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Image vs. Reality (Essays in Frustration)

Cost Based Pricing
vs. Universal Service

September 1, 1987

The Editor
The New York Times

Your editorial, “More Phones, More Fairness,” (8/30/87) is an interesting study in non sequiturs. While praising cost-based pricing, you come out for “lifeline service” for poor people, with installation and monthly charges obviously far below their costs. You then justify this stand by stating as a fact something that a hundred years of telephone innovation disproves: that much of the gain from rapidly improving communications technology will be lost without cost based pricing.

In castigating “cross subsidies” from long distance to local calling, urban to rural service, etc., you deny the whole basis of “Universal Service” which lifeline telephones exemplify, and which produced the best, most innovative and lowest cost telephone service in the world.

Although sophisticated regulators may be no harder to find than a cure for AIDS, your suggestion that they exist at the FCC is absurd. The FCC has purposely delayed the implementation of cost based pricing of long distance service (and the related monthly increase in the cost of local service paid by the customer) for two reasons: it wants to maintain a profit window as long as possible for the synthetic long distance competition it created, while minimizing the uproar from all of us who would suddenly have to pick up the total cross-subsidy in one giant step. If you have looked at your home phone bill lately, you MUST know that this INCREASE is vastly greater than the lifeline rates which you praise.

As a final kicker, the FCC, as reported in the Times, is about to abandon cost-based pricing for AT&T by simply setting a ceiling on what can be charged for long distance service, permitting AT&T to make all the money it can, independent of costs, by exercising its skill in technical innovation. AT&T’s competitors are very happy with this. Their hope seems to be that, if AT&T no longer has to worry about cost-based pricing, it will use some of its profits from long distance to subsidize its ailing computer business instead of cutting LD rates to the minimum that cost based pricing would have required. Such an action would, of course, be a direct subsidy to long distance competition instead of the local phone companies, and thus would preserve the American Dream.

Lifeline rates are a great idea, as was Universal Service. Both are under attack by lawyers, economists and other technological illiterates who use their appointive positions to enforce their personal ideologies. I would hope that the Times would give reality, to say nothing of logical consistency, some editorial consideration instead of praising the wrong people for the wrong actions. Cost-based pricing, if actually applied across the board, would eliminate lifeline service and be the end of what is left of Universal Service for rich and poor alike.

Very truly yours...

The experiences of half a lifetime as a telephone engineer don’t impress lawyers, economists, or newspaper editors. They are quite satisfied to live in fantasyland.

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