Before the
Federal Communications Commission
Washington, DC 20554
| In the Matter of |
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| |
) |
| Application by Verizon New England |
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| Inc., Bell Atlantic Communications, |
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| Inc. (d/b/a Verizon Long Distance), |
) CC Docket No. 00-176 |
| NYNEX Long Distance Company |
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| (d/b/a Verizon Global Networks Inc., for |
) |
| Authorization To Provide In-Region, |
) |
| InterLATA Services in Massachusetts |
) |
COMMENTS OF THE ALLIANCE FOR PUBLIC TECHNOLOGY SUPPORTING VERIZON NEW ENGLAND INC'S REQUEST FOR AUTHORITY TO PROVIDE LONG DISTANCE SERVICE IN MASSACHUSETTS
The Alliance for Public Technology has consistently urged the Federal Communications Commission (FCC) to pursue the goal of Section 706 of the Telecommunications Act of 19961 in every relevant proceeding by encouraging the reasonable and timely deployment of advanced telecommunications capability to all Americans.2 Section 706 authorizes the FCC and state telecommunications commissions to use "measures that promote competition in the local telecommunications market or other regulating methods to remove barriers to infrastructure investment," among other means, to achieve the goal of ubiquitous broadband deployment mandated by the Act.
The Alliance for Public Technology (APT) is a nonprofit organization of more than 300 public interest groups and individuals. APT's members work together to foster broad access to affordable, usable information and communications services and technology for the purpose of bringing better and more affordable health care to all citizens, expanding educational opportunities for lifelong learning, enabling people with disabilities to function in ways they otherwise could not, creating opportunities for jobs and economic advancement, making government more responsive to all citizens and simplifying access to communications technology. To this end, it is APT's goal to:
make available as far as possible, to all people of the United States, regardless of race, color, national origin, income, residence in rural or urban area, or disability high capacity two-way communications networks capable of enabling users to originate and receive affordable and accessible high quality voice, data, graphics, video and other types of telecommunications services.3
The Alliance is not in a position to judge the compliance of any one company with respect to the 14 point checklist of requirements under section 271. We do note, however, that the Massachusetts DTE has subjected Verizon to performance assurance plans in Massachusetts that mirror those in New York where Verizon is successfully offering interLATA services.4 These plans place more than $142 million in bill credits at risk annually in Massachusetts for failure to meet performance standards. This is assurance that Verizon will not backslide but continue to provide a high standard of service to competitors.
In APT's view, Section 271's interLATA prohibitions constrain the widespread deployment of advanced telecommunications infrastructure and therefore undermine Section 706, which seeks to promote investment in ubiquitous high-speed networks. APT maintains the belief that expeditious approval under Section 271 serves the public interest. The Alliance further contends that such prompt action eliminates a significant barrier to investment in high-speed telecommunications networks that should reach all communities.5 As we stated in supporting Verizon's (then Bell Atlantic) Section 271 application for New York, "[s]uch action would advance the goals of Section 706, and reaffirm the Commission's commitment to eliminating regulatory barriers to investment in high-capacity networks."6
The Commission has the opportunity to bolster Section 706's impact by authorizing Verizon to provide long distance telephone service in Massachusetts. APT strongly urges the Commission to seize this opportunity to increase facilities-based competition for local and long distance service, and promote ubiquitous broadband network deployment so that all Massachusetts residents, regardless of their income level, rural residence, or physical disabilities, may improve the quality of their lives through access to new sophisticated telecommunications.
APT has every reason to believe that Massachusetts consumers, particularly low volume users, will reap the same swift gains from lower prices and bundled services that New Yorkers are experiencing with Verizon's entry into that long distance market. According to a Telecommunications Research and Action Center (TRAC) study, six months after Verizon's entry, there was a Verizon long distance calling plan that was less expensive than any AT&T, WorldCom, or Sprint national plan for all long distance customers with typical calling patterns, except those who make a very large number of calls per month.7 Furthermore, in anticipation of and in response to Verizon's entry into the long distance market in New York, the incumbent long distance carriers introduced special, lower-priced bundled services offerings to customers.8
As Verizon deploys its broadband networks, APT implores the Commission to do all that it can to remove the interLATA barriers that inhibit the widest possible extension of these networks to help all Massachusetts residents enjoy the benefits of advanced telecommunications capability. Therefore, APT respectfully recommends that the Commission authorize Verizon to provide long distance service in Massachusetts.
Respectfully requested,
Pace A. Duckenfield
Counsel
Alliance For Public Technology
919 18th Street, NW, Suite 900
Washington, D.C.
October 16, 2000
1 47 USC 157 note.
2 See, e.g., Petition of the Alliance for Public Technology Requesting Issuance of Notice of Inquiry and Notice of Proposed Rulemaking to Implement section 706 of the 1996 Telecommunications Act, CC Docket No. 9244 (Feb. 18, 1998) (APT Petition) at 12-13.
3 Alliance For Public Technology, Principles to Implement the Goal of Advanced Service at 3 (1995).
4 DTE, Order Adopting Performance Assurance Plan, No. 99-271 (Sept. 5, 2000) (App. B, Tab 559) ("DTE Performance Plan Order").
5 See, e.g., Id.; and Comments of the Alliance for Public Technology, In the Matter of Petition of Bell Atlantic for Relief from Barriers to Deployment of Advanced Telecommunications Services, CC Docket No. 98-11, Petition of US WEST for Relief from Barriers to Deployment of Advanced Telecommunications Services, CC Docket No. 98-26; and Petition of Ameritech for Relief from Barriers to Investment in Advanced Telecommunications Capability, CC Docket No. 98-32 (April 6, 1998) at 2.
6 Comments of the Alliance for Public Technology Supporting Bell Atlantic's Request for Authority to Provide Long Distance Service in New York, In the Matter of Application by New York Telephone Company (d/b/a Bell Atlantic-New York) Bell Atlantic Communications, Inc., NYNEX Long Distance Company and Bell Atlantic Global Networks, Inc., for Authorization to Provide In-Region , InterLATA Services in New York, CC Docket No. 99-295 (Oct. 19, 1999) )(APT NY Comments) at 2.
7 See Telecommunications Research & Action Center, A Study of Telephone Competition in New York, Sept. 6, 2000.
8 Id.
