ESP access charge proposal would apply only to interstate
traffic, although if adopted it is likely that at least some state PUCs would
follow the FCC's lead and impose their intrastate access charges on ESPs as
well. This memo discusses only the FCC proposal.
2. The FCC directed the LECs to develop a means of measuring such interstate
traffic, and to report on their progress. To our knowledge, no such reports
have been made, and the situation today remains as it was in 1983: The LECs
have no means of determining which local dial calls to or from a customer's
data or voice equipment are, in fact, interstate in nature.
3. MTS, or message telecommunications service, is the ordinary long-distance
dial telephone service furnished by AT&T and its competitors such as MCI and
US Sprint. WATs, or wide are telecommunications service, is similar to MTS
but priced on a bulk basis for large users.
4. The NTS rate element is also called the "Carrier Common Line" (CCL) charge,
and is referred to as such in the NPRM.
5. As discussed in footnote 26 of the FCC's NPRM, the SLC on residence lines
is currently capped at $2.60 per line per month, and will increase somewhat in
the future. The SLC on the business lines (IMB lines) is capped at $6.00 per
line per month, and is not expected to increase in the future. Each LEC sets
the actual SLC rates in its territory, subject to these caps.
6. See NPRM, paragraph 9 and footnote 26.
* * * * * * * * * * * * * * * *