Received: from eff.org by kragar.eff.org with SMTP id AA19129 (5.65c/IDA-1.4.4 for ); Mon, 13 Apr 1992 11:39:34 -0400 Received: by eff.org id AA18534 (5.65c/IDA-1.4.4 for pub-infra-exploder); Mon, 13 Apr 1992 11:18:20 -0400 Date: Mon, 13 Apr 1992 11:18:17 -0400 Message-Id: <199204131518.AA18528@eff.org> From: Subject: Frankston on ISDN To: pub-infra@eff.org (pub-infra mailing list) Prescript: I've been putting these comments together for a while, but at some point, I've got to ship the product even if it is not perfect nor complete. With that caveat in mind, I'm submitting this commentary on ISDN and the rest of the universe. I've just read through D.P.U. 91-63-B of the Commonwealth of Massachusetts Department of Public utilities which is the response to the ISDN filings. I've already Prodigy's briefs on the subject. Though the language was a bit long winded, it was, to my surprise, fascinating. I don't know how these compare to what the situation is in other states, but there is some spirited opposition to NET's attempt to sell ISDN services at a high rate. The Prodigy filing also incorporated some of Mitch Kapor's research. I should also strongly emphasize that I am not a lawyer, I'm not well versed in regulatory law. I'm more a dabbler/kibbitzer in these matters, then an expert. Given all that, I'll attempt to give a biased summary of the filings and my reactions. More my reactions than summary. The basic position of NET is that ISDN is an optional offering that should be priced at competitive rates. Where competitive means "what the market will bear". Prodigy's position is that ISDN should be a basic part of the communications infrastructure and should be priced at a rate that would encourage its use, or at least, not discriminate against its use. NET referred to Prodigy's view as a "field of dreams" wherein Prodigy expects that if ISDN were available, people would flock to it. NET claimed its studies showed that there are people who would pay high rates for ISDN and thus it should be priced for the known customers. I call this "railroad pricing" referring to the days when the railroads were in decline and kept increasing their rates to get the same return from fewer passengers and thus reduced the number of passengers etc. Even worse, for communications offering, providing only one hand so that people can experiment with clapping has its limits. There is much discussion on what the actual costs of ISDN deployment are. This gets complicated because the costs of ISDN components vary due to accounting considerations as well as purchase price variations due to one time offers, quantity discounts and startup costs. The distinction between hardware, software and other components is not clear, so I resort to the technical term "stuff". The fact that these are not broken out makes it hard to evaluate some of the claims. The DPU seems to be caught in the middle. It seems to buy into the infrastructure argument but is very conservative on limiting NETs rates since NET must be allowed to recover its costs. Now a word from our sponsor -- me. I had a number of disparate (knowing how bad spelling is on the net, I should point out that that is not a typo for desperate) reactions to reading these filings. One question is whether ISDN is the right service for data. Some of the DPU discussion was on the relationship of ISDN as a data transport with switched 56KB (an example of high priced service). But there was no discussion on how to provide a connectivity other than point to point bulk data transfer. I realize the advantage of concentrating on ISDN issues is that there is at least some agreement on what ISDN is -- a necessary prerequisite for rational debate. Given the grief that NET is giving over ISDN deployment, asking for really different services seems to be an uphill battle. Which brings us to NET as a consumer buying merchandise off the shelf. It seems that once they've bought into an exchange (often the DMS-100) they are captives of their maintenance plan with the exchange. I can't imagine them buying anything nontrivial from anyone but Northern-Telecom for its DMS-100 COs. It doesn't seem they have much negotiating leverage. It would be nice to see the CO become a more distributed entity that allowed more mixing and matching from different vendors. For now, at least, it is not clear how to build such a system. This further concentrates debate on off-the-shelf ISDN because alternatives are problematic. NET whines about the difficulty of providing ISDN, yet they seem to have no problems if you want Intellipath and Centrex, both of which are ISDN-based services. This seems to be far from a level playing field. I'd like to see a situation in which NET couldn't base any of its services on ISDN unless others gain the same access. Of course, the fact that the ISDN services seem to run in the same switch as ISDN itself means that they can provide the services without the complexities of providing ISDN to third parties. This goes back to the issue of the monolithic CO. Perhaps ISDN can be a mechanism for brining CO capabilities outside the physical (or even logical) machine so that the protocols necessary for these services are provided at arms length and thus provide a mechanism for a marketplace. This issue of ISDN as a set of protocols for implementing a marketplace is an interesting one but not fully fleshed out in the current ISDN protocols. It should receive explicit attention in its own right. Given all this, it still galls me to see NET refer to capabilities by their service product names rather than the generic features. It also recalls the problems that "good' COCOTS have in trying to compete with NET in the pay phone business since NET gives itself a great deal on the costs of phone calls (of course, the fact that Massachusetts still mandates $.10 for NET pay phones is probably also a factor -- something that bespeaks a strong DPU which might make the state a good place for ISDN advocacy). The cellular phone network offers an interesting case study. In following the discussions of features of the cellular phone network, it feels like amateur night wherein features are cobbled together by kludging together disparate systems. A lot of the feature set depends on whether one happens to have an Ericsson or Motorola switch and what sort of jumpers have been placed between them. I get the impression that many features are implemented by placing a PC (personal computer) offnet and having it send back DTMF codes. I see this a symptom of the complexity of making any changes in the network. At least, in the network as currently architected The ISDN and cellular problems illustrate the problem of what happens when one buys a complete service from a monopoly. Unlike the PC world of mix and match, you get all or nothing. A long term agenda should be to go beyond simply breaking of ATT to architecting a communications infrastructure that consists of components. This is very very difficult, especially when coupled with requirements for reliable and predictable service. It is less clear that the current approach is more amenable to graceful evolution. A more modest approach is to encourage competition on the local loop. Perhaps the RBOCs should be divested of their control of the right of way and instead, all parties would have equal access to the communications right of way at a physical level. Access at a logical or signal level is more complicated. We'll see some of this in action now that Cable companies are becoming more of a force for loop competition. Cable company monopolies are anther topic I won't get into here. Back to my Ox. The current network is designed for voice communications with services like switched 56KB being viewed as expensive premium services. But the reality is just the opposite. Voice is very demanding of the network whereas data communications is very forgiving of delays and can recover from errors (OK, voice can tolerate many errors that give data fits). So why is voice cheap and data expensive? There are some answers in the current network architecture but these are not intrinsic. The other aspect is the circuit switched model for data communications. Admittedly it is possible to get an X.25 connection that does provide a switched service but I'm not confident that it is sufficiently standard for me to assume I can make a very cheap quick connection to a service and be charged accordingly. If I want to get one stock price, how much overhead is involved? If I want to keep simultaneous connections to multiple services is there a holding charge? I realize that there is a contradiction between my asking for a raw service from telco and the ability to then buy enhanced services from other parties. But is the raw service copper to the CO and a voice path or is it a datapath. If a third party provides the packet service, do all messages have to travel through the network and then get redispatched? Are there sufficient standards for things to "just work"? This brings us to the concept of intra CO tariffs These do exist for Centrex and might exist for early ISDN capabilities which can be supported within a switch but which must await protocol upgrades (SS7?) in order to communicate with other exchanges. I can image that a call within the exchange being essentially free but having a significant charge to call the next town. Or should social policy minimize this? We already have the example of cable TV systems where I simply cannot get broadcasts from the next town -- a very bad precedent but something we accept as if it were natural rather than a kludge while we await BISDN (where BISDN is a code word for switched video but not limited to ISDN protocols). Postscript. I've seen mention that NET has adopted ISDN pricing that is akin to standard message unit service but haven't seen the details. I've also received a brochure from Nynex touting Basic Exchange Service which seems to be their ISDN Centrex replacement that lists a menu of features that you can select 3 of plus optional features. Of course, it is these services that are being offered, not "raw" ISDN. [Pricing in Mass. is 2.6 cents per minute for the first minute for residential service, 1.6 cents per minute thereafter. For businessis, the rates are 9.6 cents for the initial minute and 1.6 cents thereafter. This covers service to the CO. Inter-office tariffs will be filed by the end of the year. - Mitch Kapor]