[comp.dcom.telecom] Hollings and Pac*Bell

John Higdon <john@zygot.ati.com> (06/05/91)

Pac*Bell has given those of us who care to look a glimpse of the
future under the Hollings bill that permits the RBOCs to enter the
world of equipment manufacturing. It is call "The Message Center", and
while it is not exactly "hardware", it is a good example of how
Pac*Bell intends to compete in the marketplace.

The "Message Center" is a voicemail service that directly competes
with voicemail service bureaus. It will answer your phone after a
preset number of rings, allow you to retrieve your messages from
anywhere, and will put "stutter" dial tone on your phone if there are
messages waiting.

What is wrong with this? First, it is priced well below most service
bureaus. Using the vast capital resources available courtesy of its
ratepayers, Pac*Bell can offer this service at a preditory price that
is designed to murder the competition. When the field has been thinned
out sufficiently, then the price can be whatever it wants.

With a service bureau, it is necessary to forward calls to the special
number it provides for your mail box. This results in at least local
charges for the forwarded calls. Pac*Bell, being "the phone company"
does not worry about this and will tout this as an advantage for its
own system (no local charges).

And no service bureau can provide "stutter" dial tone on your
telephone if you have messages holding. Another EXCLUSIVE Pac*Bell
advantage -- exploiting the fact that it controls the network.

This is how Pac*Bell would play in the equipment market. "Buy our
system. It has special features that no other system can provide." And
it would have those features because if you bought the Pac*Bell
system, special signals or what-have-you could be sent from the CO to
enable the exclusive selling points--signals that would be denied
ordinary vendors. In other words, Pac*Bell would use its capital from
the regulated services to subsidize preditory pricing, while using its
position as controller of the network to provide "exclusive" services.

If you doubt this, just look at "The Message Center" and ask yourself
these questions:

1. Why does "The Message Center" offer features I can't get anywhere
   else?

2. Why does it cost less than any other comparable service?

3. What will it cost when the competition is driven out of the market?

What would you think of ConEd or PG&E selling appliances, claiming
that this would advance the state of the art, benefit the handicapped,
improve the quality of life, etc., etc.?

Let us hope the Hollings bill dies a well-deserved death in the House.


        John Higdon         |   P. O. Box 7648   |   +1 408 723 1395
    john@zygot.ati.com      | San Jose, CA 95150 |       M o o !


[Moderator's Note: But actually, in Chicago the Commonwealth Edison
Company does offer 'light bulb service'. For every paid electric bill
you turn in, you can have four bulbs (various wattages) for every ten
dollars or so on the bill.  No one complains about it, and I am not
about to complain about Ameritech/Illinois Bell's voicemail service
here. I think it beats out any of the others at half the price.  PAT]

Charlie Mingo <Charlie.Mingo@f421.n109.z1.fidonet.org> (06/09/91)

In a recent posting, John Higdon attacks Pac*Bell's new voicemail
service, because it is priced "well below" that of Pac*Bell's
competitors, and because it offers features which the local telephone
company is uniquely capable of providing. He claims that this is part
of a strategy of "predatory pric[ing] designed to murder the
competition," and argues that Pac*Bell's voicemail service offers "a
glimpse of the future under the Hollings bill" (which would permit
RBOC's to manufacture telephone equipment) and goes on to call for the
bill to be defeated in the House.  Although I take no position on the
Hollings bill itself, it sounds perverse to me to attack a company for
offering quality service at a low price.

    It must be remembered that antitrust law generally (and the Bell
divestiture in particular) was designed to benefit *consumers* not
competitors.  "Predatory pricing," for example, is defined as selling
a product *below the cost of production* for the purpose of eventually
monopolizing a market. Mr. Higdon provides no evidence that Pac*Bell
has priced its voicemail service below the cost of providing it; on
the contrary, he himself shows that Pac*Bell's size and credit rating
give it easier access to capital, which lowers its cost of providing
the service. This is a natural advantage which large, established
companies have over smaller ones; pricing one's goods to reflect one's
lower cost structure is neither anticompetative nor "unfair."

    Mr. Higdon also writes that "[w]hen the field has been thinned out
sufficiently, then the price can be whatever [Pac*Bell] wants." It
should be clear that Pac*Bell cannot raise the price of voicemail in
the future above what independent providers currently charge, without
allowing the competition to reestablish itself.  Given this
limitation, any such "predatory pricing" strategy would be decidedly
unprofitable.

    Likewise, his argument that Pac*Bell should be prevented from
offering voicemail, because it alone is in a technical position to
provide special services (such as "stutter" dialtone and free call
forwarding), is similarly flawed. Consumers would not be better off by
making these desirable features unavailable merely to protect
inefficient competition. (Of course, if it is possible to extend these
feature to competitors' services, Pac*Bell should be required to.)
The key concept here should be service to consumers, and not
"fairness" to competitors.

john@apple.com> (06/09/91)

On Jun 9 at  1:28, Bob Frankston writes:

> Pac*Bell is able to provide some compelling features because it owns
> the network.  The issue is not simply one of pricing but rather the
> fact that it can create the protocols it needs to provide the
> services.  In fact, many of the protocols are intranetwork protocols
> that are generally available to telcos.

Information and service bureau providers will tell you that they can
beg, plead, demand, suggest, and cajole until they are blue in the
corporate face, but Pac*Bell could not care less about a given
protocol or service enhancement until IT needs it. Then it will
sluggishly make it available to outside parties at a cost that usually
seems out of line. For example, service bureaus can offer stutter dial
tone just like The Message Center -- IF they are willing to install and
pay for a dedicated data line TO EACH SWITCH in which they wish to
provide the feature.

>  A common theme of my messages is that these protocols must be exportable.  
>  Unfortunately, protocols generally means CCITT and a design cycle the 
>  guarantees irrelevance.

But when they are exportable, they are almost always skewed to the
regulated telco's advantage.

> In the spirit of naive optimism I'd like to see a law that allows
> telcos to offer these services but with the condition that they
> services be done with an arms length sub and that any protocols used
> would be made generally available to third parties.

Given that the resources for completely auditing an RBOC do not exist,
I would submit that there is no such thing as "arms' length". "No
connection", "not affiliated with", "no common ownership", now THAT is
arms' length.

> Making these protocols available external raises many network
> integrity and  performance issues, but these issues must be faced
> otherwise the Judge Greene error is for naught.

It is the cornerstone of the whole divestiture exercise. If there is
to be an expectation of fair competition, everything must ultimately
become available externally.

I thought I would share with all of you a little analogy.

Let's say I owned a bus company (that competed with other bus
companies) and I also owned a bridge that carried a major highway. I
have decided that my bus company is going to "win". To do that, I put
luxurious busses on my routes, increase my runs per hour (to make it
convenient to riders), and lower my rates to the point that anyone
would be stupid to ride the competition. What a boon to consumers.
Excellent bus service at cheap rates. Only an ogre could attack that,
right?

But these things cost money. My busses don't pay their way as it is
and now with my increased service the cash flow is really lacking.
What do I do? I increase the tolls on my bridge to an astronomical
figure. The people who cross the bridge have no choice; they must
cross my bridge to get to where they are going. They must pay my toll.
Now I have the money to run my superior bus company. I put the
competition out of business. Now, not only must people cross my bridge
(and pay anything I demand), but they must ride ONLY my busses and pay
whatever I now decide to charge. The competition? They sold their
busses to me (at distressed prices) before they went bankrupt. We
won't be hearing from them any time soon.

Far fetched? Have you ever heard of the Golden Gate Transit Authority?


        John Higdon         |   P. O. Box 7648   |   +1 408 723 1395
    john@zygot.ati.com      | San Jose, CA 95150 |       M o o !

Bob Frankston <Bob_Frankston%Slate_Corporation@mcimail.com> (06/09/91)

The issue of protocols raises its ugly head.

Pac*Bell is able to provide some compelling features because it owns
the network.  The issue is not simply one of pricing but rather the
fact that it can create the protocols it needs to provide the services.  
In fact, many of the protocols are intranetwork protocols that are
generally available to telcos.

A common theme of my messages is that these protocols must be
exportable.  Unfortunately, protocols generally means CCITT and a
design cycle that guarantees irrelevance.

In the spirit of naive optimism I'd like to see a law that allows
telcos to offer these services but with the condition that the
services be done with an arms length subsidiary and that any protocols
used would be made generally available to third parties.

Understanding the difficulty of designing good protocols, there would
be a grace period in which they can experiment with protocols without
invoking the full standards wrath but that they would have to have a
process for advancing the protocols beyond their initial design.
Perhaps they would also be allowed a not-for-profit grace period in
which they can experimentally try out the services.

I do appreciate the difficulty of creating good protocols and I don't
want to inhibit the process but with transition from POTS to ISDN and
other digital interfaces, we need to realize that the ability to offer
these services, even in arms-length subsidiaries with no revenue
sharing, is based on a policy of proprietary protocols.

Making these protocols available external raises many network
integrity and performance issues, but these issues must be faced
otherwise the Judge Greene error is for naught.


[Moderator's Note: One of the nicest features of telco-operated voice
mail is the stutter dialtone which advises the subscriber of new
messages waiting. It should not be that hard for telco to provide this
to the competitors: A third-party voice mail system would send
messages to the serving CO (of the subscriber) saying 'turn on
stutter' or 'turn off stutter'. They'd send this message on a special
data circuit, and your CO would toggle it on or off, just as it does
now for telco's own voicemail service.  Also, telco *could* now
provide 'programmable forward on busy / no answer' if they wanted to.
Ameritech Mobile presently allows me to toggle 'forward on busy / no
answer' as I wish; AND program it to any number, anywhere, but
Illinois Bell (my hardwired service) insists that this feature can
only be programmed in the CO on a work order (that of course means a
fee), and that it cannot be turned off or on (except by CO action),
and that forwarding MUST be to another number in the same exchange!
Phooey on that ... it is useless to me. So they could give these two
items to competing voicemail operators if they wanted to.  PAT]

John Higdon <john@zygot.ati.com> (06/09/91)

Charlie Mingo <Charlie.Mingo@f421.n109.z1.fidonet.org> writes:

[The usual uninformed, simplistic response citing the short term
effects of monopolistic behavior.]

Since my points, which I thought to be more than clear, were not
understood by all, I will support them one by one.

> Although I take no position on the
> Hollings bill itself, it sounds perverse to me to attack a company for
> offering quality service at a low price.

Regardless of how it manages to do that? If it does so by taking from
regulated ratepayers and then undercutting legitimate competition
through its control of the network AND subsidization from capital
derived from other captive customers, you do not feel that worthy of
attack? Especially when those regulated ratepayers are taking it in
the shorts with rate hikes and rapidly deteriorating service. Too bad
those "inefficient" competitors do not have a nice regulated ratebase
cash cow that they can squeeze more capital from when desired.

> "Predatory pricing," for example, is defined as selling
> a product *below the cost of production* for the purpose of eventually
> monopolizing a market. Mr. Higdon provides no evidence...

Sorry. Here is the evidence. For $4.50, Pac*Bell provides The Message
Center. Nothing else is necessary. CF/No Answer, CF/Busy, and standard
CF are included for voicemail purposes. Last time I checked, the going
rate for the forwarding services alone exceeded $4.50. Either Pac*Bell
is overcharging its forwarding customers, or it is giving away the
store to its VM customers. Which is it?

> This is a natural advantage which large, established
> companies have over smaller ones; pricing one's goods to reflect one's
> lower cost structure is neither anticompetative nor "unfair."

It is also an advantage enjoyed by companies that control the MEANS of
service delivery, have sources of income that are decreed in statute
(FCC and PUC R&R), and have colusion with other entities. And I
disagree: this is BOTH anticompetitive AND unfair.

>     Mr. Higdon also writes that "[w]hen the field has been thinned out
> sufficiently, then the price can be whatever [Pac*Bell] wants." It
> should be clear that Pac*Bell cannot raise the price of voicemail in
> the future above what independent providers currently charge, without
> allowing the competition to reestablish itself.

I do not understand this at all. Why not? What magic force will
prevent Pac*Bell from marching right up to the PUC to claim that it
must charge more for the service? It will not be hard to make a
convincing case, since it probably should have been charging more all
along. Only at this point it can have ALL the business.

>     Likewise, his argument that Pac*Bell should be prevented from
> offering voicemail, because it alone is in a technical position to
> provide special services (such as "stutter" dialtone and free call
> forwarding), is similarly flawed. Consumers would not be better off by
> making these desirable features unavailable merely to protect
> inefficient competition. (Of course, if it is possible to extend these
> feature to competitors' services, Pac*Bell should be required to.)
> The key concept here should be service to consumers, and not
> "fairness" to competitors.

In your imaginary, fairytale world, maybe. I am sorry to be so harsh,
but you are obviously light years away from the day to day grunge of
this business. Other VM companies can, indeed, offer any techincal
service Pac*Bell provides IF they are willing to, themselves, buy the
means from (guess who) Pac*Bell. This is the multi-layered whammy.
Pac*Bell offers stutter dial tone. That is easy; the system lives in
the CO anyhow. Mr. Service Bureau can do it by paying Pac*Bell for a
dedicated data circuit to each and every switch that Mr. B wishes to
serve. So now Pac*Bell has a bigger piece of Mr. B's income, it
enriches itself, keeps Mr. B's prices higher, etc., etc. For Pac*Bell,
it is a win/win/win situation.

Pac*Bell only provides things like stutter dial tone activation when
it deems such a feature useful for its own marketing purposes. VM
bureaus have been requesting it for years. Now it is available because
Pac*Bell, itself, wants it. But Pac*Bell gets it free (or rather
buried under unauditable paperwork), while it SELLS it to others.

Another example: From Pac*Bell payphones a call to any Bay Area
Cellular One (owned by McCaw and PacTel) number cost twenty cents,
untimed regardless of distance from the phone to where the number is
based.  Calls to GTE Mobilnet numbers from those same payphones go
full toll. Why? The cellular companies buy a connection package to
link to the landline carrier (Pac*Bell). The "no toll" payphone
package costs MUCH more than the standard one. But since there is
common ownership between the cellular company and the landline
carrier, it makes no difference what the higher charge is; it all
circulates in the same pocket anyhow.

But cross subsidy is not permitted, you say. Maybe not, but until
someone produces a full, verified audit of Pacific Telesis and its
subsidiaries then I am going to assume that which appears to be
self-evident.

If you want to fall for the Pac*Bell line of "we can do it better and
we can do it cheaper", then go for it. But please do not expect all of
us to bury our heads in the sand with you.


        John Higdon         |   P. O. Box 7648   |   +1 408 723 1395
    john@zygot.ati.com      | San Jose, CA 95150 |       M o o !

Jim.Redelfs@uunet.uu.net> (06/09/91)

[Disclaimer:  I am an 18+ year employee of US WEST Communications - JR]

John Higdon wrote:
  
> Pac*Bell has given those of us who care to look a glimpse of the
> future under the Hollings bill that permits the RBOCs to enter the
> world of equipment manufacturing. It is call "The Message Center",
> and while it is not exactly "hardware", it is a good example of how
> Pac*Bell intends to compete in the marketplace. The "Message Center"
> is a voicemail service...
  
Sir, I believe I have seen enough advantages of the uniqueness of
TelCom within the state of Nebraska that I can conclude that (nearly)
complete DEregulation of the these companies are in the ratepayer's
best interest.
  
By some accounts, L.B.835, the landmark legislation that was passed
into law by Nebraska's Unicameral several years ago, was RAMMED down
the representative's throats. Be that as it may (but I disagree), the
horrible effects that were predicted by the opponents have not come to
past.
  
Our local rates have not risen disproportionately.  Competition has
not been swallowed up - indeed it has thrived.  Service is excellent
and the rates are "reasonable" (certainly among the average, if not
below).
  
US WEST Communications began offering "Business Voice Messaging" quite
a while ago, and it has been in the residential market for some
months.  All is going well, it is being well accepted and subscribed
to.
  
> [This service] ...will answer your phone after a preset number of rings, 
> allow you to retrieve your messages from anywhere, and will put "stutter"
> dial tone on your phone if there are messages waiting.
  
It is an excellent service.  (I do not subscribe to it.)
  
> [This service] ...directly competes with voicemail service bureaus.
  
Horrors!    
  
> What is wrong with this?  First, it is priced well below most
> service bureaus.
  
I have not checked, so I cannot dispute your claim, but what's wrong
with charging less than your competition - even in this case?  Do you
suppose the regulatory agency would approve of the TelCo charging
substantially MORE that it costs to PROVIDE the service?  No way.

> Using the vast capital resources available courtesy of its
> ratepayers, Pac*Bell can offer this service at a preditory price that
> is designed to murder the competition. When the field has been
> thinned out sufficiently, then the price can be whatever it wants.
  
Given that exagerated scenerio, you should be the first on your block,
possibly state, to appear during their rate hearings and request that
Pac*Bell charge MORE for their service!
  
[Re: House Resolution that would relax some of the constraints that
were placed on the Bell Operating Companies as a result of the
Modified Final Judgement in 1984] ...
  
> Let us hope the Hollings bill dies a well-deserved death in the House.
  
I hope not.  In fact, this concern may cause me to write my FIRST
letter to my elected representatives - in SUPPORT of the bill.

I think it is time for a little SUBSIDY of my local service!  And if
the little guy can't hack the competition (REAL competition) that is
SLOWLY entering his domain after an absence of almost EIGHT years, so
be it.
  
The Bell Operating Companies have a great potential - a LOT of which
was hogtied by Judge Harold Greene.  I think the time is LONG OVERDUE
that they be allowed to ENDOW us lowly ratepayers with some of this
FABULOUS technology that, until now, had been either in development,
legally KEPT from us, or available or AFFORDABLE only to business
customers!
  
I am not advocating, and would certainly resist, a return to the good,
old days when the phone company was the only show in town.  (Remember
when they OWNED the wire and jacks in your home, as well as everything
that was plugged into the system?)
  
But, I think a little relaxation of the MFJ would be a good thing.
The BOCs have concentrated their efforts since deregulation on those
areas where they were legally allowed (with the odd exception
[blush]), and the time has come to see what they can do in their other
areas of expertise.
  

JR
  
[Dislclaimer: The above does not necessarily reflect the opinions of
my employer - JR]
    
 --- Tabby 2.2
 MacNet Omaha 402-289-2899 On loan from Mrs MacWidow (1:285/14)

andys@ulysses.att.com (06/09/91)

In article <telecom11.438.3@eecs.nwu.edu> Charlie Mingo writes:

> In a recent posting, John Higdon attacks Pac*Bell's new voicemail
> service, because it is priced "well below" that of Pac*Bell's
> competitors, and because it offers features which the local telephone
> company is uniquely capable of providing. He claims that this is part
> of a strategy of "predatory pric[ing] designed to murder the
> competition," and argues that Pac*Bell's voicemail service offers "a
> glimpse of the future under the Hollings bill" (which would permit
> RBOC's to manufacture telephone equipment) and goes on to call for the
> bill to be defeated in the House.  Although I take no position on the
> Hollings bill itself, it sounds perverse to me to attack a company for
> offering quality service at a low price.

That isn't what he attacked them for.  He attacked them for a) using
their regulated business to subsidize unregulated business b) using
their position as a regulated monopoly to provide unregulated services
that were unavailable to their competitors.

>    It must be remembered that antitrust law generally (and the Bell
> divestiture in particular) was designed to benefit *consumers* not
> competitors.

Interesting mythology.  Where did you find it?  I've seen no evidence
that government intentions regards antitrust law in general or in US
vs AT&T in particular have anything whatsoever to do with consumers.
The Sherman antitrust act was enacted to prevent anticompetitive
behavior by large monopolies for the express purpose of keeping
smaller less efficient competitors from being driven out of business.

I've not seen anybody claim that US vs. AT&T was undertaken to protect
consumers.  The question was whether AT&Ts monopoly position in
providing local phone service made it an unfair competitor in the long
distance, manufacturing, and enhanced service businesses.  Consumers
were at best a tertiary concern in that courtroom.  From what John
describes, if the government's concerns were valid in 1984 then they
are valid now.  We have seen ample evidence that the RBOCs are capable
of abusing a captive relationship between supplier and customer to
either undercut competition or drive up the price to consumers of
monopoly services.  (The NYNEX case comes to mind, among others).

> "Predatory pricing," for example, is defined as selling
> a product *below the cost of production* for the purpose of eventually
> monopolizing a market. Mr. Higdon provides no evidence that Pac*Bell
> has priced its voicemail service below the cost of providing it; on
> the contrary, he himself shows that Pac*Bell's size and credit rating
> give it easier access to capital, which lowers its cost of providing
> the service. This is a natural advantage which large, established
> companies have over smaller ones; pricing one's goods to reflect one's
> lower cost structure is neither anticompetative nor "unfair."

It is not Pac*Bel's size and credit rating that gives it an advantage.
It is its unique position as the owner of the network that enables the
service.  Nobody else can forward your calls for free, because nobody
else is the phone company.  Nobody else can make your dial tone
stutter because nobody else owns the switch.

>    Mr. Higdon also writes that "[w]hen the field has been thinned out
> sufficiently, then the price can be whatever [Pac*Bell] wants." It
> should be clear that Pac*Bell cannot raise the price of voicemail in
> the future above what independent providers currently charge, without
> allowing the competition to reestablish itself.  Given this
> limitation, any such "predatory pricing" strategy would be decidedly
> unprofitable.

This is precisely the type of abuse that the antitrust laws were
written to deal with.  In real practice, rather than in Capitalist
Theory 101, once competition has been driven out through artificially
low prices, that the marketplace is much slower to respond to price
increases from the predator.  People can't jump back in the business
 -- they've gone bankrupt.

>    Likewise, his argument that Pac*Bell should be prevented from
> offering voicemail, because it alone is in a technical position to
> provide special services (such as "stutter" dialtone and free call
> forwarding), is similarly flawed. Consumers would not be better off by
> making these desirable features unavailable merely to protect
> inefficient competition.

*INEFFICIENT* competition?  It is not the fault of other providers
that they are not the local phone company.  That franchise was awarded
to Pac*Bel's predecessors long before there was voice mail.  This is a
classic case of what the antitrust lawyers and the FCC have called
cross-subsidy.  Pac*Bel's position as the provider of local phone
services, *AS A MONOPOLY PROVIDER UNDER GOVERNMENT REGULATION*, is
being abused to subsidize non-regulated business.  The governement has
handed Pac*Bel a juicy 12% guaranteed rate of return on service for
which it has no competition.  Let is go compete fairly in other
arenas.

> (Of course, if it is possible to extend these
> feature to competitors' services, Pac*Bell should be required to.)
> The key concept here should be service to consumers, and not
> "fairness" to competitors.

I see.  People get financing, take jobs, quit jobs, start businesses,
extend credit, use credit, all on the assumption that they are
entering a level market place.  The marketplace is not level when one
competitor can muscle in on the strength of a government sanctioned
monopoly.  Is that fair to the creditors, investors, and employees?
Are they not worthy of the same consideration as "consumers"?

Pac*Bel *could* find a way to tariff services in such a way as to make
for fair competition.  A) It *MUST* offer the same arrangements for
local forwarding and dial tone modification to all comers who are
willing to use appropriate voice mail technology B) Its voicemail
subsidiary *MUST* properly pay its phone company subsidiary a fair and
reasonable market rate for network based services that a competitor
would have to pay for.  Ultimately, nothing else would be fair to
either competitors or consumers.

I agree with John Higdon.  This is an ominous precursor of what we can
expect from the post-Hollings RBOCs.


Andy Sherman/AT&T Bell Laboratories/Murray Hill, NJ
AUDIBLE:  (908) 582-5928   
READABLE: andys@ulysses.att.com  or att!ulysses!andys
What? Me speak for AT&T?  You must be joking!

Joe Talbot <joe@mojave.ati.com> (06/10/91)

I think that RBOCs shouldn't be able to engage in ANY business other
than providing local telephone service. Despite what many "I didn't
have to understand it then, and I shouldn't have to now" people say,
things are much better since divestiture. There are services available
that the Bell System NEVER would have thought worth offering. They
were not a great deal when they came out, but the fact that they were
available may have caused more desirable services to appear.

If Pac*Bell's voicemail service puts all the other providers out of
business because it is selling the service below what non-telcos can
provide it for, there is somebody paying the difference, or Pac*Bell's
rates to the private voicemail providers are unjust.

If Pac*Bell's service is the only one around (for any reason) then the
only service improvements that will appear are the ones Pac*Bell feels
will make it more money in a large marketplace (mass appeal).

In article <telecom11.437.2@eecs.nwu.edu>, Bob_Frankston%Slate_
Corporation@mcimail.com (Bob Frankston) writes:

> In the spirit of naive optimism I'd like to see a law that allows
> telcos to offer these services but with the condition that the
> services be done with an arms length subsidiary and that any protocols
> used would be made generally available to third parties.

A good idea, but why should they be able to have an advantage at all?
Laws don't seem to work with technical issues and we've seen some
pretty creative examples of "creative accounting" for these subsidiary
companies (ask your friends in New York about Materiel enterprises).
Besides, these protocalls/services are supposed to be available to
service providers NOW!

This Hollings bill is very dangerous! We're headed for the Bell System
all over again. I don't want to go back to that again because a few
dummies don't want to make choices, but just "let the phone company do
it."

If Pac*Bell isn't satisfied with having the local service monopoly,
guaranteed to make a profit, then I suspect there might be a few who'd
take this thankless job off their hands so that they could make it big
in all the other businesses they wish to pursue.


joe@mojave.ati.com	
Slow mail: P.O. box 1750, Helendale California 92342 
Phone: (619) 243-5500     Fax (619) 952-1030 

Al L Varney <varney@ihlpf.att.com> (06/10/91)

In article <telecom11.437.2@eecs.nwu.edu> Bob_Frankston%Slate_
Corporation@mcimail.com (Bob Frankston) writes:

> The issue of protocols raises its ugly head.

An evil I'd love to stamp out, but I haven't thought of a better way.
An the most evil part is the letter "s" at the end of "protocols".
 
> Pac*Bell ... can create the protocols it needs to provide the services.  
> ....  Unfortunately, protocols generally means CCITT and a
> design cycle that guarantees irrelevance.

It would be interesting to compare the US staff-years spent on CCITT
and ANSI protocols in 1990 vs. 1980 (pre-divestiture).  And the cycle
is soooo slooooow.  Even Bellcore's drags on.
 
> In the spirit of naive optimism I'd like to see a law that allows
> telcos to offer these services but with the condition that the
> services be done with an arms length subsidiary and that any protocols
> used would be made generally available to third parties.

Most services are tested during the protocol discussion stage.  I'm
not aware of any TELCo yet stating they would NOT make protocols
available to the public (but not free), and ONA probably forces this
to occur.  This does not mean a private vendor can't develop something
without public input and offer it to one or more Telcos as a product.
The standardization lag would give the original vendor a large market
window, however.  This doesn't happen often because TELCos don't like
to be stuck with a hot-shot product with only a single source (unless
they start manufacturing themselves, of course).  There is always the
threat that the Standard will be deliberately different from the
original product ...
 
> Understanding the difficulty of designing good protocols, there would
> be a grace period in which they can experiment with protocols without
> invoking the full standards wrath but that they would have to have a
> process for advancing the protocols beyond their initial design.
> Perhaps they would also be allowed a not-for-profit grace period in
> which they can experimentally try out the services.

Happens all the time today.  I am not aware of any law/rule that
prevents the TELCo from having "market trials", "technical trials",
etc.  Many RBOCs also have "test labs" for trialing new technologies
in a "non-penalty" environment.  The "Intelligent Network" view, where
TELCos do their own feature programming would allow them some lead
time over other vendors and/or RBOCs.
 
> I do appreciate the difficulty of creating good protocols and I don't
> want to inhibit the process but with transition from POTS to ISDN and
> other digital interfaces, we need to realize that the ability to offer
> these services, even in arms-length subsidiaries with no revenue
> sharing, is based on a policy of proprietary protocols.

> Making these protocols available external raises many network
> integrity and performance issues, but these issues must be faced

What protocols are not external, if you have the cash for the CCITT,
ANSI T1 and Bellcore requirements?  I know there is some black holes
around Autovon, 911 and Call Trace mechanisms, but ISDN is well
documented.  Of course, you have to decide which version(s) to 
support ....

The "stutter dial tone" issue, even in its old form, is simply one of
providing access lines from the Message Center to the switch(s) of
it's subscriber(s).  If PacBell is using a different implementation,
the only one that's available on AT&T switches is also Publicly
documented.  Again, there are 3 versions, but its standard :-) (See
below).
 
> [Moderator's Note: One of the nicest features of telco-operated voice
> mail is the stutter dialtone which advises the subscriber of new
> messages waiting. It should not be that hard for telco to provide this
> to the competitors: A third-party voice mail system would send
> messages to the serving CO (of the subscriber) saying 'turn on
> stutter' or 'turn off stutter'. They'd send this message on a special
> data circuit, and your CO would toggle it on or off, just as it does
> now for telco's own voicemail service.

Patrick, You ain't gonna believe your suggestion has been turned into
code already!!  Bellcore's TR-866 provides the interface spec. for
ISDN-connected Voice Messaging Services, allowing them to turn stutter
tone on or off, or light a lamp/indicator on your ISDN terminal.  ANSI
T1S1 has requirements mostly ready for approval that provide the
National specs. for both the ISDN- and non-ISDN- Voice Messaging
Services.  This includes the method for switches to notify other
switches (via SS7) to activate/deactivate the appropriate indicator.
With ISDN, you can actually have multiple indicators, one per Message
System.  So in theory, the protocol IS available to the public (and
the switch vendors).  In SS7 areas, the Voice Messaging provider will
only need connectivity to one switch (unless you want backup lines).

The real problem here is the usual one with protocols.  No, not the
snails pace of design or the lack of detail.  It's too many cooks.
TR-866 specifies an inter-switch protocol that will not work with ANSI
(even though Bellcore wrote the ANSI version??), and the two ANSI
specs disagree on whether or not one parameter is required.

> Also, telco *could* now
> provide 'programmable forward on busy / no answer' if they wanted to.

This isn't available on all Ameritech switches (especially those nice
1A ESS(tm) switches).  Ameritech Mobile's oldest switch is probably
two years old; they ditched all the original switches.

Try to talk the regulators into allowing the wholesale replacement of
all those old(er) switches!!!

> Ameritech Mobile presently allows me to toggle 'forward on busy / no
> answer' as I wish; AND program it to any number, anywhere, but
> Illinois Bell (my hardwired service) insists that this feature can
> only be programmed in the CO on a work order (that of course means a
> fee), and that it cannot be turned off or on (except by CO action),
> and that forwarding MUST be to another number in the same exchange!

Actually, intra-office is no longer a restriction, if IBT wants to buy
the feature ... But the Busy/DA forwarding is CO only unless you want
to pay for a "Centrex Station Rearrangement" capability; your own
Recent Change terminal (but only for lines in YOUR Centrex).

So PAT, how about helping me out with something?  I need the exact
quote and author for something like:

   "That's the wonderful thing about Standards; there're so many
    to choose from!"

Thanks,


Al Varney, AT&T Network Systems
Disclaimer: These are my opinions, and hardly proprietary.


[Moderator's Note: I've heard this quotation before, but don't know
who authored it. Maybe other readers can tell us.   PAT]

Jon Sreekanth <jon_sree@world.std.com> (06/10/91)

In article <telecom11.431.1@eecs.nwu.edu> john@zygot.ati.com (John
Higdon) writes:

> The "Message Center" is a voicemail service that directly competes
> with voicemail service bureaus. It will answer your phone after a
> preset number of rings, allow you to retrieve your messages from
> anywhere, and will put "stutter" dial tone on your phone if there are
> messages waiting.

> What is wrong with this? First, it is priced well below most service
> bureaus. Using the vast capital resources available courtesy of its
 ..

There's already competition from other telecom giants: the LD
companies. AT&T and probably the others are selling voice mail
services. So the monopoly scenario above might not happen.

It might require the resources of a large company to sell the idea.
New England Telephone is still taking out expensive TV and radio ads
for call waiting, some 4 - 5 years after introducing the service,
meaning there's still a large inertia to using special phone services.
About a year ago, I saw an ad in a small Boston area newspaper for a
voicemail service targeted to students and mobile young professionals.
They sank without a trace.

IMHO, the voicemail services are really competing with answering
machines, not small service bureaus. The latter have the option of
sticking to the traditional answering service, using human operators,
hence distinguishing themselves from voice mail.


Jon Sreekanth

Assabet Valley Microsystems			Fax and PC products
346 Lincoln St #722, Marlboro, MA 01752		508-562-0722
jon_sree@world.std.com

"Jerry M. Carlin" <jmcarli@ns.pacbell.com> (06/11/91)

In article <telecom11.442.2@eecs.nwu.edu> joe@mojave.ati.com (Joe
Talbot) writes:

> If Pac*Bell isn't satisfied with having the local service monopoly,
> guaranteed to make a profit, then I suspect there might be a few who'd
> take this thankless job off their hands so that they could make it big
> in all the other businesses they wish to pursue.

What local service monopoly? We're already seeing large companies
working with fiber companies to bypass the local loop and go directly
to the long-distance carriers and to their other offices. The cable
companies would like to do the same for residence customers. In a few
years, we'll see competition in all areas of the business with the
RBOC's forced to keep prices higher than the rest until the share of
their business is down quite a bit judging by the precident of AT&T.


Jerry M. Carlin	(415) 823-2441 jmcarli@srv.pacbell.com

Robert Jacobson <cyberoid@milton.u.washington.edu> (06/11/91)

I'm not a guy who naturally sides with the RBOCs, having dueled with
Pac*Bell for years on the issue of introducing new services in a fair
way.  But also having experienced the reluctance of the competitive
market to develop and introduce new telecommunications services that
make a difference to most of us, I'm inclined to say, give 'em a
chance.  Reinstating the antitrust provisions, if the RBOCs abuse
their position, is a lot less difficult than prevailing on the
competitors to produce services with value for the little guy.

This is NOT an argument for deregulation of the RBOCs.  It is merely a
call for the RBOCs to be able to put their considerable resources at
the disposal of the market and possibly add to the limited supply of
technology now available to us "little guys."


Bob Jacobson

(These opinions are mine alone and not necessariy those of my employer
or colleagues.)