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L(67t&S TECHNICAL NOTE 1104

Volume 1
NATIONAL BUREAU OF STANDARDS

The National Bureau of Standards' was established by an act of Congress on March 3, 1901. The Bureau's overall goal is to strengthen and advance the Nation's science and technology

and facilitate their effective application for public benefit. To this end, the Bureau conducts

research and provides: (1) a basis for the Nation's physical measurement system, (2) scientific and technological services for industry and government, (3) a technical basis for equity in trade, and (4) technical services to promote public safety. The Bureau's technical work is per- formed by the National Measurement Laboratory, the National Engineering Laboratory, and

the Institute for Computer Sciences and Technology.

THE NATIONAL MEASUREMENT LABORATORY provides the national system of

physical and chemical and materials measurement; coordinates the system with measurement

systems of other nations and furnishes essential services leading to accurate and uniform

physical and chemical measurement throughout the Nation's scientific community, industry,

and commerce; conducts materials research leading to improved methods of measurement,

standards, and data on the properties of materials needed by industry, commerce, educational

institutions, and Government; provides advisory and research services to other Government

agencies; develops, produces, and distributes Standard Reference Materials; and provides

calibration services. The Laboratory consists of the following centers:

Absolute Physical Quantities2 — Radiation Research — Thermodynamics and

Molecular Science — Analytical Chemistry — Materials Science. THE NATIONAL ENGINEERING LABORATORY provides technology and technical ser- vices to the public and private sectors to address national needs and to solve national problems; conducts research in engineering and applied science in support of these efforts; builds and maintains competence in the necessary disciplines required to carry out this research and technical service; develops engineering data and measurement capabilities;

provides engineering measurement traceability services; develops test methods and proposes

engineering standards and code changes; develops and proposes new engineering practices;

and develops and improves mechanisms to transfer results of its research to the ultimate user. The Laboratory consists of the following centers:

Applied Mathematics — Electronics and Electrical Engineering2 — Mechanical

Engineering and Process Technology2 — Building Technology — Fire Research —

Consumer Product Technology — Field Methods.

THE INSTITUTE FOR COMPUTER SCIENCES AND TECHNOLOGY conducts

research and provides scientific and technical services to aid Federal agencies in the selection,

acquisition, application, and use of computer technology to improve effectiveness and

economy in Government operations in accordance with Public Law 89-306 (40 U.S.C. 759), relevant Executive Orders, and other directives; carries out this mission by managing the Federal Information Processing Standards Program, developing Federal ADP standards

guidelines, and managing Federal participation in ADP voluntary standardization activities; provides scientific and technological advisory services and assistance to Federal agencies; and

provides the technical foundation for computer-related policies of the Federal Government.

The Institute consists of the following centers:

Programming Science and Technology — Computer Systems Engineering.

'Headquarters and Laboratories at Gaithersburg, MD, unless otherwise noted; mailing address Washington, DC 20234.

2 Some divisions within the center are located at Boulder, CO 80303.
NOV 3 1979

<N9t> ft t Cjl-ccl

The FCC Public Message

Services Policy Change:

An ETIP Evaluability

Assessment Report — Volume 1

James Bell 1 Sharon Kirby 1 Roland G. Weiss2 Steve Watson 1

'The Urban Institute 2100 M Street, NW

Washington, DC 20037

2Center for Field Methods

Experimental Technology Incentives Program

National Bureau of Standards

Washington, DC 20234

^ y^dLl ^0U

U.S. DEPARTMENT OF COMMERCE, Juanita M. Kreps, Secretary

Luther H. Hodges, Jr., Under Secretary

Jordan J. Baruch, Assistant Secretary for Science and Technology

.\y-> NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director

Issued September 1979
National Bureau of Standards Technical Note 1104/

1

Nat. Bur. Stand. (U.S.), Tech. Note 1104/1, 232 pages (Sept. 1979) CODEN: NBTNAE

U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON: 1979

For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402

Stock No. 003-003-02117-2 Price $11. Sold in sets only. (Add 25 percent additional for other than U.S. mailing)
Ill

ABSTRACT

This document is a report of work in progress toward evaluating effects

of the recent decision of the Federal Communications Commission to open

public message services to competition. It is one product of the Regulatory

Processes and Effects Project of the Center for Field Methods (ETIP) . The

broader project, described elsewhere, is attempting to analyze the effects

of changes in regulatory processes on industrial innovation. The joint

ETIP/FCC project will involve measuring whether the FCC policy change leads

to increases in competition, technological innovation, and public benefit.

The first two chapters provide an introduction and snyopsis. Chapter III

examines the setting in which the decision occurs in terms of historical developments, industry trends, and views held by various observers. Chapter IV

describes the: Commission's mandate for regulation, process for implementing

this mandate in terms of regulations and operations, and current industry

status. The fifth chapter describes the evaluation logic. The last chapter

is an assessment which shows that there are many choices to be made to target

the evaluation. A glossary of terms and bibliography are included. Seven

appendices are bound separately.

Key words: Administrative experimentation; economic deregulation;

evaluability assessment; evaluation; Experimental Technology Incentives Program;

Federal Communications Commission; regulatory experimentation; regulatory

policy; technological innovation; telecommunications.

ACKNOWLEDGEMENTS

This report could not have been completed without the assistance and

cooperation of many people. First and foremost we would like to thank the

Federal Communications Commission staff who provided invaluable information

both about Commission operations and about issues that are currently being

debated within the telecommunications industry. In particular, we wish

to acknowledge:

• David Irwin, Chief of Policy and Rules;

• James Smith, Policy and Rules;

• Charles Oliver of Program Evaluation;

• Frank Patella, Judy Nitsche, Ken Levy, and Daniel Harrold of

Tariff Review and Tariff Proceedings;

• Jim Ferris, Complaints and Service Standards; and

• Robert James (Domestic Division) and Helene Bauman (International

Division) of the Facilities Branch.

We would especially like to thank Leonard Sawicki, Program Evaluation Branch,

who provided assistance throughout the effort Including reviews and comments on the preliminary drafts of this report.

Staff of both The Urban Institute and The Experimental Technology

Incentives Program of the Department of Commerce participated on committees

reviewing this report and offered advice during the course of research.

We would like to thank Victor Berlin, Bud Libman, and Dan Fulmer of ETIP

and Robert Sadacca, John Waller, Joe Nay, Lucile Graham, Michael Mulkey,

Bill Foskett, Paul Nalley, John Heinberg, and Richard Schmidt of The Urban

Institute.

Our initial contact with the industry produced a gratifying response.

We would like to thank the common carriers which expressed interest in our experimental evaluation of the effects of changes in interstate telecommunications regulation. In some cases, carriers submitted information

about their operations.

The telecommunications industry is indeed fast moving and complex.

We found that the publication Telecommunications Reports provided valuable

information about developments in the industry. Mr. Fred Henck, publisher

of Reports , very kindly gave us permission to quote his journal.
VI

We also appreciate the fine job done by Erica Sweeney who edited this

report. Finally, we would like to thank the many people who helped to

prepare the report. Staff who assisted us include: Kraig Jones, (Ms.) Mike

Malone, Mary Sarley, John Fortunato-Schwandt, Ilona Bush, and Barbara Shunney.

We are especially grateful to Copper Wilson who, in spite of coming

to the project during the final report writing, took responsibility for

primary secretarial support, worked long hours to meet deadlines, and

also made valuable contributions to the content of the report.

James Bell

Sharon Kirby

Roland Weiss

Steven Watson
Vll

PREFACE

Regulatory agencies and regulatory reform are subjects of great interest

today, and the effects of regulation on technological innovation and productivity in American industry are of special concern. Many reforms and changes

in the regulatory process are being proposed, and some are being made. Each

change represents an "experiment" in the operation of our society, even if no one carefully determines the result of that "experiment."

Since 1974, the Experimental Technology Incentives Program (ETIP)

located in the Center for Field Methods of the National Bureau of Standards

has pursued an understanding of the relationships between government policies

and technology-based economic growth. This goal is based on three premises:

o Technological change is a significant contributor to social and

economic development in the United States

.

o Federal, State, and local government policies can influence the

rate and direction of technological change.

o Current understanding of this influence and its impact on social

and economic factors is incomplete.

ETIP seeks to improve public policy and the policy research process in order

to facilitate technological change in the private sector. The program does

not pursue technological change per se . Rather, its mission is to examine

and experiment with government policies and practices in order to identify

and assist in the removal of government-related barriers and to correct

inherent market imperfections that impede the innovation process.

ETIP assists other government agencies in the design and conduct of joint

projects. Key agency decision makers are intimately involved in these

experiments to ensure that the results are incorporated in the policymaking process. ETIP provides its agency partners with both analytical

assistance and funding for the experiments while it oversees the

evaluation function.

In 1977, The Urban Institute's Program Evaluation Group was awarded a significant contract ($856,000 over 15 months) as a result of competitive

bidding on a U.S. Department of Commerce Request For Proposal. Under this

contract the Program Evaluation Group provided analytic support and data

collection services to ETIP. This work was the foundation for the Regulatory

Processes and Effects Project (RPE). The Regulatory Processes and Effects

Project, through this analytic support work, will analyze the process and
Vlll

attempt to document the results of ETIP's regulatory projects, which investigate whether private sector innovation is generated by changes in regulatory

agencies. In December 1978, the Regulatory Processes and Effects Project

moved from The Urban Institute to the Performance Development Institute (PDI) as the result of a competitive award process.

Regulatory Processes and Effects Project teams are conducting short,

exploratory efforts, significant explorations of expectations and reality,

and assessments of fully developed regulatory process changes under various

regulatory situations. * The following regulatory agencies are (or have

been) involved:

Environmental Protection Agency (Air, Pesticides, and Water),

Federal Communications Commision,

Food and Drug Administration,

Federal Energy Regulatory Commission,

Federal Trade Commision,

Interstate Commerce Commission,

Nuclear Regulatory Commission,

Occupational Safety and Health Administration, and

State Public Utility Commissions (Electric Power).

The Regulatory Processes and Effects Project not only helps to develop

actual regulatory administrative experiments, but also helps formulate a generalizable body of methods for implementing and assessing the effects

of regulatory changes on commerce, industry, and technological innovation.

1. ETIP prefers to use the strategy of "administrative experimentation"

when applicable. An administrative experimentation stragegy (1) helps to

bring about a change in the performance or operation of an agency, and

(2) Improves the understanding of the relationship between the change introduced and the results observed. Thus, an administrative experiment is conducted more in the sense of carefully evaluated change, and not in the social

sciences sense of change controlled by the researcher, according to certain

prescribed rules, solely for research purposes. A "quasi-experimental" re- search design may be the best that one can do. See , for example, Campbell,

Donald T. , "Administrative Experimentation, Institutional Records and Nonreactive Measures," Improving Experimental Design and Statistical Analysis , Stanley, J.C., ed., Chicago: Rand McNalley, 1967. Thompson, Charles W. N.

,

and Rath, Gustave J. "The Administrative Experiment: A Special Case of

Field Testing Or Evaluation," Human Factors , Vol. 16, No. 3, June 1974,

pp. 238-252. Thompson, Charles W. N. "Administrative Experiments; The

Experience of Fifty-Eight Engineers and Engineering Managers," IEEE

Transaction on Engineering Management , Vol. EM-21, No. 2, May 1974,

pp. 42-50.
IX

In each situation, team members from ETIP, the ETIP contractor (PDI),

and the regulatory agency jointly analyze an initiative in regulation, or

its implementation as an experiment, and/or perform an assessment of its

effects. Other interested parties are also involved, and the work is

conducted under the management and review structure of the Regulatory

Processes and Effects Project. Consequently, knowledge gained from

similar projects can be shared.

This document concerns the development of an effort with the Federal

Communications Commission (FCC). In fall 1976, ETIP regulatory staff

began to investigate the possibility of developing a joint project with

the FCC. With the assistance of a small contract (Transcom, Inc.), it

conducted preliminary background research on the Commission and developed

three ideas in the area of international telecommunications.

Preliminary discussions continued between ETIP and FCC for several

months. During this time, the discussions revealed the need for a con- siderable amount of definitional and economic research on the telecommunications industry. The Common Carrier Bureau (CCB) Program Evaluation staff

proposed alternatives that included public message telegraph services

deregulation, 2» 3 ancj a Commission attorney began to investigate the legal

issues involved.

In June 1977, ETIP and FCC staff agreed that there was sufficient mutual

interest in the development of a joint project to justify requesting formal

Commission approval for continued work. The Commission granted formal

approval in July 1977. ETIP and Commission staff then developed a joint

project plan and interagency agreement. The plan, used by ETIP to obtain

National Bureau of Standards' approval, describes:

a project to be carried out with the Federal Communications

Commission (FCC) to identify, design, implement, and assess

1. The initial proposals were entitled: "Eliminating Time Delay

in the Section 214 International Facilities Construction Authorization

Process"; "Elimination of The Requirement That International Record Carrier

Rates Be "Cost Justified' with Section 61.38 Support Data (Rate Deregulation For Existing Carriers)"; and "Expanded Communications Carrier Ownership of Satellite Earth Stations for International Telecommunications."

Transcom, Inc. International Telecommunications Experimental Ideas For

The Experimental Technology Incentives Program , December 7, 1976, 34

pages.

2. Sawicki, Leonard S. Program Evaluation, Common Carrier Bureau of

the Federal Communications Commission, Draft of Internal Working Memorandum

(undated)

.

3. The term deregulation is used here to denote a change in policy,

practice, and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
X

one or more administrative experiments ... intended to

obtain knowledge of the agency and commercial impacts of

changes in the FCC regulatory process.

1

ETIP and Commission staff agreed that the public message telegraph

services deregulation, if implemented, might be a change to investigate.

Common Carrier Bureau staff expressed an interest in also using the proposed project as a prototype or test of ETIP's evaluation process, and

suggested that, if successful, the process might be used in other areas within the Commission.

In October 1977, the staffs of the CCB, ETIP, and The Urban Institute

began conducting research. The following activities were included:

o A review of legal authority was completed in December \9~1

•

o The Urban Institute interviewed CCB staff about Commission procedures and specific plans for public message services deregulation.

o The Urban Institute drafted, verified, and revised an initial

report of findings based on these interviews.

3

o CCB staff drafted a briefing memorandum outlining the characteristics of the change.

o In July 1978, the Western Union Monopoly Inquiry proceeding

became part of the focus of the ETIP/Urban Institute research

effort to evaluate the impact of a decision, if implemented,

to open competition.

An official Memorandum, Opinion, and Order opening public message

services commerce to competition was prepared by CCB staff and approved by

the Commission on January 25, 1979. The Commission does not view this

decision to change its policy as an experiment. The decision was made for

reasons of policy and not for purposes of research. What is regarded as experimental is the evaluation process being developed, and the ways in

which it can be applied. The Commission has expressed a strong interest

in evaluation results as noted by Commissioner Ferris.

1. U.S. Department of Commerce, Bureau of Standards, Experimental Technology Incentives Program. Experiments in Communications Regulation , Project

Plan for ETIP Project 161, August 1, 1977.

2. U.S. Federal Communications Commission. "Memorandum of Law," from

Richard Severy to David Irwin, dated December 7, 1977.

3. Bell, James: The FCC/ETIP Regulatory Experiment , Working Paper Number

1198-70-01 (Draft), The Urban Institute, Washington, D.C., May 3, 1978.

4. U.S. Federal Communications Commission. "Points Memorandum,"

by David Irwin, et al., Summer 1978.
XI

.... I intend to ensure that the Commission monitors the

effects of this policy change. This evaluation will be undertaken by staff of the Common Carrier Bureau in cooperation with

the Experimental Technology Incentives Program (ETIP) of the

National Bureau of Standards. This will enable the Commission

to check its expectations of public benefits, based on today's

reasoned judgment, against subsequent events in the marketplace.

1

A proposed rulechange will be presented before the Commission, probably in April or May, 1979, and will be finalized after a public notice

period. The process that the Commission and ETIP will use to manage

the evaluation of the impact of the PMS deregulation over time is

currently being developed.

This report contains our findings to date about the operations of the

Commission and a logic for the proposed project, and assesses important

situations and issues in telecommunications. Using these findings and ETIP/

FCC criteria for success, the report also discusses the possibility of

developing a useful evaluation. It represents the result of approximately

27 person months of ETIP and Urban Institute staff time.

This project will also facilitate communications between the Commission,

industry, and others, such as Congress, that might be interested. We hope

that the report will encourage their interest and suggestions. We also

hope that this report and subsequent products of the evaluation will con- tribute to our understanding of evaluation process and methodology, theories

about innovation, effects of regulation, and other subjects of interest to

members of government, the research community, and industry.

The Regulatory Processes and Effects Project has been screening regulatory situations which might be appropriate for evaluation as administrative experiments. During the coming year, the methods we are developing

will be made more widely available to users. We welcome inquiries from

regulatory agencies that wish to draw upon our experience to date. For

further background the reader may wish to consult the Management Plan for

the Regulatory Processes and Effects Project and the latest proposal to ETIP , Proposal in Response to ETIP Solicitation No. EO-78-3603 .

This document was prepared and submitted under Department of Commerce

Contract #7-35822 by the Regulatory Processes and Effects Project. The report

represents work in progress at this time, and will be revised and updated

1. U.S. Federal Communications Commission News Release. "FCC Ends

Western Union Telegram Monopoly; Conditionally Approves Graphnet's Application for Domestic Service (CC Docket Nos. 78-95-96)," Report No. 14735,

Action in Docket Case, January 25, 1979—CC, Separate Statement of

Chairman Charles D. Ferris.
Xll

periodically, as we advance and receive additional information. These

reports are used for information exchange on the development of methodology

and on substantive results.

It should be noted that the usefulness of the findings about this

deregulation can be increased or decreased by the competency of the evaluation.

The evaluation must be perceived as thorough and impartial, and it must

produce useful findings.
Xlll

CONTENTS

Page

ABSTRACT iii

ACKNOWLEDGEMENTS v

PREFACE vii

CHAPTERS:

I INTRODUCTION AND ORGANIZATION 1

II SYNOPSIS OF THE REPORT 7 A. The Setting for the Deregulation 11

B. Present Situation 17

1. Commission Mandate and Code of Federal

Regulations Volume 47 17

2. The Commissioners 19

3. The Common Carrier Bureau 20

4. PMS Commerce Before Deregulation 21

5. PMS Commerce After Deregulation 23

C. Logic of the Evaluation 26

1. Event I—CCB Drafts M0&0 and Rulemaking to End PMS Monopoly 30

2. Event II—Commissioners Authorize Revised Rulemaking To Go 30

Into Effect

3. Event III—Common Carrier Bureau Streamlines Process 31

4. Event IV—Carriers and Others Apply To Offer PMS Services 32

5. Event V—Market Structure Is Observed To Change 32

6. Event VI —Findings of Systematic Evaluation 33

7. Event VTI—Knowledge Transfer 33

D. Potential Users and Uses of Evaluation Information 34

E. Summary of Assessment for Useful Evaluation 35

III FINDINGS ABOUT THE SETTING FOR THE EVALUATION 39

A. Organization 39

B. Historical Perspective: The Road to Regulation 41

1. Patent Protection and Independent Agreement

Between Potential Competitors Assure Each A

Market Share 41

2. Competition in Provision of Telephone Service

Experiences Market Failure 42

3. Telephone Independents Seek Lessening of

Antitrust Laws 44

4. Competitive Telegraph Market Fails 44

C. Regulated Telecommunications: Propensity For Change 46

1. Influence of the Regulator on the Industry 50

2. Regulatory Decisions Favoring Competition 51 a. FCC Decision Opens Terminal Equipment Market 52
XXV

Page

b. FCC Approves Licensing of Private Point-to-Point

Microwave Communications Systems 52

c. The Emergence of the Specialized Common

Carriers (SCCs) 53

d. The Value-added Carrier Decision 54

e. The Resale and Shared Use Decision 54

3. Regulatory Decisions Bolstering Monopoly 55

D. Telecommunications in Transition: Dynamics of Change 58

1. American Telephone and Telegraph 58

a. Possible Advantage Over Large and Small

Competitors—Ownership of the Network 58

b. AT&T and Fiber Optics 60

c. AT&T and Teletext-Viewdata Systems 61

d. AT&T, Xerox and IBM 62

(1) AT&T and the Domsat Moratorium 63

(2) AT&T and Satellite Business Systems 63

(3) Summary 64

2. Western Union Telegraph Company 65 a. Response to a Competitive Environment 65

b. The Infomaster System 68

c. Western Union and the United States Postal

Service (USPS) 70

(1) Implications of ECOM 71

(2) ECOM and Facsimile 72

(3) ECOM and Congress 73

3. The Specialized Common Carriers 73 a. Diversity 74

b. A Web Of Competitors 75

E. Investment, R&D Funding, and Corporate Strategy 77

1. An Example Involving Ownership and Investment

Patterns of the SCCs and An Example of Transfer

of Technological Innovation 79

2. Some Examples of Types of Influences on Innovation in Telecommunications 82

F. The Commission's Inquiry Process: Forum For Dialogue

With The Industry 84

1. Fair Charges and Interconnection 87

2. Redefinition of Obsolete Services 89

G . Summary 93

IV PRESENT SITUATION 95

A. Overview 95

B. Logic of the Evaluation 97

C. The Federal Communications Commission: Regulator of PMS 101

1. The Communications Act of 1934 101

2. The Commissioners 102

3. Code of Federal Regulations, Volume 47 103

4. The Common Carrier Bureau 105

a. Domestic Facilities and International

and Satellite Branches 110

b. Tariff Review Branch 111

c. Tariff Proceedings Branch 115
XV

Page

d. Complaints and Service Standards 115

e. Accounting and Audits Branches 117

f. Economic Studies 117

g. The FCC Inquiry Process and Line Support Activities 117

5. Summary 119

D. The Western Union Telegraph Company and PMS Commerce 120

1. The Western Union Telegraph Company 120

2. PMS Revenue and Service Characteristics 122 a. PMS Revenue and Volume in Perspective 127

b. PMS and Infomaster 129

E. Potential Competitors in Deregulated Public Message

Services Commerce 131

1. The United States Postal Service Mail 134

2. The Specialized Common Carriers 135

a. Graphnet Systems, Inc. 138

b. Telenet Communications Corporation 142

V A LOGIC FOR THE EVALUATION 147

A. Overview 147

B. Event I: Common Carrier Bureau Drafts An M0&0 and

Rulemaking Intended to End Western Union's Monopoly,

Open Public Message Services Commerce to Competition,

and Reduce Future PMS Regulation 149

1. Expectations 149

2. Activities 149

3« Timeframe 154

C. Event II: After Public Notification, Commissioners Authorize

CCB Revised PMS Rulemaking To Go Into Effect 154

1. Expectations 154

2. Activities 154

3. Timeframe 159

D. Event III: Common Carrier Bureau Streamlines The Process

For Administering Ongoing Public Message Services Regulation 160

1. Expectations 160

2. Activities 160

3. Timeframe 161

E. Event IV: Carriers and Other Interested Businesses Submit

Applications To Offer Public Message Services 163

1. Expectations 163

2. Activities 163

3. Timeframe 165

F. Event V: Public Message Services Market Structure Is

Observed To Change 165

1. Expectations 165

2. Activities 167

3. Timeframe 167

G. Event VI: Systematic Evaluation and Research Demonstrates

Improvement in PMS Commerce 169

1. Expectations 169

2. Activities 169

3. Timeframe 172
XVI

Page

H. Event VII: CCB and ETIP Transfer Knowledge Gained From

Evaluation As Evidenced By Products and Useful Applications

of Findings 172

1. Expectations 172

2. Activities 173

3. Timeframe 174

VI AN ASSESSMENT OF THE POTENTIAL FOR USEFUL EVALUATION 177

A. Overview 177

B. Need for Measurement Information 177

1. ETIP and FCC 177

2. Others Who Might Use Evaluation Information 180

C. Evaluation Measurement 184

1. Model for Measurement 184

2. Evaluation Measure Construction and Application 190

a. Measure Construction 190

b. Measure Application—A Hypothetical Example 192

D. Findings Concerning The Potential for Useful Evaluation 198

BIBLIOGRAPHY 203

GLOSSARY 213

APPENDICES (BOUND SEPARATELY AS VOLUME II)

A. PUBLIC MESSAGE SERVICES CHRONOLOGY (1844 Through January 1979)

Developed by Steven Watson and Sharon Kirby.

B. EXECUNET CHRONOLOGY WITH BRIEF INTRODUCTION (July 1975 Through

June 1978), Developed by Sharon Kirby.

C. SPACE INDUSTRIALIZATION CONCEPT AND IMPLICATIONS FOR TELECOMMUNICATIONS,

by Copper Wilson and Roland Weiss.

D. FINDINGS ABOUT INFORMATION SOURCES AVAILABLE AT THE FEDERAL

COMMUNICATIONS COMMISSION AND ELSEWHERE, By Sharon Kirby and James Bell.

E. POTENTIAL USES OF INFORMATION AND POTENTIAL MEASURABLE ISSUES,

Developed by Steven Watson, James Bell, Sharon Kirby, Paul Nalley

and Ro 1 and We is s

.

F. POTENTIAL USERS OF INFORMATION, Developed by Sharon Kirby.

G. FCC NEWS RELEASE ANNOUNCING END OF WESTERN UNION MONOPOLY AND

CONDITIONAL APPROVAL OF GRAPHNET'S APPLICATION FOR DOMESTIC

SERVICE (CC Docket Nos. 78-95-96).
XVI

1

FIGURES:

Page

II-l Technologies Which Have Affected, or Might Affect, The Public

Message Services Market, and Some Possible Innovative Services/

Applications that Might Occur in the Future 10

II-2 FCC Organization and CCB 47 CFR Responsibility 19

II-3 Basic Representation of Written Message Telecommunications

in Terms Of Senders, Receivers, Carriers, and Regulator 22

II-4 Components of PMS Regulation and Commerce, Current Status 24

II-5 Logic of the Deregulation Evaluation In Terms Of Main

Events Expected To Occur 27

III-l Western Union Telegraph—All Offices and Agencies (1944-1977) 68

III-2 Patterns of Ownership and Investment—Examples From SCCs 80

III-3 Generic Telecommunications Issues and Links to Current Debates 86

IV-1 Expected Events of the Deregulation—The Logic 100

IV-2 Basic Organization of FCC 105

IV-3 CCB Organization and 47 CFR Responsibility 107

IV-4 Tariff Filings Per Carrier, 9/76 to 4/78 109

IV-5 Tariff Filings Per Month 109

IV-6 Scale Showing Time Constraints and Steps of Tariff Analysis

in Preparation for Regularly Scheduled Commission Agenda Meeting

(90-day Notice Period) 116

IV-7 Steps in the FCC/CCB Inquiry Process 118

IV-8 The Western Union Telegraph Company, Percentage of Employees

By Function 122

IV-9 Distribution of Public Message Services Volume By Percent Per

Class of Message 123

IV-10 Western Union Operating Revenue by Type of Service, 1976 127

IV-11 Western Union Operating Revenue, Selected Years 1945-1976 128

IV-1 2 Distribution of Revenue in Regulated Telecommunications

Commerce, 1976 129

IV-1 3 Western Union's PMS Network 130

IV-1 4 The Western Union Infomaster Computerized Message

Switching System 132

IV-15 Graphnet Computerized Store-and-Forward Facsimile

Communications System ^-^ 141

IV-1 6 Cost Comparison of Fax Grammy and Telegram 142

IV-1 7 The Telenet Network, 1977 144

V-l Event I Participants, Activities, and Potential Products,

Measures, and Information Uses 153

V-2 Event II Participants, Activities, and Potential Products,

Measures, and Information Uses 158

V-3 Event III Participants, Activities, and Potential Products,

Measures, and Information Uses 162

V-4 Event IV Participants, Activities, and Potential Products,

Measures, and Information Uses 166

V-5 Event V Participants, Activities, and Potential Products,

Measures, and Information Uses 168
XVI11

Page

V-6 Event VI Participants, Activities, and Potential Products,

Measures, and Information Uses 171

V-7 Event VII Participants, Activities, and Potential Products,

Measures, and Information Uses 175

VE-1 Special Interest Measurement Needs of Sponsors 179

VI-2 Potential Users of Measurement Information—Participants

and Onlookers 182

VI-3 Components of PMS Regulation and Commerce, Current Status 185

VI-4 Expectations for Measurement Associated with the PMS

Deregulation 189

VI-5 Extended Impact of Deregulation 191

VI-6 Basic Configuration of the "Process Rate" Measure 193

VI-7 Hypothetical Evaluation Measure Application: Innovation in

Terminal Equipment in Relation to the PMS Deregulation 195

TABLES:

IV-1 Notice/Petition Period Guidelines 116

IV-2 Western Union PMS Messages and Revenues, 1977 126

IV-3 Service Characteristics of Ten Carriers (Western Union

and AT&T Compared to Eight Specialized Common Carriers) 136

V-l Hypothetical Stipulations for PMS Carriers Compared to

Current Content Requirements in Sections of Part 63

of 47 CFR 151

V-2 Sample Set of Measures 156

V-3 Percentage Change in 47 CFR Rules and Requirements

(Hypothetical) 157

VI-1 A Page From Appendix E's Section on Graphnet/ Telenet

Application to Enter International Market Showing Sample

Use of Measurement Information 183

VI-2 Description of Components of PMS Regulation and Commerce 186

VI-3 Links Between Components of PMS Regulation and Commerce 187
I. INTRODUCTION AND ORGANIZATION

Telegraph service preceded telephone service by 40 years. For much

of the 1800s, it was the primary telecommunications method in the United

States. (See Appendix A, chronology of major events in the history of

public message services [PMS].) The Communications Act of 1934 gave the Federal

Communications Commission jurisdiction over the telecommunications industry

and made the Commission specifically accountable for several trusts including

safeguarding, for the public interest, "a rapid, efficient, Nation-wide and

worldwide telegraph . . . service at reasonable charges."

In 1943, The Western Union Telegraph Company was granted a de jure

monopoly in this market, to insure the availability of public message

2 telegraph services, including the telegram. Since then alternate public

message-type services (both unregulated and regulated) have come into

common use, often displacing the traditional telegram. Low cost, easily

accessible telephone service may be partly responsible for the telegram's

decline

.

Data processing and electronics technologies developed during the

last 20 years have also influenced the telecommunications field. As a

result, Western Union's regulated public message services have lost customers,

especially commercial customers, to parallel data transmission technology

1. Communications Act of 1934: Title I, Section I. 2. According to Part 21, Chapter 1, Subchapter B, "Common Carrier

Service," of the Code of Federal Regulations, Volume 47, public message

service is defined as "a service whereby facilities are offered to the public

for communications between all points served by the carrier or by interconnected carriers on a non-exclusive, message-by-message basis, contemplating

a separate connection for each occasion of use."
and message transfer services. Many believe that lowering of regulatory

barriers and ending the Western Union PMS monopoly could make these innovations available to the general public and revive the public message services

market

.

On January 25, 1979, the Commission voted to change its policy and

allow competition in this market. The Commission made its decision during a

period when political, economic and technological developments facilitate a

decrease in telecommunications regulation. Therefore, the methods used by the

Commission to deregulate and successfully convert a monopolistic public message

services market to a competitive one will probably interest many people in

government, industry, and the research community.

This report presents a preliminary assessment of the potential of

the Commission's initiative to be evaluated usefully. Until the final

Commission rulechange and reactions of industry are known, the boundaries

of the evaluation cannot be confidently defined, and the initial set of

evaluation measures cannot be finalized. We expect to distribute this

document to interested parties in government, industry, and the research

community, to both inform them of our efforts so far and elicit comments.

Their comments should be helpful in directing the future course of the

research.

Chapter II is a synopsis of this report. For detailed discussions

of major points raised in this chapter (and specific references to source

materials), refer to the main body of the report, which is organized as

explained below.

1. Throughout this report, the term deregulation is used to denote

a change in policy, practice, and/or rules which reduces (but does not

necessarily eliminate) the burden on the regulatee. The term reregulation

has also been used to denote such a change.
Chapter III examines the telecommunications industry environment in

which the deregulation will take place. Historical developments, industry

trends, and current issues in telecommunications regulation are presented.

The chapter discusses the need to investigate how to use economic, technical,

and other information on telecommunications issues to better understand

novel regulatory situations. We attempt to demonstrate that an ETIP administrative experiment, could help supply necessary information for other areas

of Commission inquiry as well. Additional work must be done at both the

theoretical and operational levels. For example, issues, hypotheses, and

measures for this change must be specifically linked to existing theories in

the literature, and information must be exchanged more directly with industry.

Chapter III should be of interest to all three groups—government,

industry, and the research community—mentioned earlier. We are interested

in receiving (1) comments on our accuracy in representing the views of

various observers, (2) additional views on the issues presented, and

(3) data to support or refute the various views presented.

Chapter IV introduces a logic, or the main events which must occur for

the evaluation to be successful. The chapter also examines the present

regulatory situation by discussing the dominant factors involved in this

logic: the Commission's mandate for telecommunications regulation; the

Federal Communications Commission's processes for implementing this mandate

through regulations and Common Carrier Bureau operations ; and The Western

Union Telegraph Company and the current public message services market.

We also describe the operations of two common carriers that will probably

become competitors of Western Union in the PMS market. The descriptions
illustrate how new providers of public message services might differ from

Western Union in services and operations. More research in industry is

planned.

Readers from the government should find Chapter IV useful not only for

its description of the regulatory process, but also for information on industry,

Similarly, readers from industry might be interested in the information on

regulation as well as that on industry. We are particularly interested

in comments from any of these groups that verify or improve the accuracy,

validity, and specificity of the descriptions presented.

Chapter V contains a proposed plan for developing an evaluation,

organized in terms of the sequence of main events identified in Chapter

IV. Specifically, this chapter outlines the participants, activities,

expected products, measures and comparisons, information uses, and timeframe

associated with each event. While this chapter is presented mainly for ETIP

and FCC use, researchers may also wish to examine our proposed approach.

We are interested in any suggestions that will help improve the plan for

tracking the effects of the deregulation. Data which would help us assess

the plausibility of the expected effects would also be appreciated.

Chapter VI assesses the potential to usefully evaluate the effects of

the deregulation. It demonstrates that many choices must be made concerning

how to target the evaluation and how to allocate efforts in each area

marked for close scrutiny. We outline a preliminary set of measures,

which will be refined as the FCC policy shift goes into effect and as

the research progresses. Readers in government, industry, and the research

community will probably be interested in different sections of Chapter VI.
We would particularly like to receive reactions to our preliminary set

of evaluation measures and information on their feasibility and validity.

A glossary of terms and a bibliography of books, articles, etc., reviewed

during this preliminary phase of work are included at the end of the report.

Bound separately as one volume are seven appendices which are referred

to in the main body of the report. These are:

• Appendix A: Public Message Services Chronology (1844 Through

January 1979)

• Appendix B: Execunet Chronology With Brief Introduction (July

1975 Through June 1978)

• Appendix C: Space Industrialization Concept and Implications For

Telecommunications

• Appendix D: Findings About Information Sources Available At

The Federal Communications Commission and Elsewhere

• Appendix E: Potential Uses of Information and Potential Measurable

Issues

• Appendix F: Potential Users of Information

• Appendix G: FCC News Release Announcing End of Western Union

Monopoly and Conditional Approval of Graphnet ' s Application for Domestic Service (CC Docket Nos . 78-95-96)

1. Please send comments to the ETIP/FCC Evaluation Design Group,

Performance Development Institute, 1800 M Street, N.W. , Suite 1025,

Washington, D.C. 20036.

II. SYNOPSIS OF THE REPORT

On January 25, 1979, the Federal Communications Commission decided

to deregulate public message services, and open this market to competition.

Deregulation of public message services was chosen as the subject of a

project, jointly sponsored by the Commission and the Experimental Technology

Incentives Program (ETIP). The Commission does not view this decision

to change its policy regarding PMS as an experiment. The decision was

made for reasons of policy and not for purposes of research. However, the

evaluation process being developed, and its use, are viewed as experimental.

The primary purpose of this project is to obtain knowledge about the agency,

the industry, and the commercial impacts of changes in the regulatory

process, and to evaluate specifically the impact of the public message

services deregulation.

The changes in rules and regulations governing PMS commerce must conform

with the policy intent of the Commission, which is to reduce PMS regulation

and encourage competition. Although the Commission does have a great deal

of flexibility in changing its rules and procedures, both Congress and

the courts strongly influence Commission actions. It should also be noted

that the Commission's authority to deregulate any telecommunications service

is limited by the Communications Act of 1934; for example, the Act requires

the agency to regulate rates.

1. Throughout this report, deregulation denotes a change in policy,

practice, and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
The effects of deregulation are currently being debated, in both

the research and policy communities. Many debaters believe that opening

regulated markets will lead to increased competition and that this, in

turn, will result in increased technological innovation. Consequently,

a major hypothesis which this project is testing is whether a competitive

PMS market will create an environment for carriers to offer a greater variety

of better quality and less expensive public message services to the public.

The project can also be related to a broader issue: the role of competition

in the telecommunications industry as a whole.

The deregulation of public message services seems consistent with

recent events in telecommunications and the current policy of actively

encouraging a competitive environment. In the 1960s, innovations in the

data processing and electronics technologies began to influence telecommunications. The scope of regulation has consequently become vague in

certain market segments (data communications, for example), and traditional

service definitions are no longer adequate. Technologically, traditional

telegraph services (and perhaps traditional telephone services) have become

obsolete for many commercial and private purposes. The Commission is now

confronted by unusual regulatory situations, which require a reexamination

of its rules, regulations, and procedures, and which seem to call for a more

effective data-gathering approach than the agency has used in the past.

(See Chapter III for examples of decisions currently facing the Commission.)

Systematic evaluation of a major Commission policy change is rare.

Traditionally, the Commission makes decisions on a case-by-case, or problemby-problem basis. Chapter IV describes Commission procedures and shows

that CCB staff authority and expertise, the inquiry process, and legal

precedent and process have been the primary avenues for handling disputed
situations. Data gathering that promotes transfer of relevant information

about the effects of recent decisions might supplement this traditional

approach. It should also be pointed out that there is virtually no evaluation measurement system for regulated telecommunications commerce; thus,

the groundwork laid by an evaluation of this regulatory change could be

very valuable. At the very least, however, the project should help improve

the evaluation of this deregulation's impact on industry.

Therefore, the public message services deregulation provides an opportunity for the Commission (1) to analyze and implement appropriate procedural

changes and (2) perhaps more important, to study an actual shift from a

monopoly to a competitive market. We hope that the information gained

will help clarify the advantages and disadvantages of competition in the

telecommunications industry and assist policy makers as they plan for the

future.

ETIP is particularly interested in determining whether deregulation

will stimulate innovation in public message services technology, and in

increasing its understanding of the relationship between innovation and

the many factors, including regulation, which influence the introduction

of state-of-the-art technologies into the marketplace. Several technologies

presently available or under experimentation could contribute to truly

innovative and perhaps improved public message services. These technologies

include facsimile, electronic mail, satellite relay, personalized computer

communications, etc. Figure II-l illustrates major innovations of the

past and some technologies and services currently on the market or under

development. (For a more detailed description of these technologies, see

Chapter III.)
10

2020-

E P T

X

P S

E s B N R I E

I B 4 W M L

E E N N

T T M

A A A

L R R G K

E E T T

U980-

1970-

> Space Station Communications Transmission

> TFurther Innovations?

—> More Powerful and Cost Effective Microwave and Satellite Transmission —> Fiber Optics Transmission

(light wave and laser technology) —> Message-flwltchable Facsimile

(fully Integrated into other networks)

-> Digital Transmission

(packet switching) —> Satellite Transmission —> Computerized Message Switching

Possible Applications/

Services

• Electronic Message Systems

• ECOM

• Office Communications

• Teletext

• Viewdata

• Education

• Health Care

• Emergency Services

• Personal Computer

• Teleconferencing

—> Telex —> Microwave Transmission

N

T

H

E

M

A

R

K

ET

I 1940-

1920|

1880-

-> Facsimile Transmission

-> High-speed Switching Systems

-> Teleprinter

-> Automatic Telegraph Transmission

-> Multiplexing

> Telephone-grade Transmission (analog)

18 70-

-> Ocean cables

> Telegraph-grade Transmission

Source: Interview with FCC Staff and FCC Information Bulletin . "A Short History of Electrical Communication," February 1977.

FIGURE II-l: TECHNOLOGIES WHICH HAVE AFFECTED, OR MIGHT AFFECT, THE

PUBLIC MESSAGE SERVICES MARKET, AND SOME POSSIBLE INNOVATIVE SERVICES /APPLICATIONS THAT MIGHT OCCUR IN THE

FUTURE
11

As we suggested earlier, the primary purpose of this project is to

gather empirical data on the actual effects of a specific deregulation.

These data will help us to completely or partially answer the questions

discussed above and elsewhere in this report.

A. THE SETTING FOR THE DEREGULATION

An historical review shows that, under the competitive conditions

prevalent in the early years of the industry, both telephone and telegraph

services experienced market failure. As a result, both telephony and telegraphy were classified as natural monopoly markets (that is, a market which

one firm can supply at a lower per-unit cost than two or more firms). Some

other forces that contributed to monopoly conditions included early patent

laws, intercorporate agreements, duplicative and unprofitable services, the

Depression and World War II. (See Chapter III.) Therefore, some observers

believe that the advantages and disadvantages of competition in the telecommunications industry were therefore never adequately tested, and some assert

that present market conditions are different and warrant reexamining the

role of competition in the industry.

As mentioned, during the 1960s, innovations in the data processing

and electronics technologies began to influence telecommunications. In

response to these changes in the telecommunications environment, the Federal

Communications Commission made a series of decisions which opened markets

to competition and began to make the advantages of new services available

to the public. Some observers believed that the established carriers (AT&T

and The Western Union Telegraph Company) did not have the technical or service

capabilities required to meet new market demands for data communications and
12

nontraditional private line service offerings. (See Chapter III, Section

C2, "Regulatory Decisions Favoring Competition.")

During the past 20 years, AT&T and Western Union have upgraded services

and technical capability and now offer the full range of customized private

line and terminal equipment services. AT&T has also proposed services which,

with AT&T's ownership of the underlying transmission network and its manufacturing and financial resources, may surpass those offered by competing smaller

carriers. Western Union is also embarking on new ventures, especially in

the unregulated sector; the company has recently increased its involvement

in government contract work. It now offers Mailgram service in conjunction

with the United States Postal Service (USPS) and intends to collaborate with

USPS shortly in Electronic Computer-Originated Mail service (ECOM) , an outgrowth of Mailgram. In this arrangement, Western Union's primary responsibility will be to accept and transmit messages.

The Commission must decide whether to authorize these new services

proposed by the established carriers. Many other important decisions are

also pending. The Commission must review an earlier decision to allow

Satellite Business Systems to merge its operations with IBM, COMSAT, and

Aetna Life Insurance Company; it must consider whether to extend the moratorium on AT&T's entrance into the satellite communications market; and

it must review Xerox's requests to enter the telecommunications industry

through a proposed subsidiary, Xerox Telecommunications Network, and to acquire Western Union International. These decisions could affect the success

or failure of a competitive public message services market. For example,

would the presence of the USPS's ECOM service or of Xerox's office facsimile

services inhibit smaller firms from entering the message service markets?

1. In terms of quality and speed, Mailgram is a class of priority

message service between the telegram and First Class Mail.
13

We do not presently know which companies will apply to provide PMS domestically. Common carriers that are already operating might step forward, or

new firms might apply for licensure as common carriers in order to offer PMS.

Members of the Specialized Common Carrier group (SCCs) are expected

to enter the PMS market. Two characteristics of the SCCs are important.

First, these carriers are very diverse in size and resources. Second,

they engage in complex competitive relationships in both regulated and

unregulated markets.

These two facts present the Commission with a difficult situation in

which it must establish standards for competition and develop a system for

smooth transition to an open market which will treat diverse carriers fairly

and still protect the public interest. Commission staff are considering

alternate approaches for addressing this situation in the present deregulation.

For example, should only Western Union, and no other public message carriers,

be held to stringent regulations (such as those presently governing reporting

requirements or conditions for office closure)? Or should the same rigid

rules apply to all public message carriers? Or should rules be substantially

relaxed for new entrants, while Western Union is required to adhere to

more stringent rules until the shift to competition is well under way?

Evaluation data on the effects of a decision such as this and experience

gained in guiding the deregulation could be useful to the Commission in

other areas.

Although public message services deregulation is a unique situation

which directly affects only a small part of the industry, there may be

core issues present which can be linked to questions in other problem areas

1. Chapter IV presents a complete list of carriers generally regarded

as specialized, and a more thorough discussion of characteristics of the

SCCs.
14

confronting the Commission. ETIP and The Urban Institute staff analyzed:

(1) issues raised by individuals and organizations who filed formal comments

on pending Commission decisions regarding five inquiries, and (2) testimony

before Congress regarding H.R. 13015, the Communications Act of 1978. Nine

possibly generic issues were identified. They are:

I. What is the appropriate economic justification for continuing

monopoly regulation?

II. Should regulation be maintained in order to preserve a certain

minimum level of quality in the service or technical system

efficiency?

III. Does a regulated or an unregulated environment provide better

distribution of service to low-density areas?

IV. Will deregulation encourage technological innovation?

V. How should the regulatory boundaries of an agency be altered

when new services and technology arise in peripheral unregulated markets?

VI. How does one prevent regulated carriers from making anticompetitive intrusions into the unregulated marketplace?

VII. How does one assure just and reasonable charges and nondiscriminatory rates?

VIII. What is the tradeoff between streamlining procedures and

maintaining the quality of regulatory decisions?

IX. How should the transition from monopoly to competition be

handled?

The analyses suggested that information gained from the evaluation

might be used in two ways: (1) to develop empirical equipment and/or service standards on which to base Commission decisions and (2) to test the

possibility of generalizing from core issues, which cut across inquiries

as well as across broad policy questions being debated in Congress.

1. These inquiries include: the Western Union Monopoly Inquiry; the

MTS/WATS Inquiry; the Telex/TWX Inquiry; the Gateway Inquiry; and the

Computer Inquiry. Chapter III and Appendix E, "Potential Uses of Information

and Potential Measurable Issues," describe the inquiries. For an explanation

of the inquiry process, see Chapter IV.
15

The fifth generic issue above can be used to present an example of the

first type of use. It is possible that the deregulation will result in the

use of innovative types of computerized message switching technology. Information gained from systematic observation of the equipment in use and its

effects on PMS applications and commerce might help the Commission to determine what "intelligence" threshold, or service category, would identify

transmission systems that are primarily data processing. Such transmission

systems are not subject to telecommunications regulation. Since no formal

standards have been defined, Commission decisions about which hybrid equipment and/or services should be regulated are currently made on an case-bycase basis.

The second use of evaluation information reflects the fact that each

major area of inquiry is related to many underlying technical, economic,

and/or political issues. For example, in the Western Union Monopoly Inquiry,

which contains issues of direct concern to the PMS deregulation, individuals

and organizations submitted the following questions to the Commission.

• Can Western Union inhibit public message services competition by

subsidizing with Telex/TWX revenue?

• What rate structure should be used when Western Union interconnects

with other carriers providing PMS?

• How vital is PMS to the public?

• Should the Commission prescribe technical standards or customer

service standards for PMS or will a competitive market structure

be adequate to insure that carriers meet customer needs?

• Is public message services a natural monopoly, characterized by

economies of scale, or has it evolved into a "resale" service?!

1. Resale carriers lease facilities from other carriers; they own no facilities of their own.
16

Over time, answers to these questions might also provide empirical

evidence to answer questions about the characteristics of natural monopoly

markets, rate structure, issues of definition, etc., which are debated

in connection with other telecommunications markets. Chapter III presents

examples showing the interrelationship of generic issues and the ways they

relate to some specific questions.

Information about outside factors which may affect the deregulation

is also needed. One of these factors is congressional activity, such as

the Communications Act of 1978. Less obvious factors include investment

and ownership patterns, research and development funding, and corporate

decision making. For example, facsimile systems which can be fully integrated into other communications networks are currently being developed

and may be a very important component in electronic message systems. This

technology might affect the nature of new public message services. Corporations might base decision making regarding expenditures in this area on

market analyses, intercorporate agreements, investor interest, high-risk or

low-risk characteristics, potential competition, probable technical difficulty, and time/cost factors until a fully integrated system can be achieved.

Any of these factors—or Commission activities—could affect whether fully

integrated message-switchable facsimile systems become available in the

marketplace. (For other examples of potential outside influences on the

PMS market or telecommunications in general, see Chapter III.)

In short, many variables can influence the development of an industry.

In addition to those listed above, these are: marketing capability, consumer

attitudes, supply and demand factors, corporate diversification, economies

of scale, inflation, employees and unions, etc. Since most of these can

be observed clearly in a study of telecommunications, and since decisions
17

made by Congress or the courts could have a direct impact on this deregulation, some mechanism in the evaluation design to monitor industry dynamics

and related events in telecommunications seems appropriate.

The following sections of this chapter will concentrate on the evaluation itself. Specifically, we will summarize the dominant elements, the

plan (or logic) in terms of the main events we expect, and the findings

so far on this project's potential for useful evaluation. (it should be

noted at this point that the plan is subject to change by either the Commission or ETIP.)

B. PRESENT SITUATION

The principal elements operative in this evaluation are discussed in

detail in Chapter IV of this report. They include: the Commission's mandate contained in the Communications Act of 1934 and in the Code of Federal

Regulations Volume 47 (47 CFR) governing telecommunications; the Commissioners; the Common Carrier Bureau (CCB) of the Commission, which is directly

responsible for common carrier regulation; PMS commerce before deregulation;

and PMS commerce after deregulation.

1. COMMISSION MANDATE AND CODE

OF FEDERAL REGULATIONS VOLUME 47

Written policy and rules, such as the Communications Act of 1934 and

47 CFR, are important because of their relationship to Commission actions

and Congressional policy intent as well as to Common Carrier Bureau organization and procedures, and its effects on telecommunications commerce.
18

The Commission's mandate is contained in Title I of the Communications

Act of 1934. Specifically, the mandate makes the Commission responsible

for:

. . . regulating interstate and foreign commerce in communications by wire and radio so as to make available ... to all

the people of the United States a rapid, efficient, Nation-wide,

and worldwide wire and radio communication service with adequate

facilities at reasonable charges ....

Title II of the Act gives the Commission the tools and powers to regulate

the industry; for example, the carriers are required to file rate schedules

with the Commission.

Each Part of 47 CFR contains rules and stipulations governing general

or specific operational responsibilities of the Commission. Each branch of

the Common Carrier Bureau is assigned one or more Parts of 47 CFR relating

to common carrier regulation, including public message services. (See

Chapter IV for a description of Parts of 47 CFR most relevant to PMS.)

Figure II-2 depicts the Commission organization with special emphasis on

the Common Carrier Bureau, and lists the parts of 47 CFR administered by

each CCB branch.

The rules and stipulations of 47 CFR define which carrier activities

are subject to Commission review. (See Chapter IV for a more detailed description of 47 CFR.) Common Carrier Bureau staff develops forms and protocols for handling common carrier applications, which must be consistent

with 47 CFR requirements and the intent of language specified in these

rules

.
19

OFFICE

AND

BUREAUS

COMMON CARRIER

BUREAU

Commissioners | 7 members

I Office of Executive

Director

I Office of Plans and Policy

J. Office of Chief

Engineer

Office of General

Counsel

I Office of Administrative

Law Judges

Review

Board

I Common

Carrier Bureau

Broadcast

Bureau

I Cable

Television

Bureau

J. Field

Operations

Bureau

Office

of the CCB Chief

SUPPORT GROUPS

FOR ALL DIVISIONS

AND BRANCHES

REGULATOR

DIVISION MANAGERS

Program

Evaluation

International |

Programs |

Policy and Rules —

1 T7„ rt -* mJ «« 1

Facilities and Service Division

Tariff

Division

Accounting

and Audits

Division

Hearing

Division

Safety and

Special Radio

Service Bureau

Office of Opinion

and Review

REGULATOR

BRANCHES

SPECIFIC PARTS OF 47 CFR IN WHICH

STAFF ARE EXPERT AND HAVE PRIMARY RESPONSIBILITY FOR ADMINISTRATION

International |-»- and Satellite !

Domestic

Facilities IComplaints

and Service

Standards

21 Domestic Public Radio Services

23 International Fixed Public

Radio Communication Services

25 Satellite Communications

63 Extension of Lines and Discontinuance of Service

64 Miscellaneous Carrier Rules

i Tariff Review f-*-

Tariff

Proceedings

Account

and Audi

ingl >

its|

61 Tariffs

Economic

Studies

31 ) 33/ Uniform System of Accounts

34f for Various Types of Carriers

35)

42 Preservation of Records

Mobile

Services

+- | 21 Domestic Public Radio Services |

Source: 47 CFR, Part 0, and interviews with CCB staff, Summer 1978

FIGURE II-2: FCC ORGANIZATION AND CCB 47 CFR RESPONSIBILITY

2. THE COMMISSIONERS

The Commissioners make decisions about contemporary issues. These

selections set precedents for subsequent Commission actions, including

routine staff decisions. The Commissioners also control resources and,

to some extent, the agenda of activities of Common Carrier Bureau staff.

In these ways, the Commissioners influence the character of telecommunications regulation and commerce.
20

3. THE COMMON CARRIER BUREAU

Most CCB staff are either attorneys, economists, engineers, public

utility specialists, managers, or administrators. Most common carrier

interaction with CCB branch operations involves applications to change

business practices. For example, if Western Union wanted to change the

location of a station, it would first submit an application to the Domestic

Facilities Branch of CCB to obtain authorization to construct additional

transmission lines. If authority to provide new services or a rate change

is desired, the carrier must also submit a tariff to the Tariff Review

Branch. Different types of applications are known as filings; filings

are usually approved, disapproved (or denied), or withdrawn. Commission

approval or disapproval is termed a ruling. Tariff applications, however,

are not "approved." For example, Part 61 of 47 CFR (concerning rates)

stipulates that a tariff filing may be considered effective if there is

no Commission decision to the contrary within a prescribed period of time.

In other words, the tariff becomes effective within a certain period if

the Commission finds no compelling reason to deny it.

The number and types of activities required to produce a ruling seem to

vary according to application classification (for example, station license).

Most filings are routine and require only simple, low-cost activities to

produce a ruling. However, some are quite complex and require a heavy

investment in activities. Bureau operations are best suited to routine

types of filings. Activities seem to be devised to handle large carriers,

especially the established carriers.

Difficult or disputed applications are handled by relying on staff

expertise in specific areas of common carrier regulation, rather than on
21

any one group or formalized procedure. Only when CCB staff authority and

expertise cannot resolve a problem filing are Commission lawyers and the

legal process called into play.

4. PMS COMMERCE BEFORE DEREGULATION

To put it simply, the job of the telecommunications industry is to

move a message, written or verbal, from A to B. It is a $43-billion-a-year

business based on the ancient concept of "courier." What was once the

province of runners, riders, and assorted vehicles of hand delivery is fast

becoming a completely automated system of information transfer, characterized

by computers, microwave technology, and other innovations that will probably

bring an electronic message age to the public in a relatively short time.

There are eight key players in the interstate telecommunications

industry: three types of senders, three types of receivers, the carriers,

and the regulator. Figure II-3 illustrates how the players on the hardcopy

or "record" side of telecommunications interrelate. The boxes on the left

represent government, private (e.g., large corporations), and general public

senders (e.g., residential and small business), while the broken connecting

lines between the two columns of boxes represent the current carriers and

their transmission facilities. The boxes on the right are government,

private, and public receivers of written messages. The figure illustrates

that message exchanges involving the public as sender or receiver are the

subject of the proposed deregulation. Excluded, are government-to-government

and private-to-private exchanges utilizing privately owned networks. The

check marks indicate that key record message exchanges for this evaluation

are public to public, private to public, and government to public.
22

REGULATOR

Federal

Communications

Commission

T

SENDERS

Government

Private

Public

r~

CARRIERS

TRANSMITTING

MESSAGES

y

v-L

I

RECEIVERS

Government

Private

Pub lie ^

FIGURE II-3: BASIC REPRESENTATION OF WRITTEN MESSAGE TELECOMMUNICATIONS

IN TERMS OF SENDERS, RECEIVERS \ CARRIERS, AND REGULATOR

In 1943, The Western Union Telegraph Company was granted virtual monopoly

status as supplier of message record services to the general public. Since

then, the volume of public record messages has dropped precipitously from

a high of about 231 million in 1943 to about 37 million in 1973—an 84 percent

slide. After bottoming out in 1973, there has been a slight recovery, as

illustrated by a 45 million message volume for 1977. Nonetheless, the volume

of public record messages has declined a full 80 percent since the monopoly

was granted. As of 1977, PMS revenues represented less than .3 percent of

the total revenue generated through regulated telecommunications.

The Western Union services which could be exposed to competition include:

Mailgram, full rate telegram, domestic transmission portion of messages to

and from locations outside of the United States, and money order service. In

1977, these four services generated 95 percent of the total PMS revenues. Other
23

public message services, such as the press telegram service, generated only

minor revenue.

In 1977, the basic facts regarding the high-revenue generating services

traditionally considered PMS were as follows:

• The full rate telegram preceded other public message services

and, at one time, was the most common. In 1977, it accounted

for 17.3 percent of the PMS dollar revenue and only 9 percent

of the total message volume.

• Mailgram accounted for the largest volume, 53.8 percent. Western

Union Telegraph Company revenue generated by Mailgram totaled

over $44 million or 53.8 percent of the PMS revenue and about

9 percent of the company's total revenue in 1977.

• Domestic transmission of transoceanic communications or "cablegrams"

was the second most active public message service in 1977, generating 17 percent of the message volume and 13.1 percent of

PMS revenue.

• Telegraphic money order, providing 14 percent of the volume and

about 32 percent of the revenue, was the third largest service

class with 6 million money transfers in 1977. (Just as a jurisdictional problem may occur in connection with the service outgrowth of Mailgram, ECOM, there is a possibility that a similar

problem may develop when the telegraphic money order is deregulated,

whether electronic fund transfers should be regulated is also a current issue.)

Figure II-4 illustrates our model of current PMS commerce. This model is

still subject to further validation by industry. Chapter VI contains a more

detailed depiction of this model and compares it to a model illustrating

expectations about changes in PMS commerce as a result of deregulation.

5. PMS COMMERCE AFTER DEREGULATION

As we mentioned, the carriers and services which will opt to serve this

market cannot be identified at this stage of the deregulation. Most of the

information which follows is presented to suggest, based on our analysis to

date, potential effects and impacts of the deregulation.

Electronic message service is a wide open field. Most of the new

specialized carriers serve business markets but have capabilities for resale
24

The Commission

THE FEDERAL

MiirJSiCATiONS COMMISSION

PMS Agenda Items Pending Mandate In Question

for PMS

PMS Policy and Rules

High Number of CFR Stipulations

Monopoly Oriented Policy and Definitions for PMS

CCB Organization and Process

for Regulating PMS

General Public

and Onlookers

Chief

Management Policy and Rules Tariffs Facilities and Services Complaints/ Standards Accounts/Audits

Economics Hearings

10 PMS Facil. Filings Per Year

20 PMS Tariff Filings Per Year

Staff time to handle PMS Filings

varies—can be very time con- suming due to monopoly conditions

Carrier, HATS, DSPS, etc. Some complaints

Comments Congressional

activities

• Virtual Monopoly

• 30 filings per year

• 14 reports per year

Service Network

THE PUBLIC MESSAGE SERVICES MARKETPLACE

Senders

$146 million purchase

per year

few social users

$4.47 per message

Approx. ten message

services available

Central Telephone Bureau Infomaster System

few in/out modes

45 million messages Basically computerized- message switching

Receivers

45 million messages

54 percent mailgram

i and Support Standard rate, leased lines Terminal equipment

type/price

Status of Commerce

.3 Percent of Total Telecommunications Revenue

FIGURE II-4: COMPONENTS OF PMS REGULATION AND

COMMERCE, CURRENT STATUS
25

or transmission which could be used to provide a variety of services,

including those traditionally considered public message services and even

some outside the bounds of regulated telecommunications. For example,

some services of the USPS mail could probably be provided by regulated

PMS carriers.

The competition for public message services is already under way.

For example, we found it possible to move hardcopy text from one location

to another using word processing firms. The service is inconvenient and

expensive, but workable. We also suspect that it would be possible to

purchase, on a walk-in or phone-in basis, interstate transfer via small

private computer terminals. In addition, a December 16, 1978, Washington

Post article announced that a company is now offering transmission and

hookup service to interconnect personal computers. At the moment, these

patchwork arrangements seem to signal the market for such services. Also,

competition might come from any number of major corporations with extensive

private communications networks. For example, a large hotel chain could

easily open its message transfer system to the public and establish itself

as a public message services carrier.

However, the United States Postal Service and some of the specialized

common carriers seem the most likely competitors in an open PMS market. The

USPS might capture a large share of the market with its proposed ECOM service.

For the specialized carriers, however, the deregulation will be the first

opportunity to enter legally into the market. Likely entrants from the

specialized carrier group are discussed in detail in terms of service operations, revenue, capital, employees, etc., in Chapter IV of the report.

Essentially, findings show that would-be competitors in an open PMS market
26

differ dramatically in size from Western Union and the USPS. However,

they are surprisingly similar in their basic capability to provide message

services

.

C. LOGIC OF THE EVALUATION

Figure II-5 illustrates a logic or chain of events of the evaluation

in relation to our current model of PMS commerce (Figure II-4). The figure

points out the distinction between the first five events, which center

around achieving reformulated PMS commerce, and Events VI and VII, which

focus on processing and analyzing information.

The "intervention" is defined by activities which could occur during

the first three events. Event I activities might be characterized as preparatory; e.g., drafting a set of revised rules to govern a deregulated PMS

market. Event II concerns obtaining Commission authorization for the deregulation. The first major activities occur during this phase: (1) approval

of the Memorandum, Opinion, & Order, (M0&0), which announces the deregulation

and explains the Commission's rationale for deregulating PMS; and (2) approval

of the finalized rulechange. Event III deals with streamlining Commission

procedures for handling PMS filings.

As of January 1979, most Event I activities have occurred. However, the

time schedule expected for revising the PMS rules has slipped. Although the

M0&0 was approved by the Commission on January 25, 1979 (an Event II activity),

the revised draft rulemaking has not yet been scheduled for submission to the

Commission (an Event I activity.) The draft of revised 47 CFR rules and regulations is scheduled for release within 90 days of the Commission's approval
27 o

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28

of the M0&0. These rules are expected to deal with market entry and exit as

well as business operations while a firm is actually engaged in PMS commerce.

The Commission is expected to consider adopting a revised rulemaking after

an analysis of comments received during a public notification period.

Event IV involves carriers applying to the Commission to enter the PMS

market. Although carriers may apply as soon as the M0&0 is approved, interested firms are not expected to act until they have had an opportunity to

review the actual rulechange. Therefore, a more practical time for new entrants to begin to market public message services is probably March or April

1979, assuming that presentation of the draft rulechange before the Commission occurs in February. During Event V, staff of CCB, ETIP and the ETIP

contractor plan to monitor commerce as PMS services and operations change.

Events VI and VII involve continued observation of commerce, analysis

of evaluation findings, and transfer of knowledge gained from the evaluation.

Both of these events are already under way. They are portrayed as final

stages of the research since these types of activities will increase and

step into the forefront toward the end of the evaluation period. Also, in

actuality, products occurring at any time could be either subjects of analysis

or results of analysis by evaluators. Hopefully, these analysis and information transfer activities will be timely in terms of the information needs

of those expected to use evaluation findings and in relation to real world

events that might affect deregulation activities.

The hypothesized effects of the intervention would affect (1) Commission

process (for example, workload) and (2) the commercial sector and innovation.

In an initial attempt to set boundaries for this proposed evaluation, a

preliminary model for ongoing measurements and a preliminary measurement

set have been developed. The model is presented in Chapter VI of this
29

report and is illustrated with hypothetical examples, such as the way

one would track innovation in terminal equipment used for public message

services. Although measures outlined presently appear feasible at some

level of rigor, more work is needed to determine the degree of feasibility

and rigor possible.

As already noted, we expect to update the model as industry trends

develop and user needs are better defined. Specifically, we expect to

make revisions as the intervention becomes better defined and as we validate

the model and measures with industry and others. Events I through VI all

conclude by reassessing the potential for useful evaluation. This step

should insure that measures and comparisons assess agreed-upon goals, and

that activities achieve both interim and downstream objectives.

It is already apparent that more measurements could be taken than can

reasonably be accomplished, and priorities will have to be established in

this regard. Also, many potential users of the evaluation information

have been identified. (See Appendices E and F and Section D of this chapter.)

Chapter V of this report suggests that an Evaluation Group composed of staff

from the Commission, ETIP, and the ETIP contractor, could be organized to make

those decisions that will guide the conduct of the project. Also, evaluators

should soon finalize criteria for judging the significance of observed changes

in relation to the Commission's mandate and CCB and ETIP goals. For example,

for purposes of the evaluation, what yardstick of customer satisfaction should

be used to measure whether public service standards used by different carriers

are adequate? Decisions such as these require a broad consensus of opinion;

therefore, discussions should begin as soon as possible. (Description under

Event VI below includes an explanation of how the criteria might be applied.)
30

A Design Group of similar composition could also be formed to perform the

primary research tasks of collecting and analyzing data.

Each event is discussed briefly below. For a detailed description of

participants and activities, and potential products, measures, and information uses for all events, see the seven figures contained in Chapter V.

1. EVENT I—CCB DRAFTS M0&0 AND

RULEMAKING TO END PMS MONOPOLY

Event I produced a draft M0&0 intended to end the de_ jure monopoly

of Western Union. As mentioned, the revised PMS rules are not yet ready

for submission before the Commission. Other products completed during

Event I include: an early Urban Institute working paper, which contains

data gathered as of May 1978 regarding Common Carrier Bureau procedures;

and this report, a partial evaluation assessment of the proposed project.

Also during Event I, representatives of relevant CCB branches participated on a committee which conducted preliminary analysis of certain relevant sections of 47 CFR. This process helped to point out areas where

further legal research was required. Also early participation by each

branch which will be affected by the rulemaking should help to implement

a streamlined CCB process for administering those rules (Event III). In

other words, use of the CCB committee should facilitate a smooth transition from Commission policy intent to changed regulatory process as events

progress.

2. EVENT IT—COMMISSIONERS AUTHORIZE

REVISED RULEMAKING TO GO INTO EFFECT

As mentioned, the M0&0 was approved by the Commission on January 25,

1979. So far, no petitions contesting the decision have been received
31

by the Commission. If the deregulation is challenged now, or during the

public notice comment period for the proposed rulemaking, the evaluation

timetable could slip, perhaps considerably. For example, a telegraph workers

union might raise an objection to the deregulation which would necessitate

court action.

In addition to the final M0&0, Event II should produce the final rulemaking, a revised definition of public message services, comments from

industry regarding the new rules, and comments regarding this report.

3. EVENT III—COMMON CARRIER

BUREAU STREAMLINES PROCESS

The third event implements procedural change within those CCB divisions

and branches that will administer the revised rules and regulations governing

public message services. The process for implementing this streamlined

CCB process cannot be designed yet since the rulemaking is not finalized.

The central expectation of the event is characterized by faster processing

times for routine matters, fewer disputed regulatory rulings, and general

reductions in the workload associated with PMS regulation. On the practical

level, Event III activities should produce simpler formats for required

reports from PMS carriers, improved work checklists, and improved criteria

for branch-level decisions regarding applications, expedited CCB procedures,

etc.

Hopefully, the branches will begin to implement a revised PMS regulatory

process in March or April 1979. A set of measures to monitor this new

process will be developed.
32

4. EVENT IV—CARRIERS AND OTHERS

APPLY TO OFFER PMS SERVICES

This event may be the crucial phase of the transition from de_ jure

monopoly to competition. Different (non-Western Union) common carriers are

expected to apply to provide PMS and to offer new services based on innovative

technologies. Chapter IV discusses two likely entrants, and the kinds

of information that would be collected about entrants. We expect the data

on carriers entering the market to form the basis for establishing measures

of effects on market structure. These effects should be observable during

Event V. In another Event IV activity, ETIP and its contractor will gather

information about the actual process of PMS deregulation using measures set

up in Event III.

5. EVENT V—MARKET STRUCTURE

IS OBSERVED TO CHANGE

Event V could begin as early as May 1979. It is contingent on (1) the

rulechange being submitted before the Commission, and (2) the reactions

of carriers to the new rules. If new PMS facilities are established

by carriers, and innovative technologies and better services are introduced,

we expect that consumers will opt to buy public message services and that

their general sense of satisfaction will improve. Another possibility is

that consumers will reject new public message services. This result could

warrant investigation into reasons for rejection, such as inadequate consumer

education.

During Event V, ETIP and its contractor will trace the actual changes

in commerce that result from Event IV activities. In turn, the data generated through these activities will provide the basis for analysis.

Information obtained from CCB files and documents is expected to be supplemented by information from companies, consumers, equipment manufacturers,
33

etc. The Evaluation and Design Groups will probably exchange information

with members of industry and other interested parties. (For a review of

information sources available at CCB and elsewhere, see Appendix D and

Chapter IV.)

6. EVENT VI—FINDINGS OF

SYSTEMATIC EVALUATION

This event is expected to produce evaluation and research findings

related to changed regulatory process and commercial impacts, such as

technological innovation, resulting from the deregulation. During this

phase, ETIP and its contractor are also expected to apply evaluation criteria

for success to the data on the deregulation. The task is expected to

have three components. The first establishes whether a commercial effect

(or anticipated event) has occurred and whether it can be linked to the

deregulation. If the link is established, the second component compares

data gathered about the actual event with the hypothesized expectations

about the event. These hypothesized expectations are based on the criteria

for judging the significance of observed changes previously agreed upon

by ETIP, the ETIP contractor, and the Commission staff. The third component

is expected to establish whether information gained from the evaluation

will lend itself to generalization.

7. EVENT VII—KNOWLEDGE TRANSFER

The seventh event will be the transfer of knowledge gained through

systematic evaluation of the deregulation. The result, often termed feedback, is expected to be indicated by useful application of specific findings

from the evaluation and research described above. Reports resulting from

the evaluation are expected to cover topics such as impact of deregulation,
34

rulechange process, barriers to deregulation, and techniques and methods

for managing regulatory change. Event VII will end when the last evaluation

product has been completed as per the terms of the FCC/ETIP working agreement

D. POTENTIAL USERS AND USES OF

EVALUATION INFORMATION

As mentioned, there are numerous individuals and organizations who

might benefit from the research findings on the issues in this discussion

of public message services and other common carrier regulation. The direct

users, of course, are the sponsors of the project: ETIP and CCB staff.

In cooperation with officials at the Commission and the Department of

Commerce, they control the resources used to shape evaluation activities.

Another group of potential users is composed of those who actually

participate in public message services commerce and are subjects of the

evaluation (but who have no control over evaluation resources). These

include Western Union, resale common carriers, firms in the peripheral

equipment industry, and investors.

Other users are those who are involved in some aspect of telecommunications commerce but do not participate directly in public message services.

This group includes all those associated with the evaluation by virtue of

their willingness to act when presented with new information about the

effects of deregulation. Some potential users of information are government

agencies, such as the National Telecommunications and Information Administration and the Justice Department. Some groups are veterans in the ongoing

dialogue about telecommunications regulation. Among these are AT&T, RCA,

IT&T, and a host of less well known suppliers. Others, like the specialized
35

common carriers, are relatively new companies on the scene. Of course,

even a partial list is incomplete without labor and consumer groups.

We have identified in the course of this research numerous ways in

which measurement information might be used by sponsors and other classes

of users. For example, ETIP could use research findings to increase its

understanding of the relationship between regulation and technological

innovation and could make this information available to specified policy

makers. The Complaints and Service Standards Branch of the CCB might use

measurement information to help define public service standards. The National

Telecommunications and Information Administration might use results of

the deregulation evaluation to reformulate its policy on competition. (See

also Appendices E and F and Chapter VI.)

E. SUMMARY OF ASSESSMENT FOR USEFUL EVALUATION

The project does present several important opportunities for both the

Commission and ETIP, which were discussed earlier in this chapter. In

summary, these include:

• An opportunity to test the role of competition in a telecommunications market that has traditionally been considered a natural monopoly;

• An opportunity to gain knowledge regarding: (1) the effects of

regulation on technological innovation and (2) the complex of

outside factors which may facilitate or hinder introduction

of innovative services and technologies into the marketplace;

• An opportunity for the Commission to analyze and implement procedural changes, including a more purposeful data-gathering approach,

which might be transf errable to the process of deregulating

other monopoly markets and also more routine activities;

• An opportunity for the Commission to develop empirical standards

on which to base its decisions; and,
36

• An opportunity to test the possibility of generalizing from

information on technical, economic, and political core issues

present in the public message services deregulation to other

areas of inquiry. (The evaluation can also serve as a vehicle

for moving to broader sets of generic issues. As noted in

Chapter III, the Commission has before it several decisions

which will influence innovation.)

In addition, we believe that this evaluation (properly monitored and

analyzed) will be of great interest to the research community. The process

by which public message technologies and services enter the marketplace is

a case study which should prove valuable in formulating and examining existing

theories about innovation in telecommunications and in other industries as

well.

Given the relatively modest size of the present PMS market, an evaluation

process of the magnitude contemplated for this ETIP administrative experiment

is reasonable only if the project is expanded to encompass a larger segment

of telecommunications than a narrowly defined public message services market.

Such an expansion might occur in any of several ways.

One way the project might expand is related to formulating the definition of public message services. The M0&0 most likely refers to public

message services in a very general way in order to allow as much leeway as

possible for new, innovative types of services. The tightness of the PMS

definition will probably be determined after the public notice period for

the rulechange. After the final definition of the PMS market is issued,

it could affect the size of the project. A relatively broad definition

could result in large impacts; that is, many firms, offering a wide variety

of new services using different technologies, could decide to enter a broadly

defined PMS market to seek the advantages of deregulation. The project

could also be sequentially expanded by applying the information obtained
37

to pending decisions and/or by transferring the evaluation process itself

to other decisions.

Finally, following is a summary of concerns with which ETIP, its contractor, and the Commission will have to deal in the near future in order

to increase the potential for a useful evaluation effort.

• Public message services deregulation goals need to be more

precisely stated. For example, there is general agreement

that the regulations governing deregulated public message ser- vices should be fewer than regulations during the monopoly.

However, it is not yet clear whether the smallest possible

set of regulations is desirable or just a smaller set than

the previous one.

• The project needs better standards for performance. For

evaluation to show that competition exists, an acceptable indicator of the threshold between a monopoly and competitive state

is necessary. Is competition simply the presence of a minimum

number of companies in a specific market or is competition

achieved when each carrier gains a certain minimum percentage

of the market?

• A mechanism to transfer evaluation information to appropriate

CCB staff is needed in order to link findings about the process

and effect of public message services deregulation to other

areas of inquiry, such as Telex/TWX or MTS/WATS.

• A plan is needed to guide distribution of evaluation information

to the outside world.

• Measurement priorities must be established for sponsors of the

evaluation and those outside of the evaluation who might use evaluation findings. A full-scale evaluation design probably

will be based on the choices of ETIP and CCB staff who participate in decision making, and by findings of an analysis of early

"participant" reactions to the deregulation. Essentially, the

tradeoff will be between decisions about priority uses of information and the actual resources available for information collection.

• Since the events being monitored are not taking place in a con- trolled policy environment, they are subject to effects of outside

events, such as decisions by the Congress and the courts. Therefore,

a method is needed to track reaction to the deregulation and related

developments in other areas of regulated telecommunications. This

will insure that the deregulation is properly understood within the

context of the telecommunications industry and that expectations for use of evaluation information are reasonable.

39

III. FINDINGS ABOUT THE SETTING FOR THE EVALUATION

A. ORGANIZATION

Chapter III presents necessary findings and background information for

understanding the proposed public message services deregulation—and the

evaluation—in the context of the telecommunications industry. This information is presented to help relate the proposed deregulation to historical

and current events, assess the progress of our work, and suggest directions

for future evaluation efforts.

A brief review of telecommunications history from 1830 until 1943

begins this chapter. This review describes various observers' assessments

of conditions that contributed to the need for government regulation and

conferring monopoly power on AT&T and Western Union.

After some information needs which exist in the area of telecommunications regulation are examined, the circumstances which led to a renewal of

Commission decisions favoring competition are described. The process by

which the Commission tests decision making and policy formulation is illustrated by an examination of major recent decisions (such as the Specialized

Common Carrier and the Execunet Decisions )

.

For greater insight into industry conditions we shift the focus to current matters which probably require Commission attention. Some of these are:

electronic message service and the United States Postal Service; the AT&T

Domestic Satellite (Domsat) Moratorium; Xerox's proposed entry into telecommunications; and the Satellite Business Systems controversy.

1. The term deregulation is used here to denote a change in policy,

practice, and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
40

Next we briefly describe specialized common carriers and discuss the

promise of competition which they bring to the industry. The diversity of

these carriers and the complex competitive relationships in which they are

involved illustrate the difficulty of establishing standards for fair competition. A look at specialized common carrier intercorporate relationships,

investment patterns, and examples of industry links with government research

and development pinpoints areas for additional study by the Commission and

the academic community.

When current events are discussed, alternatives for future telecommunications (especially public message services) come more sharply into focus.

For example, will the message delivery vehicle be television set, facsimile,

computer terminal, or messenger? Will we transmit primarily by air, or by

wire? Will a government or quasi-government agency have jurisdiction over

the provision of public message services? Will the market sustain one,

a few, or many companies competing in an open marketplace? By monitoring

the proposed deregulation, empirical evidence may be obtained that is

pertinent to issues such as these.

The Commission inquiry process is a tool for communicating with industry

and other concerned parties. This process is described at the end of the

chapter. Issues in telecommunications are identified by content analyses

of public comments regarding inquiries that are directly or indirectly related

to the public message services deregulation, and of congressional testimony.

These issues are then linked to generic issues of regulation and innovation.

The opportunity for using the evaluation to test whether one can generalize

and apply the information obtained to other inquiries and broad issues is

discussed.

In summary, this chapter shows the complexity of the telecommunications

environment in which the deregulation is taking place. The FCC is only one
41

of a number of forces which influence telecommunications and innovation in

that industry. Other influences include court decisions and government

research and development, as well as changes initiated by the industry

itself. Thus, to properly interpret the deregulation and its effects on

innovation, it will be necessary in future work to conduct research into

a variety of areas, at both the theoretical and operational levels. For

example, theories given in various literatures (for example, on market

structure and innovation) and specific links to those literatures in terms

of measures need further examination. Also, the findings in this chapter,

for the most part, come from secondary sources (documents, literature, etc.)

and selected parts will be further validated by more direct contact with

industry.

In this chapter we try to show that the Commission can strengthen its

influence in encouraging commerce and innovation by adopting a more structured data gathering approach than it has used in the past. The evaluation,

properly conducted and linked to generic issues, could initiate such an

approach and also provide ETIP with information on the relationship between

regulatory process and technological innovation.

B. HISTORICAL PERSPECTIVE: THE ROAD TO REGULATION

1. PATENT PROTECTION AND INDEPENDENT

AGREEMENT BETWEEN POTENTIAL COMPETITORS ASSURE EACH A MARKET SHARE

The beginning of telecommunications dates back to the invention of the

telegraph by Samuel Morse in the late 1830s. At first, several small companies offered telegraph service to the public. From 1866 to 1876, through

a series of mergers, Western Union achieved a prominent position in the industry
42

and became the sole source provider in many locations. A technological

advance in 1876—the invention of the telephone—was an important event

that went unnoticed by most, including Western Union. When its business

communications customers opted to use telephone service rather than telegraph,

Western Union acknowledged telephony as a competitive alternative service.

In 1878, the Western Union Telegraph Company attempted to enter the telephone

business. Its monopoly protected by a federal patent, the Bell Company sued

Western Union; Western Union counter-sued. A settlement was reached in 1879:

Bell purchased Western Union's telephone equipment, paid Western

Union a small royalty, and convenanted not to enter the telegraph

business during the life of the disputed patents. In return, Western

Union agreed to stay out of telephony for the same period and drop

its patent suits. Thus, Western Union protected its monopoly status

in the telegraph sector, and AT&T no longer had to worry about

competition in the telephony field from a financially superior

rival. This private agreement laid the groundwork for an industry

structure [in which] Western Union is the telegraphy monopolist

and AT&T is the predominant telephony monopolist.

2. COMPETITION IN PROVISION OF TELEPHONE

SERVICE EXPERIENCES MARKET FAILURE

In 1893, federal protection of the Bell monopoly ended, and a 20-year

period of fierce competition began. Bell aggressively forced independent

telephone companies out of business, and in 1913 the Kingsbury Commitment

(an agreement between AT&T and the Justice Department) required Bell to

interconnect independent telephone company lines with its own and to refrain

from purchasing or acquiring control of telephone independents operating

in the same market as Bell subsidiaries. But the company was free to

purchase noncompeting independent telephone companies. Bell found numerous

opportunities to acquire companies in areas where Bell was not operating

1. U.S. Federal Communications Commission. "An Overview of the Domestic

Telecommunications Industry and the Commission" s Policies Concerning Terminal

Equipment and Private Line Services," (Undated) p. 4. (Hereafter known as "Domestic Telecommunications.")
43

but where competition among groups of other independent telephone companies

had led to unprofitable, duplicative telephone services —and subsequent

market failure. Through these acquisitions, Bell greatly increased its holdings

between 1913 and 1921.

The Kingsbury Commitment did not deter the growth of Bell. One noted

economist has suggested why attempts to influence market structure are

sometimes inadequate.

If patents are backed up by massive control of sources of materials

and power, . . . the conditions are present for a new product monopoly

that may outlast the original patents and be hard to convert to com- petition, especially when a legal system ... is geared to combat

identifiable monopolistic actions, rather than bring about or maintain

whatever conditions may be needed for effective competition ....

This would mean preventing the acquisition of sources of material

and power from going to such lengths that its natural and probable

effect would be to preclude the entry of competitors A

Also, this new, technology-oriented industry was in a developmental stage;

the potential effect of transmission network unification and geographic

expansion on market structure was probably not foreseen.

This market failure which compelled telephone independents to sell out

to Bell (and eventually to seek relief from the antitrust laws mandating

competition), was explained by the "natural monopoly" concept. Today, however,

economists cite difficulties inherent in identifying a true natural monopoly:

Traditional definitions of natural monopoly suggest that where one

firm can supply the market at a lower per-unit cost than two or more

firms, competition leads to the elimination of all firms but one

. . . . The problem of determining empirically whether a monopoly

is justified by cost conditions—whether a natural monopoly exists

is difficult; attempting to do so by inference from the actions and

cost data of a regulated utility is nearly impossible.

2

1. Clark, John Maurice. Competition As A Dynamic Process , The Brookings

Institute, Washington, D.C., November 1961, p. 210. (Specifically discusses

the aluminum industry and Section 7 of the Clayton Act dealing with mergers.)

2. Waverman, Leonard. "Regulation of Intercity Telecommunications,"

Promoting Competition in Regulated Markets (1975), pp. 203-204.
44

3. TELEPHONE INDEPENDENTS SEEK

LESSENING OF ANTITRUST LAWS

The plight of the independent telephone companies led to the Willis

Graham Act of 1921, which exempted telephone companies—but not telegraph

companies—from the restraints of antitrust acts once consolidation or

merger was approved by the Interstate Commerce Commission as being in

the "public interest." Formerly only the courts had this authority.

At that time, jurisdiction over the communications industry was split.

The Interstate Commerce Commission had authority over interstate rates

charged by "telegraph, telephone, and cable companies"; the Postmaster

General inspected telegraph operations. The first bill designed to end

this and give responsibility to one agency was introduced to Congress

in 1929. Consolidation was not achieved, however, until the 1930s. The

domestic marketplace was suffering from shrinking demand as a result of

the Depression, when President Roosevelt's New Deal Legislation proposed

creation of a Federal Communications Commission and the Communications

Act of 1934 was passed.

4. COMPETITIVE TELEGRAPH MARKET FAILS

Although passage of the Kingsbury Commitment and Willis Graham Act was

prompted by the struggle between independent telephone companies, telegraph

companies were encountering similar problems. In the 1920s Western Union's

1. The "public interest" concept was originally used to show the

advantages of competition in the transportation industry. See Loeb, Guy.

The Communications Act Policy Toward Competition: The Sound of One Hand

Clapping , Harvard University, Program on Information Resources Policy,

Working Paper W-77-1, March 1977. An early judicial decision ( Federal

Radio Commission v. Nelson Brothers Bond & Mortgage Company , 289 U.S. 266,

285 [1933]) in the telecommunications sector, however, set the precedent

that "monopoly was in the public interest unless proven otherwise, so that the role of competition was never really tested." Waverman, Leonard,

op. cit. , p. 202.
45

market share was again threatened by alternative services; namely, long

distance telephone service and Air Mail postal service. During the Depression, AT&T introduced TWX which "struck at the heart of Western Union's

market, the commercial record traffic market"; TWX was competing with

Western Union's Telex service. (Both services consist of interconnecting

teleprinters, equipment used in a printing telegraph system. There are

similarities to regular telephone service in that customers dial calls

from station to station, but communicate using teleprinter equipment rather

than telephones. See also Glossary.)

By 1943 only Western Union and one other company, Postal Telegraph, were

operating on a major scale. Some problems in the telegraph industry were

noted in an official Commission opinion and included paralleling of facilities, duplication of operations, and wasteful expenditures of resources

and manpower. Postal and Western Union were both in financial difficulties.

It seemed evident that telegraph competition had not produced a healthy

market. Consequently, telegraphy was classified as a natural monopoly,

and Western Union was officially designated the telegraph monopolist. .... telegraph service appears to fall within the field of

"natural monopolies" such as the telephone, power and gas distribution utilities, where it has actually been found by experience

that one company adequately regulated can be expected to render a superior service at lower cost than that provided by competing

companies .2

World War II was also a very important factor in convincing government

officials (the President of the United States and the Secretaries of War,

Navy, and Commerce) that, "unification of the domestic telegraph operations

of this country into a single company was in the general public interest

1. See "Domestic Telecommunications," op. cit

.

, p. 12.

2. Merger Case, 10 FCC 148, 162 (1943).
46

and essential to the effective prosecution" of the war. Thirteen

years passed before a significant challenge to this "natural monopoly"

was brought before the Commission.

In 1956 the Commission denied the request of Press Wireless, a carrier,

for authority to lease and operate temporary telegraph facilities for overseas

transmission of press reports about the Democratic National Convention. This

service would have competed with Western Union* s domestic transmission of

transoceanic messages. The Commission denied Press Wireless" request on the

grounds that competitors would "creamskim" or serve only the choicest customers

while leaving Western Union the responsibility of being "last resort" carrier.

It appears to us, that although Western Union is not entitled as a matter of law to the exclusive grant for pickup and delivery of

international traffic in the hinterland, the obligation it has to

provide such service at all times, whether traffic be light or heavy,

carries with it the privilege of continuing to provide service and

reap the revenues of a heavy traffic volume, unless it is demonstrated

that it is unable to do so in a manner which will serve the public

interest, or some other carrier will provide service which is so superior as to support a finding that a public interest would be

served by a grant of its application.

C. REGULATED TELECOMMUNICATIONS: PROPENSITY FOR CHANGE

As the influence of forces (technological, economic, competitive, political, etc.) which gave rise to and shaped early developments in the telecommunications industry declined, and as dependence on regulation increased,

dominant characteristics of market structure surfaced. Basically, two

established companies, AT&T and Western Union, served two discrete markets:

3 terminal equipment and private line.

1. Ibid . 2. Press Wireless , 21 FCC 331 (1956).

3. AT&T and Western Union tariffs define private line services as point-to-point, dedicated communications lines reserved for specific customers on a 24-hour-a-day , seven-day-a-week basis.
47

The industry structure which existed in the terminal equipment

and private line markets by the mid-1960s may have been appropriate

for that time. The basic, switched telephone network was used

almost exclusively for voice communications between individual

subscribers, and the only terminal used to any significant extent

was the ubiquitous, black dial telephone. Thus, the terminal

equipment market essentially consisted of a single product line,

and there probably was little incentive to attract new entrants

or little reason for the FCC to allow additional entrants in this

homogeneous market.

The private line market, while composed of four basic markets,

was—to a considerable extent—an equally homogeneous market. Telegraph grade private lines were principally used by the newspaper

wire services. Telephone grade private lines were used by broadcasters. Audio and video private lines were used by the television

networks. Each of these four submarkets constituted a single

product line for which each of the potential classes of users had

essentially the same communications requirements. Under such circumstances, it was not unreasonable to assume that Western Union

and AT&T would satisfy all the private line communications needs

of potential users.

According to some experts, the established carriers were not able to

adequately satisfy communications service demands produced by the technical

revolution of the 1960s. The Commission felt it was necessary to allow

new entrants into the private line and terminal equipment markets in order

2 . to satisfy these needs. During the same period of time, however, Bell

Labs produced major innovations that had important effects on the industry.

In his article entitled "0 Pioneers," Nathan Reingold discusses major

innovations in different industries and describes how the interest of

Bell Labs in basic research as opposed to applied research had a major

impact on both the electronics and telecommunications industries.

p. 19, and U.S. Federal Communications Commission, "Domestic Public Point-toPoint Microwave Radio Service—Specialized Common Carrier Services," Federal

Register 36, No. Ill, June 9, 1971.
48

In 1927 H.D. Arnold, then president of Bell Laboratories, wrote

[that Bell was interested] simply in producing more electrons to run its radios and telephones and, soon, its television sets. And

Bell wanted its electrons cheaply. But the best road to this end,

Arnold explained, "must include a thorough understanding of the

broad facts of electron emission." Work in this area won Bell

Laboratories physicist C.J. Davisson the Nobel Prize (1937). Bell

received another Nobel for developing the transistor (1956).

In this view, Bell Labs' interest in increasing cost effectiveness was probably

a major factor leading to an important innovation. Scholars have cited many

variables which influence the introduction of innovative technology into a

market, including: investments, research and development (R&D) funding,

resource allocation, marketing capability, customer attitudes, supply and

demand factors, patents, acquisitions and mergers, geographic location,

economies of scale, cross subsidization, corporate diversification, staff

expertise, potential and existing competition, inflation, employees and

unions, etc., as well as regulation. How these factors influence one another

2 is not well understood.

Why does an innovation occur? What conditions and/or type of market

structure would be optimal for encouraging innovation? Are large firms or

small firms more likely to produce an innovation? What is the nature of

innovation? These questions are currently being debated and studied. Nelson

and Winter, economists at Yale University, are pioneers in investigating

1. Reingold, Nathan. "0 Pioneers," The Wilson Quarterly , Summer 1978,

p. 63.

2. Nelson, Richard R. , and Winter, Sidney G. "In Search of Useful

Theory of Innovation," Research Policy 6 (1977), 36-76; Nelson and Winter.

"Neoclassical vs. Evolutionary Theories of Economic Growth," Economic Journal 84

(December 1974) 886; "Factor Price Changes, and Factor Substitution in an Evolutionary Model," Bell Journal of Economics 6 (Autumn 1975) 446; and

"Dynamic Competition and Technical Progress," Jji B. Balassa and R. Nelson

(eds.) Private Incentives, Social Values and Public Policy: Essays in Honor

of William Fellner (Amsterdam, North Holland, 1976). See also Section E of

this chapter regarding investment, R&D funding, and corporate strategy.
49

the applicability of dynamic theory to the study of innovation. They

suggest that:

[A]lmost any nontrivial change in product or process, if there

has been no prior experience, is an innovation. That is, we abandon the sharp distinction between moving along a production

function and shift to a new one that characterizes the studies

surveyed earlier .... we treat any innovation as involving

considerable uncertainty both before it is ready for introduction

to the economy, and even after it is introduced, and thus we view the innovation process as involving a continuing disequilibrium. At any time there is coexistence of ideas that will

evolve into successful innovations and those that will not, and

actual use of misjudged or obsolete technologies along with profitable ones. Over time selection operates on the existing set

of technologies, but new ones continually are introduced to upset

the movement toward equilibrium.!

Public message services deregulation could set the stage to test statements such as the one above and also offers an opportunity to learn what

factors influence innovation. For example, what will the mix of technologies

be after deregulation? Will state-of-the-art and obsolete technologies

be used together to provide PMS? Which technologies and services will be

most profitable? How will public message services technologies evolve over

time? A case study that examines the effects of deregulation and whether

a shift toward competition in PMS occurs—and why—should produce useful

information for both the Commission and academics interested in gaining

a better understanding about factors influencing an industry's propensity

for change. ETIP is especially interested in gaining information about

the relationship of regulation to innovation.

The next sections will provide background information on past Commission decisions and how they have affected the market structure of the telecommunications industry and the availability of innovative technology in

the marketplace.

1. Nelson and Winter, op. cit. , p. 48.
50

1. INFLUENCE OF THE REGULATOR

ON THE INDUSTRY

Recent major decisions made by the Commission have resulted in a significant restructuring the telecommunications industry. Each of these decisions

involved a great deal of time and effort for both Commission staff and members

of industry. At any given time, however, routine decisions and special decisions with "minor" consequences are made. Decisions that coincide with a shift

in policy may either advance or may not advance the new policy direction.

Each Commission decision, whether routine or special, is made on an

ad hoc basis, with special consideration to the merits of the particular set

of circumstances, rather than on a policy basis, with a one-dimensional, goaloriented approach. Implications of such an approach are discussed below.

In the marketplace, Commission policy formulation is experienced as a series

of inquiries and subsequent decisions (or rulemakings).

The inquiry process (described in Chapter IV) is meant to provide the

Commission with information on which to base its decisions and to gauge the

effects of policy change on market structure. The announcement of a formal

inquiry includes a request that parties with a stake in the Commission's

actions send in comments and evidence in support of their positions. The

legalistic, adversary relationship that exists under inquiry conditions

also imposes ex parte restrictions on direct contact between Commission

staff and industry. The type and quality of information on which Commission

decisions are based depends on what information each commenting party decides

to submit. Logically each commentor will base his decision on advice of

legal, technical, and corporate staffs and their unique expertise and interests. Under these conditions, assigning Commission staff to inquiries
51

according to their knowledge of the issue makes great sense, and this is

what the Commission does. But one weakness of the regulatory process is

that as in certain complex areas of research, there is no formal mechanism

to insure that "the whole adds up to more than the sum of the parts and

knowledge extends beyond the particulars."

2. REGULATORY DECISIONS FAVORING COMPETITION

In the 1950s, the Commission began to reexamine its policy favoring

monopoly. Technological advances, many of which occurred outside of the

traditional communications common carrier industry in the fields of data

2 processing and electronics, spurred this process.

The so-called "technical revolution" in the 1950s produced a plethora of demands for new, specialized, communication services

which were not generally available from the established carriers.

Because of this demand, and the emergence of new communications

firms who were willing and able to satisfy these specialized needs,

the FCC embarked on a new common carrier policy which has had,

and continues to have, tremendous impact on the structural development of the entire common-carrier industry. . . . For the most

part, the Commission has not adopted specific regulations to

implement this policy; instead it has authorized entry into the

particular markets through a series of rulemaking decisions based

on conclusions reached in inquiries initiated to determine whether

competition from new entrants would be a viable and valuable addition to the market.

Five Commission decisions will be discussed: (1) the Terminal Equipment

Decision (1956); (2) Microwave Common Carrier Decision (1959), (3) Specialized

Common Carrier Decision (1971); (4) the Value-added Carrier Decision (1973);

and (5) the Resale and Shared Use Decision (1976).

1. Nelson and Winter, op . cit . , p. 50.

2. Examples are the modern digital computer and the increased reliance

of computer systems on communications, (e.g., remote batch processing and

timesharing). Breakthroughs in electronics include the transistor, integrated

circuits, and the minicomputer. For detailed account of these and other

technological advances, see "Domestic Telecommunications," ^p_. cit . 3. U.S. Department of Commerce, Office of Telecommunications, Policy

Research Division: Federal Regulations Relevant to the Structural Development

of Telecommunications Industries, November 1977, p. 19.
52

a. FCC DECISION OPENS TERMINAL EQUIPMENT MARKET

Until 1956, telephone carrier tariffs prohibited connecting to the system

any device not provided by the telephone company. Complaints to the FCC,

first by a company called Hush-A-Phone and then by the Carterfone Company,

resulted in the Commission decision that not only AT&T's tariff, but all

tariffs which prohibit the "use of harmless as well as harmful devices"

interconnected with the communications system, are unlawful.

The terminal equipment question is still being investigated, but FCC

decisions have had an impact on the structure of the market. There are currently 300 companies which manufacture, supply, or vend "nontraditional"

communications terminals. These include "communicating typewriters, small

business computers, computer peripherals, computer terminals, facsimile

eqi

„3

2 equipment, answering devices, dictation equipment, and intercom equipment

used with the switched telephone network.

\ b. FCC APPROVES LICENSING OF PRIVATE

POINT-TO-POINT MICROWAVE COMMUNICATIONS SYSTEMS

The next example of the FCC's shift in the competitive/monopoly balance

is its decision regarding microwave common carriers.

And, early in 1945, the FCC in essence granted a monopoly of the

frequency spectrum usable for microwave transmission to common carriers. Subsequently, the FCC gave [AT&T] a virtual monopoly of the use of microwave by refusing to force AT&T to interconnect with

private systems and by not allowing [Western Union Telegraph Company]

to interconnect with Bell System Companies.

In later years, however, the FCC attempted to diminish the monopoly

it had itself granted. In 1959, noting the low rate of increase in

private microwave systems, the commission broadened the range of

1. FCC Decision, 1968b, pp. 424-425.

2. Equipment which provides transmission of pictures, maps, diagrams, etc.

The image is scanned at the transmitter, reconstructed at the receiving station,

and duplicated on some form of paper.

3. "Domestic Telecommunications," op_. cit . , p. 50.
53

industries in which individual firms could build their own systems,

and by 1965, few additional private systems having been constructed,

the number of industries that could acquire frequencies was again

enlarged, and, in addition, firms were allowed to share microwave

systems. After its 1969 decision authorizing a private-f or-hire

carrier between St. Louis and Chicago prompted 1,800 further applications for such service, the commission in 1972 announced its intention to allow competition in the provision of point-to-point intercity services. Thus in the space of about a quarter century the

FCC reversed its policy from one of granting a new monopoly on intercity communications to AT&T to one of allowing limited competition.

The commission gave the same reasons—efficiency and economy—for

allowing competition as for granting monopoly. The commission felt

in the mid-1940s that microwave communications was a natural monopoly;

yet by 1971 it felt that the natural monopoly had exhausted all

economies of scale.

c THE EMERGENCE OF THE SPECIALIZED COMMON CARRIERS (SCCs)

The technical revolution of the 1960s created a demand in the marketplace

for new private line services. Types of services that were not available

to communications users through the established carriers even as late as

1971 included: two-way transmission of different bandwidths; part-time

use; sharing of channels; and use of carrier's facilities for installation

2 3

of subscriber's private equipment. '

Applications from companies interested in entering the market typically

pointed out technological advances they could offer the public: channels could

be terminated into the full single bandwidth of the channel or into a number

of channels ; thousands of channel and termination combinations were possible

and feasible. A growing need for communications channels designed especially

for data transmission was also emphasized. A series of FCC decisions from

1. Waverman, Leonard, op_. cit . , pp. 202-203.

2. See , U.S. Federal Communications Commission. "Domestic Public Pointto-Point Microwave Radio Service—Specialized Common Carrier Services,"

Federal Register , Vol. 36, No. Ill, Part II, June 9, 1971.

3. See the glossary for definitions of specific terms such as bandwidths, channels, and facilities.
54

1971 to 1976 (including the Value-added Carrier and Resale and Shared Use Decisions) stimulated the introduction of innovative private line pricing systems

and services into the marketplace, to the advantage of the high-volume business

1 user of communications services.

d. THE VALUE-ADDED CARRIER DECISION

This decision, initiated by a petition from Packet Communications Inc. (PCI),

2 . . ...

permitted "value-added" carriers to tailor existing carrier facilities to

meet user needs:

The PCI Order recognized that the entry of value-added carriers

into the communications services market would affect the structure

of the communications industry. The Commission determined that

entry should, nevertheless, be permitted because it would introduce new and improved means for meeting consumers' data transmission requirements in a manner not available from any generalized

or specialized carriers.

3

e. THE RESALE AND SHARED USE DECISION

The Resale and Shared Use Decision made it possible "for user groups

to share services, and for for-profit companies to combine data processing

and communications to offer integrated, regulated services, by seeking waivers

of [a previous Commission] stipulation that there be maximum separation

4 of data processing and communications within the company."

1. For a complete description of these decisions, see "Domestic Telecommunications," op. cit . , pp. 73-104. See also , U.S. Federal Communications

Commission. "Domestic Public Point-to-Point Microwave Radio Service

Specialized Common Carrier Services," Federal Register , Vol. 36, No. Ill,

Part II, June 9, 1971.

2. Value-added, or resale, carriers lease channels from other carriers

and add to those channels the value of their own computers and software

in order to provide more efficient data transmission; i.e., permit computers

of incompatible speeds, codes, formats, etc., to communicate with one another,

3. "Domestic Telecommunications," op cit . , p 79.

4. Kalba, Konrad K., et_ jil_. Electronic Message Systems: The Technological, Market and Regulatory Prospects , Kalba Bowan Associates, Inc.,

April 1978, pp. 192-193.
55

3. REGULATORY DECISIONS BOLSTERING MONOPOLY

Although each of the above decisions represents a policy shift favoring

competition, other decisions have favored monopoly conditions. For example,

in 1971, the Commission approved Western Union's acquisition of AT&T's

TWX service.

Section 222 and its legislative history also indicate Congress' desire

that Western Union acquire TWX from AT&T. This was reemphasized by the

Senate Interstate and Foreign Commerce Committee in the "Tobey Report"

(Senate Document No. 53, 83rd Cong., 1st sess., June 22, 1953) on the

problems of domestic telegraph industry. Moreover, a 1966 FCC Investigation into Western Union's declining financial condition made a similar

recommendation. On January 15, 1969 AT&T finally agreed to sell TWX

to Western Union. The FCC authorized the purchase on July 28, 1970,

and the sale was completed on April 1, 1971.1

The same rationale, to protect the public interest and continued viability

of the marketplace, is the basis for all Commission decisions. This policy

"tug of war" may be inevitable in dealing with such complex situations. The

ways in which any particular Commission decision(s) will actually affect

market structure over time can never be known with certainty because all

the related interacting forces can never be perfectly understood.

Thus an airtight prescription which will protect the public interest

and the market for all time and in all situations may not be possible. If

an optimal market structure does exist, it certainly will not be discovered

without trial and error. However, if certain principles of interrelationships

in complex situations were established and if better information about specific

situations over time were available, decision makers might operate with more

certainty. This evaluation will try to determine whether this is true. The

Execunet decision, which follows, is an example of a decision which might have

been improved had such principles been established and better information been

available.

1. "Domestic Telecommunications," op. cit . , p. 13
56

The Execunet case (1976) concerned the application of MCI Telecommunications Corporation to offer a service which would compete with basic public

telephone service (MTS and WATS), rather than private line service.

In the Execunet decision, the Commission . . . reaffirmed its

decision to limit competition to private line service. In so doing, the Commission described private line service as a service

which (a) either originates or terminates communications at a specific location designated by the customer via an access channel

which is dedicated to the customer's private use and which, therefore, is not used as part of a service offering to the general

public; and (b) accesses only those distance locations . . . specifically designated ... to meet . . . private communications needs.

This decision preserved the long distance telephone service monopoly and

protected the stability of the nationwide rate averaging system which

subsidizes small "ma and pa" telephone companies in low-volume areas of

the country.

In mid-1978, the Court of Appeals overturned the Commission decision

regarding the Execunet service on the grounds that the Specialized Common

Carrier Decision (which allowed MCI entry into the private line market in the

first place) did not "explicitly and affirmatively" exclude this type of service

from the market. The Supreme Court refused the Commission's request that it

rehear the decision. The Commission objected to the lower court's decision

on the grounds that:

[T]he Commission has not yet made the important policy determinations

this decision presupposes, and because the decision ignores the

established principle that carriers have no obligations under common

law to interconnect their services or facilities .... [court]

panel's action also conflicts with settled Supreme Court precedent

establishing limitations on the power of reviewing courts in relation

to administrative agencies.

1. See Appendix B for background information and chronology of major

events in the Execunet controversy.

2. "Domestic Telecommunications," op. cit ., p. 101.

3. "Rehearing Ruling Awaited on FCC, AT&T and Execunet Appeals to Court,"

Telecommunications Reports , Vol. 44, No. 18, May 18, 1978, p. 18.
57

As the Execurie

t

case illustrates, so little is known and understood

about possible causal relationships in the marketplace that major decisions are

sometimes based primarily on legal precedents which are subject to interpretation from many different viewpoints. When legal boundaries are not

set by other factors, such as expert opinion based on empirical evidence,

the courts may question the decisions of the Commission. However, it may

be impossible for regulators to arrive at "firm policy determinations" until

situations demanding decision making arise. One solution to this difficult

problem might be a partnership of decision makers and academics who would

share information and analysis techniques.

The next sections will probe more deeply the current transition of the

telecommunications industry and the situations which now demand decision

making by the FCC. Although discussions will focus on AT&T, Western Union,

and the specialized carriers, we will also explore: influences from the

unregulated sector, potential areas of competition, and the implications of

technological innovation for new markets, especially public message services.

New technologies and those stakeholders who are potential providers of public

message services can also be identified as major forces that directly or

indirectly affect the telecommmunications industry. The contribution that

evaluation of the deregulation of Western Union's public message services

might make to understanding of the relationship among innovation, regulation,

and othtr forces will also be explored.
58

D. TELECOMMUNICATIONS IN TRANSITION: DYNAMICS OF CHANGE

FCC decisions allowing new entrants into the private line and terminal

equipment markets put pressure on the established carriers to update their

offerings. This section will attempt to review AT&T and Western Union

strategies to retain dominance and will identify current and potential

competitors. It will also discuss other important forces in telecommunications as well as the Commission inquiry process, which provides the agency

with a mechanism to communicate with industry.

1. AMERICAN TELEPHONE AND TELEGRAPH

a. POSSIBLE ADVANTAGE OVER LARGE AND SMALL

COMPETITORS —OWNERSHIP OF THE NETWORK

Since the Specialized Common Carrier Decision , AT&T has reestablished

itself as a supplier of the full range of private line offerings, including

data transmission. In fact, according to a special report in Business Week ,

AT&T is developing marketing expertise and gearing up for a competitive

marketplace. Its prime competitor may not be another communications firm, but

a giant of the data processing industry, International Business Machines

(IBM)

.

[deButts, ex-Chairman of AT&T] has set in motion a plan designed to

change Bell from a regulated telephone company into a fiercely competitive supplier of all forms of communications systems, including computerized services that bear little resemblance to what AT&T has traditionally represented. The new direction will take AT&T into certain battle

with the country's most technologically sophisticated and marketing-wise

company—International Business Machines Corp. And . . . the word

"telephone"—at least as we know the telephone today—will have about as much place in the company's name as the word "telegraph."

1. "Behind AT&T's Change At The Top, The Biggest Corporate Reorganization

in History Puts Ma Bell on a Collision Course with IBM," Business Week , November

6, 1978, p. 115.
59

Currently before the Commission is an application from AT&T to provide

an Advanced Communication Service (ACS). Resolution of this case will depend

on the outcome of the Commission's redefinitions of data processing and

communications services and on other factors such as the implications

of the 1956 Consent Decree agreement between AT&T and the Justice Department.

Currently, the Commission's maximum separation policy is in force. If a

service is essentially data processing, it is unregulated and a carrier must

offer it through a separate subsidiary. If it is communications, then the

data processing firm must offer it through a subsidiary tariffed as a common

carrier. However, modern communications requires some data processing functions; the Commission's objective seems to be to expand the opportunities

of its carriers without damaging the data processing industry through overregulation. The data processing capabilities of the planned ACS system warrant

describing this digital network "intelligent." What effect would this

have on the data processing industry and on the terminal equipment market?

How will ACS affect competition in the telecommunications marketplace since

its services are similar to those offered by the specialized carriers?

[On the basis of market] research, [AT&T has] determined that ACS

would find a user response in the data communications marketplace.

We find the connection of approximately 137,000 customer terminals

and computers to the ACS network by 1983 out of a total 3,600,000

terminals and computers estimated to then be in use.

. . . ACS provides a data communications solution for a number of

intercompany applications, including: (i) Order entry from a manufacturer or distributor to its suppliers; (ii) transmission and

control of freight shipment documents between shippers, freight

carriers, and consignees; (iii) reservations processing between

travel agents and airlines, car rental firms, and hotel and motel

companies; (iv) claims processing between medical centers or doctors'

offices and health insurance companies; and, (v) insurance policy

and claims processing between independent insurance agencies and

insurance companies.

1

1. "Data Communications Service of Far Wider Application Than Present

Offerings, Known as Advanced Communications Service, Outlined by AT&T in Petition to FCC for Declaratory Ruling Service Is Allowed," Telecommunications

Reports, Vol. 44, No. 28, July 17, 1978.
60

The following excerpt from the prospectus of Telenet Corporation, a specialized common carrier, expresses concern about another AT&T service

and its reliance on laws fostering competition:

AT&T has introduced a new communications processing service, Transaction Network Services (TNS), which is oriented toward the banking

and retail industries and is presently offered on an intrastate

basis in the states of Minnesota and Washington .... The company

understands that consideration is being given within AT&T to the

establishment of a new public data network which might offer communications processing capabilities similar in certain respects to

those offered by the Telenet network ....

AT&T has vastly greater resources than the Company, and the introduction of AT&T data communications services similar to those offered

by the Company could have an adverse effect .... The Company

is also dependent upon AT&T for the majority of its existing transmission lines; however, AT&T is required by the Communications

Act of 1934 and the antitrust laws to furnish rnisr such facilities to

all customers on a nondiscriminatory basis.

b. AT&T AND FIBER OPTICS

In Atlanta, Georgia, in 1976, AT&T installed the first Bell (and the

first domestic) experimental fiber optics system. There are currently

six common carrier-owned fiber optics systems in the United States—two

belonging to AT&T and five owned by cable television companies. There

are 56 operating systems worldwide. According to a recently established

newsletter, Fiber Optics and Communications , this figure represents an

increase of over 53 percent worldwide since February 1978. Market surveys

indicate that fiber optics will come into its own around 1982, when the

costs of interconnecting fiber optics equipment will be less. Applications

2 for this emerging transmission technology are numerous.

1. Prospectus submitted by Telenet Corporation to the Securities

Exchange Commission, December 21, 1977, pp. 21-22.

2. Neither Western Union nor any of the specialized common carriers,

to our knowledge, have yet experimented with fiber optical systems. For more information, see Fiber Optics and Communications Newsletter , published by

Information Gatekeepers Inc., Vol. 1, No. 7, August 1978.
61

c. AT&T AND TELETEXT -VIEWDATA SYSTEMS

Teletext-Viewdata systems, developed jointly by the British Post Office

(BPO), TV manufacturers, and the British Broadcasting Corporation, were

recently discussed at a National Academy of Sciences symposium which was

initiated by the National Research Council's Board of TelecommunicationsComputer Applications. One advantage of new services such as these would

be that greater use would be made of residential telephone lines, now used

only 20 minutes a day on the average in the United States.

On June 1, 1978, the new services went into operation experimentally

in Britain. The systems provide access to a computer-based information

system that uses an ordinary TV set as the display terminal and transmits

through the British telephone network. Users have access to information

supplied by more than a hundred information providers. Proponents say

that it will complement existing similar services rather than compete

with them. Systems such as these will probably provide an alternative

to mail service. They could handle mail orders, charity donations, and

travel arrangements. Some believe that this innovation may result in

a new industry: electronic publishing. If systems such as these are

successful in the long-run, home terminals might bring these services

directly to the public.

The success of the British system would have important implications

for the types of decisions made in the United States. However, many legal

and technical problems would have to be resolved. The question of standards

for example, was a focus of controversy at the symposium. Other areas

of concern included:

1. For a complete description, see : "Science in Europe/British May

Use Telephones, TV's, to Tap Data Bank," Science , Vol. 201, July 7, 1978,

pp. 33-34.
62

• need for digital switching to be implemented and paid for, probably

by the public;

• the impact on competition and current restrictions on resellers;

© the government's role in relation to systems that could add to

literacy and open the door to services such as electronic mail

and electronic funds transfer;

• current law which states that AT&T may not provide Viewdata

service when it provides the wire; and,

• current Commission computer rules which specify that if Viewdata is considered data processing, AT&T may not provide it even

though one benefit of Viewdata is increased use of telecommunications

facilities.^

In September 1978, the British Post Office announced that the Viewdata service would become available to users in the United States in 1979. This

announcement was the result of an agreement "in principal" on a U.S. license

for the service with Insac Data Systems Ltd., a firm set up by Great Britain's

National Enterprise Board to market British computer systems and software

overseas.

Under the agreement, Insac will open a viewdata service from a computer in the U.S. within six months of the start of a public Prestel

in the United Kingdom, planned for the first quarter of 1979. Insac

service will receive from the BPO exclusive rights to the use of viewdata computer programs and know-how in the U.S. and it will also have

full access to the results of the BPO's continuing research, development and operating experience ... .2

d. AT&T, XEROX AND IBM

On November 16, 1978, Xerox filed a petition with the Federal Communications Commission to enter the telecommunications industry through a subsidiary, Xerox Telecommunications Network. This situation potentially

1. See "Potential Impact of Computer Based Information Systems on Phone Plant Among Issues Explored at National Academy Viewdata-Teletext

Symposium," Telecommunications Reports , Vol. 44, No. 43, October 30, 1978,

pp. 32-33.

2. "BPO Announces Agreement to Make Viewdata Service Available in U.S.

Telecommunications Reports, Vol. 44, No. 36, September 11, 1978, p. 31.
63

involves a three-way competition between AT&T, Xerox, and IBM (depending

on forthcoming Commission decisions). Xerox plans to build and operate

a nationwide digital communications network and lease channels on common

carrier satellites such as RCA Corporation's Satcom or the Western Union

Corporation's Westar.

On the ground, Xerox's planned digital network could bypass AT&T's

network completely and might give resellers an additional alternative for

leasing transmission facilities. It might also provide alternate facilities

for systems such as Teletext-Viewdata. The implications for satellite competition are also complex.

(1) AT&T AND THE DOMSAT MORATORIUM: A three-year moratorium on AT&T's

provision of specialized private line services via satellite is coming to an

end. RCA American Communications and Western Union are petitioning the

Commission to extend the moratorium.

(2) AT&T AND SATELLITE BUSINESS SYSTEMS: In partnership, IBM, the

Communications Satellite Corporation (COMSAT), and Aetna Life and Casualty

Company, have parented Satellite Business Systems. The District Court of

Appeals recently overturned Satellite Business Systems' FCC authorization

to construct its system. The court based its decision on Section 11 of

the Clayton Act and indicated that, before granting any authorizations, the

Commission is required to hold a hearing on potential antitrust violations

which might result from the merger of IBM, Aetna and COMSAT. The case may

hinge on the Commission's decision on the importance of the satellite market;

in other words, how important is satellite telecommunications market in

relation to the telecommunications market as a whole? In the meantime,

Satellite Business Systems is reportedly continuing operations as scheduled.

1. For additional details, see "SBS And The Courts," EMMS , Vol. 2,

No. 18, September 15, 1978, pp. 7-9.
64

(3) SUMMARY: Xerox, IBM, and AT&T (like others in the industry) are

relying on some convergence of data processing and communications. For

example, besides the telecommunications subsidiary, Xerox can also call

on the talents of two other operations with which it has merged: Xerox

Business Systems (offering facsimile, word processing, and non-impact printer

1 services) and Xerox Computer Services.

The initial target market of Xerox, AT&T, and IBM telecommunications

services is commercial, but there are slight variations:

[SBS] seeks to provide a large-capacity, digital, intracompany

communications service for only the largest companies. . . . AT&T, on the other hand, through [ACS] is proposing a nationwide network to switch digital computer data between terminals

of different speeds and formats. The AT&T service would be

land-based, while the I.B.M. system would operate through

satellite directly to earth stations located on the customer's

premises.

. . . The [Xerox] system would speed up communication times

between long distance facsimile machines, computers, word

processing equipment, and distributed data processing networks.

. . . The service [according to a Xerox official] would make high

speed communication available to the small businessman, "the five

man law firm or the regional shopping chain". . . .*•

1. Xerox is calling the ultimate service for the business communications market the "office of the future." Xerox has been experimenting

with its Office Information Systems for some time and supposedly was to

install an "office of the future" information system at the White House.

However, due to technical problems, the Secret Service felt that the Xerox

system might camouflage eavesdropping taps. A solution to this service

problem would be fiber optics. It seems logical that Xerox would be investigating a conversion to this technology and onlookers are already

wondering about this possibility. For additional details, see "Fiber

Optics, Xerox, The Secret Service, and The Office of the Future," Fiber

Optics and Communications Newsletter , Vol. 1, No. 7, August 1978, p. 3.

2. Schuster, Peter J. "Xerox is Entering Telecommunications, Will

Challenge AT&T, IBM," New York Times , November 17, 1978. For more information

see , "Xerox Asks FCC to Allocate Super High Frequencies for Nationwide Digital

Broadband Network, to Provide New Common Carrier Electronic Message Service,"

Telecommunications Reports, Vol. 44, No. 46, November 20, 1978, pp. 1-4.
65

Although AT&T, SBS, and the Xerox systems are aimed at the commercial

markets, it is hoped that the benefits of these technological advances

will eventually be made available to the public.

2. WESTERN UNION TELEGRAPH COMPANY

a. RESPONSE TO A COMPETITIVE ENVIRONMENT

In spite of Section 222 and its monopoly status, Western Union has for

some time encountered competition from both the regulated and unregulated

sectors. As early as September 1973, a study of the domestic telegraph

industry was prepared for the Office of Telecommunications Policy (now NTIA)

.

The study attempted to identify public message services users and any available service alternatives. Among alternatives, the report listed telephone,

teleprinter, public mail, and local messenger services; private network

ownership (for large-volume users); Bankwire, American Express, and the

2

1. The Western Union Telegraph Company is controlled by the Western

Union Corporation (Delaware) which, as holding company controls 92 percent

of the Company's stock. In addition, Western Union Corporation administers

the following subsidiaries:

• The Western Union Telegraph Company

• PR Newswire Association, Inc.

t Western Union Realty Corporation

• Western Union Data Services Co., Inc.

• Western Union Overseas, N.V.

• Western Union Teleprocessing, Inc.

• Distronics Corporation

• Western Union Computer Utilities, Inc.

• Western Union of Hawaii, Inc.

• National Sharedata Corporation " • Telstat Systems, Inc.

• CPI Microwave, Inc.

• Western Union Electronic Mail, Inc.

• Western Union Space Communications, Inc.

2. The Office of Telecommunications Policy, formerly located in the

White House, is now located within the Department of Commerce and is known as the National Telecommunications and Information Administration.
66

Postal Service (for money order service); leased lines, teleprinter, and

public message telephone service (for press messages).

It may suffice, however, to indicate that many kinds of substitutes

are technologically possible and probably economically feasible. The

public has often been compelled to change its habits with the obsolescence or unavailability of a commodity or a service: the municipal

streetcar. . . the family doctor who no longer makes housecalls, etc.

If there were no technology available to compete with the telegram,

the problem would take on a different perspective. But the service is

heading toward its own demise. During the time period when virtually

all communications services have experienced vast service expansion

(1942-1972), PMS traffic has dropped 90 percent .... Obviously,

communications users, whose numbers have not declined, have successfully

sought and achieved workable service alternatives. Outdated regulatory

constraints will continue to deter further substitutes. To continue

this situation any longer is to . . . deny the public adequate public

message service.

Also in the 1970s, specialized common carriers were emerging as a result

of the 1971 decision to open competition in nontraditional telecommunications

fields such as data communications. The specialized common carriers currently

offer services (such as facsimile service) which can be converted to public

message services. Some experts believe that the FCC Resale and Shared Use

Decision may be especially important in opening the public message services

market to competition.

. . . . today's telegraph service is essentially a value added

communications service which could be offered by competing resale

suppliers. The public message service is an offering of service

rather than an offering of facilities or hardware. This service is

provided by adding value or augmenting basic transmission capacity

generally obtained from the telephone company ....

1. Gabel, Richard and Karydes, Marianne. Policy Research Estimate

prepared for the Office of Telecommunications Policy , September 1973, pp. 33-

34. See also , the Appendix, pp. 45-51, which presents specifically value-added

alternative services.
67

Value added services using computerized message switching, multiplexing, 1 message storage and retrieval are not characterized by

pervasive economies of scale ... .2

Evidence suggests that Western Union would be receptive to leasing its

transmission lines to resale carriers. As public message services volume

declined, the Company explored new sources of revenue. One was leased transmission line service. Also, the company has an extensive investment in a

computerized message switching system (introduced in the 1960s) and, even today,

the system is not being used for the variety of applications and services

originally expected. However, it is interesting to note that a steady

decline in number of Western Union telegraph offices and agencies stopped

in 1976. See Figure III-l. Upcoming Commission decisions will probably

have a significant effect on Western Union's future service offerings.

As this paper hopes to show, traditional telegraphy (and perhaps traditional telephony as well) has been supplanted by new technologies and alternative services. We still do no know whether the public—business and

residential —will be better served by one, a few, or many telecommunications

firms or what characteristics the service(s) will have. We hope to learn

during this project whether the public message services market can be revived and why or why not

.

The rest of this section will discuss Western Union's operation and

current interest in electronic message service.

1. Message switching is a technique that involves receiving a message,

storing it until the proper outgoing circuit or station is available, and

then retransmitting it to its destination. Multiplexing means dividing

a transmission facility into two or more channels—a channel being a path

for electrical transmission between two or more points. See also Glossary.

2. National Telecommunications and Information Administration, U.S. Department of Commerce. "Comments before the Federal Communications Commission

In the Matter of Regulatory Policies Concerning the Provision of Domestic

Public Message Services by Entities Other than the Western Union Telegraph

Company and Proposed Amendments to Parts 63 and 64 of the Commission Rules,"

Common Carrier Docket No. 78-96, June 22, 1978, pp. 16-17, p. 31.
68

e

30,000- .

25,000--

20,000--

5 15.000--

10,000--

5,000

1944 1945 1947 1949 1951 1953 1955 1957 1959 1961 1963 1965 1967 1969 1971 1973 1975 1977 YEARS

Source: FCC. Statistics of Common Carriers (computer printouts), 1977.

FIGURE III-l: WESTERN UNION TELEGRAPH—ALL OFFICES AND AGENCIES (1944-1977)

b. THE INFOMASTER SYSTEM:

During the 1960s, Western Union consolidated and modernized key elements of its service operation. The company introduced: (1) Infomaster, a

central computer switching facility (which made it competitive with other

electronic message services); and (2) three Central Telephone Bureaus which

provide access to PMS and other services through IN-WATS telephone lines.

It also consolidated .and closed many offices and agencies. Commission
69

authorization was granted for each of these moves. Western Union attributes

$212 million of its development cost to public message services-related

improvements. A recent New York Times article succinctly described the

changing nature of Western Union's public message telegraph service:

"The public decided the telegram issue for us," said Mr. McFall [Chair- man of Western Union]. . . "Volume just declined steadily. We modernized

offices—didn't make any difference. We cut the price 25 percent—no improvement, we advertised in 13 cities and didn't generate a single

telegram."

The fact that Western Union cut back on its offices across the nation

and replaced them with part-time "agents" such as florist shops, grocers

and others sharply reduced company overhead—and, critics say, cut

service.

Customers complain about the service .... A woman in New Milford,

Conn., wondered why a money order that she sent never reached her son

in Oro Station, Canada. If the sending clerk had checked before

dispatching the money order, he would have discovered that there was

no office anywhere near Oro Station. A message cancelling the money

order was returned to the woman—four months later.

The article continues with a discussion of the evolution of telegraphy

service from a labor-intensive to a capital-intensive market.

To replace the thousands of personnel who once punched out

messages from store-front offices across the nation, Western Union

now relies on three centers where operators take messages on a tollfree number on the telephone. The messages are punched directly

into a computer [Infomaster] in rural Virginia, near Washington.

The computer relays the message to local offices or—much more

likely to local post offices, where letter carriers deliver them

the next day as Mailgrams ....

The computer center, which has an identical back-up system near St.

Louis is a technological marvel, and is thought to be the largest

electronic switchboard in civilian use. It receives all of Western

Union's traffic, including telegrams, messages across the TWX and

Telex leased network, and even incoming international data from

Western Union International, a separate and independent company. . . .

1. Holsendolph, Ernest. "Western Union's Monopoly Challenged; Western

New York Times, March 19, 1978.
70

The company, which has already spent $1 billion on expansion, is

thinking ahead ... to the day when satellite communications will

be received by individuals in 15-foot or smaller [microwave] dishes on rooftops ... .1

In the meantime, electronic data technology and telephone lines have become

primary alternatives to traditional public message telegraph service.

c. WESTERN UNION AND THE UNITED

STATES POSTAL SERVICE (USPS)

In 1970, the Commission authorized a joint Western Union/USPS offering,

the Mailgram. Mailgram is somewhat slower and less expensive than other

public message services; customers 1 messages are transmitted via Western

Union facilities to a post office for inclusion as preferential mail in

the next day's postal delivery. The USPS is expanding the Mailgram concept

by introducing an Electronic Computer-Originated Mail service (ECOM) , which

is raising many questions in the areas of communications regulation, data

processing, and postal regulation. Like telegram service, mail service,

which was originally labor intensive, now also finds itself competing with

capital-intensive, declining-cost, telecommunications services.

On September 7, 1978, the U.S. Postal Service Board of Governors approved

a new electronic mail service and submitted it to the independent Postal Rate

Commission as a new subclass of First Class Mail.

The USPS and Western Union Telegraph Co. have signed a contract,

covering a 15-month preliminary phase and including an option for

the Postal Service to continue for an additional three years of

operation, for provision of the electronic computer originated mail

(ECOM) service, which, it was said, could begin as early as Dec. 15.

Selected mailers with the necessary computer capability and sufficient

volume would be able to transmit messages electronically to 25 specifically equipped "serving post offices" [SPOs] around the country.

At these locations, the messages would be electronically printed,

mechanically enveloped, and then processed through the normal mail

1. Holsendolph, Ernest, op. cit.
71

stream. ECOM messages would receive two-day delivery anywhere in

the country, and would cost between 30 and 55 cents per message,

depending upon the customer's volume.

Under this agreement, Western Union would provide the switching

and transmission capability [via Infomaster] for the new service,

while the USPS would have responsibility for marketing and message

delivery. *

Within the same month, Western Union wrote a letter to the Commission,

stressing that, in connection with its planned provision of transmission service

for ECOM, the company would not be engaged as a common carrier for hire.

Western Union pointed out that the Commission's rules contemplate non- common carrier activities by common carriers, and the FCC has determined

that the transfer of flowers, candy and gifts is not a communications

service. Since mail, like flowers, candy, and gifts, is not subject to

the Commission's jurisdiction, its handling on behalf of the Postal

Service should not be regarded as a common carrier service.

2

The Commission has subsequently ruled that Western Union must submit a tariff

on the ECOM service. On January 25, 1979, the Commission voted to hold a formal

inquiry regarding the ECOM question.

(1) IMPLICATIONS OF ECOM: EMMS , a newsletter published by International

Resources Development, Inc., recently printed an article analyzing the long3

and short-term implications of the ECOM system. The article raised the

following questions:

• How will ECOM affect Mailgram? (Its growth is expected to slow

by 15 percent during the next five years.) Will ECOM reduce the

value of other high priority message services such as Datagram

and Faxgram?

1. "Electronic Mail Service for High Volume Users, Expected to be Ready

by Dec. 15, announced by USPS; Western Union to Provide Transmission." Telecommunications Reports , Vol. 44, No. 36, September 11, 1978, p. 14.

2. "In Letter of FCC, WU Says Its ECOM Activity Will Not Be Common

Carriage." Telecommunications Reports , Vol. 44, No. 38, September 25, 1978,

p. 15.

3. For details, see, "USPS Announced Electronic Mail Service: Crosses

Regulatory Rubicon," EMMS, Vol. 2, No. 18, September 15, 1978, pp. 4-6.
72

• Does ECOM make the USPS a common carrier subject to Commission

regulation? Is the USPS acting like a resale or value-added

common carrier?

• Does ECOM qualify USPS as a computer service bureau? How will

the data processing industry react to a possible intrusion by

the USPS?

• If USPS moves further into electronic mail, it could offer bill

consolidation services and develop a data base on financial transactions for almost every citizen in the United States. How will this

affect privacy issues? Will companies and the general public want

to use the USPS in this capacity?

• Will the presence of the USPS inhibit smaller companies from

entering the electronic message services field?

(2) ECOM AND FACSIMILE: Advanced facsimile networks are already on

the market and there is an interest at the international level in compatible fax machines. The latest research in facsimile technology is being

devoted to fully integrated facsimile and message switching systems. David

Mack, manager of Network Marketing for a firm called Rapicom, believes that

Message Switchable Fax will become:

[A] key component of future electronic mail systems and, in some

cases, the only component.

This belief is based on the advantages of facsimile in general

[and the fact that] the advantages that used to apply only to TWX/

Telex and other keyboard systems . . . are available to the facsimile

user.l

This facsimile network option is in the first stages. A separate keyboard

and other peripheral devices are still necessary for proper entry into a

message switching network. Success in marketing and creating demand for

this facsimile option will undoubtedly be an important factor in whether

1. "Rapicom and the New Facsimile Era," EMMS , Vol. 2, No. 18, September

15, 1978, pp. 9-10. See also , "The Facsimile Market Verges On A New Era,"

EMMS, Vol. 2, No. 16, August 15, 1978.
73

this innovation is pursued. Primary stakeholders in the manufacture of

facsimile equipment include, besides Rapicom: Graphic Sciences, Inc.,

Qwip, Xerox, and 3M.

(3) ECOM AND CONGRESS: A Senate Government Affairs Committee Report

said that the USPS "immediately should pursue opportunities to provide services

which utilize existing electronic communications with the unique collection

and delivery systems of the Postal Service," and "for the future, the Postal

Service should determine within the next two years whether the communications

needs of the American public require electronic collection, transmission

and delivery."

The Commerce, Science and Transportation Committee emphasized that:

"the most persuasive case for Postal Service involvement in

electronics will be made where it can be shown that services can

be made available to the public by the Postal Service which

would not be made available by the private sector" .... The

committee said it expects USPS to "look beyond the types of

services it may be able to provide to such additional matters

as how to structure its procurement practices to have the least

disruptive effect upon the competitive market. "2

3. THE SPECIALIZED COMMON CARRIERS

Expert Commission staff believe that once the regulatory restrictions on

public message services competition are lifted, challengers to Western Union's

dominance in this market may come from the specialized common carriers. A

review of specialized common carrier tariffs verified that this group has the

transmission capabilities, and some of them (e.g., Graphnet, MCI, and Southern

Pacific Communications Corporation) already offer services which are convertible

1. "Bill Limiting Electronic Postal Service Awaits Turn On Floor

Of Senate": Telecommunications Reports , Vol. 44, No. 38, September 15,

1978, p. 13.

2. Ibid.
74

to PMS (namely, facsimile services) on a subscriber basis. Specialized

common carrier offerings are generally described as intercity communications

channels of various types, bandwidths, and data speeds designed to provide

transmission of voice, data, and/or facsimile, and other special-type,

dedicated services. A simple way to categorize these carriers, and the

one used by the Commission, is:

• The Specialized Satellite Common Carriers — American Satellite Corporation (ASC) — Satellite Business Systems, Inc. (SBS) — Southern Satellite Corporation — RCA American Communications (RCA Americom)

• The Specialized Microwave Common Carriers — Goeken Communications, Incorporated — ITT-United States Transmission Systems (USTS) — MCI Telecommunications — Southern Pacific Communications Company (SPCC) — Transportation Microwave, Inc. — Western Telecommunications, Inc.

• The Specialized Value-Added or Resale Common Carriers — ITT-Corporate Communications Systems (CCS) — Graphnet Systems — Telenet Corporation — Tymnet

This classification system is based on primary transmission mode. For

example, although a satellite carrier may have access to microwave and

other types of transmission facilities, its main transmission mode is

satellite.

The discussion of the specialized carriers will concentrate on two

aspects of their operations: (1) their diversity, and, (2) their complex

competitor relationships.

a. DIVERSITY

As their name implies, the specialized common carriers are different

from the traditional common carriers and even different from one another.

For example, Southern Pacific Communications Corporation is nationwide;
75

Goeken Communications' services are offered only in the Chicago, Illinois,

and Milwaukee, Wisconsin, areas. Southern Pacific constructs its own transmission channels; Telenet prefers to concentrate on development of specialized

microcomputer-based systems called "Telenet Processors," which are used as

network access concentrators. Southern Pacific offers a wide range of

specialized services; Telenet and Tymnet offer only data tansmission services; Graphnet offers only facsimile. We do not presently know a great

deal about the financial conditions of these companies. Some are suspected

to be operating at a loss; however, only one specialized carrier to date

has gone bankrupt.

The diversity of these carriers illustrates a major problem facing the

Commission: how to establish fair standards for competition. When diverse

carriers serve overlapping markets, the possibility of establishing standards that all carriers will perceive as fair is probably small. However,

in encouraging a competitive environment, the Commission will certainly aid

AT&T and Western Union, and all carriers under its license, regardless of

characteristics

.

b. A WEB OF COMPETITORS

As we stated above, the specialized common carriers are diverse. Common

carriers, including the specialized ones, do not necessarily compete only

with carriers of similar size and resources. A common carrier identifies

its competitors in terms of service capabilities or markets, and common

accessibility to geographic locations via a network. The following excerpt

1. Concentrators improve efficiency of data or voice transmission by

allowing terminals or lines to compete for and share transmission channels,
76

from a prospectus of the Telenet Corporation describes its immediate and

potential competition and illustrates the complex competitive relationships

which can exist.

Only one firm, a wholly-owned subsidiary of Tymshare Inc. [Tymnet],

presently provides data communications network service in direct

competition with the Company .... However, two other firms have

received FCC authorization to establish and operate public packet

switching networks [Graphnet and another subsidiary of ITT which

is not included in the list of specialized carriers since it does

not yet have a tariff on file] , in both cases to furnish data and

message communication services. ... In addition, it is possible

that one or more firms operating large private data communication

networks, such as General Electric Company, Information Services

Division or other time-sharing computer service companies, may seek

FCC authority to provide communication services on a value-added

carrier basis.

2 The Company also competes with private-line and circuit switched

data transmission services offered by telephone and telegraph companies,

specialized microwave common carriers and domestic satellite carriers. .... A variety of traditional and new circuit switched common

carrier services is also available to . . . users. Traditional

offerings . . . include regular long-distance telephone services

and Wide Area Telecommunications Service (WATS), furnished by the

telephone companies, and the telex and TWX services furnished by

the Western Union Telegraph Company. New circuit switched service

offerings specifically designed for data transmission include the

Datadial service of Southern Pacific Communications Company and [AT&T's]

Dataphone Switched Digital Service .... Although capable of higher

speed operation, the Telenet network is today used predominantly

for low-speed data transmission (1,200 bits per second and below).

To the extent that the Company becomes more active in the high-speed

marketplace it will be in direct competition with these new circuit

switched services. . . .

1. "A packet switching network operates by converting data from customer

terminals and computers into short blocks called packets for transmission through

a network. The packets are rapidly stored and forwarded from one switching center

to another." Prospectus of Telenet Corporation dated December 21, 1977, p. 16.

2. A switched network in which switching is accomplished by disconnecting

and reconnecting circuits in different configurations in order to set up a continuous pathway between the sender and the receiver.
77

The Company's planned deferred-delivery message switching service, which

is the subject of a pending FCC application . . . will compete with un- regulated private message-switching systems, some of which utilize the

Telenet network for transmission. Other competitive alternatives to the

Company's planned message service include such public services as telephone, telex, TWX, telegram and mail service.!

E. INVESTMENT, R&D FUNDING, AND CORPORATE STRATEGY

In studying how technological innovation is introduced into the telecommunications marketplace we might address many issues that, at first, may

not seem to be related to technology. Among these are investment patterns,

research and development funding, and corporate decision making, as well

as the effects of government regulation. Some academics now believe that

technological innovation is primarily a function of economics, and that

factors such as economies of scale and cost and demand factors play the

major roles. Others believe that factors such as key individuals are more

crucial. Before deciding whether to—or even how to—conduct research and

development which might lead to innovation, the controlling executives

of a firm might examine political climate, regulatory control, ease of

funding, advantageous intercorporate agreements, level of risk, potential

competition, etc. All these factors can affect innovation and/or the market

structure of an industry. The first early agreement between AT&T and Western

Union laid the groundwork for a subsequent monopoly market structure which

was also encouraged by other economic, political, and technological factors.

Although these influences on market structure and on the introduction of

technological innovation into a market have existed since the beginning of

1. Telenet Corporation. Prospectus submitted to the Securities

Exchange Commission, December 21, 1977, pp. 21-22.
78

telecommunications, we do not know much more today than we did in the past

about the relationships of these influences.

In this section, we will take a brief look at the ownership and investment patterns of some specialized common carriers and the possibility of

transferring ideas and money from the public to the private sectors. These

situations illustrate this complex environment, which cannot be directly

controlled by the regulator. Decisions made by the major "actors" in this

environment also affect market structure and innovation. We will present some

examples of technology transfer and also an example of a decision made outside

of the Commission that might affect PMS.

Information presented in this section has been gathered from tariff

filings, prospectuses, promotional materials such as press releases, Department of Commerce library materials, or telephone conversations with stockbrokers and carrier employees, and it will require further verification by

industry. So far, the work represents a small initial effort. As mentioned at the beginning of this chapter, further examination of theories in

various literature is needed. Measurement links to the literature are also

needed

.

1. This sort of transfer is not limited to the specialized carriers.

The established carriers may have as much or more direct contact with government research. For example, Western Union does very little independent

research and development. But, Western Union Space Communications has

contracted with NASA to construct components for NASA's tracking and data

relay satellite system, and those components may be used by the advanced Westar

system for commercial purposes. See, "Western Union Spacecom Asks Continued

Waiver for TDRSS/AW Construction," Telecommunications Reports , Volume 44,

No. 28, July 17, 1978, p. 17.
79

1. AN EXAMPLE INVOLVING OWNERSHIP AND

INVESTMENT PATTERNS OF THE SPECIALIZED

COMMON CARRIERS AND AN EXAMPLE OF

TRANSFER OF TECHNOLOGICAL INNOVATION

As mentioned, Telenet Corporation faces a great deal of competition.

Larger companies, such as AT&T, are beginning to introduce services that

might be described as imitating the data communications services which

are now offered only by Telenet and one other specialized carrier. Telenet's

chances of surviving in a competitive market with AT&T, Western Union, and

larger specialized common carriers, as well as the international carriers

(Telenet operates in 22 foreign countries) seemed small. However, on December 12, 1978, General Telephone and Electronics (GTE), the nation's largest

independent telephone company, announced its intention to purchase Telenet for

four times the small firm's asset value. This move indicated their belief

in the continued viability of Telenet's packet switching technology. A review

of investment patterns prior to this announced sale shows that, although

Telenet operated at a loss, securities brokers and underwriters continued to

invest heavily in the firm. (See Figure III-2.)

The takeover by GTE also poses some interesting and unusual regulatory issues because of the size of the companies involved and their diverse

characteristics. Telenet can be fully competitive with the larger carriers

if it is able to call on the resources of GTE. Previously the Commission has

been less stringent in its regulation of specialized carriers such as Telenet

than in its regulation of larger carriers such as AT&T and Western Union. For

example, the Commission rules require very specific cost support documentation

from AT&T, but allow reviewers to use their discretion in judging the adequacy

of cost support supplied by other carriers. The Commission is presently

reviewing its regulatory requirements in this area.
80

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Figure III-2 illustrates ownership and sources of funding from stock

sale for twelve specialized common carriers. The figure shows that the SCC

parent companies are both regulated and unregulated and include some large

companies such as Fairchild Industries and IT&T. Parent companies have varying

degrees of control over their subsidiaries. It is possible for decisions

which may affect the carrier's actions in the marketplace to occur outside

of the carriers' s own management. Parent companies also represent other

industries: data processing, transportation, insurance, investments, and

banking. Both IT&T and Fairchild Industries, of course, are well-known

conglomerates involved in both regulated and unregulated businesses. IT&T

is active in insurance, publishing, and the hotel industry; Fairchild, in

manufacturing, space electronics, and military and commercial aircraft

production.

Also, when an investment firm has a certain amount of stock in a company,

it can place one of its members on the company's board of directors. For

example, Allen & Company, a large, high-risk venture firm, has a member on

MCI ' s board of directors. The same underwriters can also own stock in competing companies. How are decisions made under these circumstances? Can

withdrawal of support affect a company's survival?

Telenet Corporation was primarily responsible for the introducting packet

switching commercially in 1975. This firm presents an interesting example of

technology transfer. Telenet Corporation's stock is sold directly on the

market because its parent companies are investment firms. Starting with

Telenet, we can trace relationships involving many diverse companies:

• Telenet has 82 underwriters. One is Allen & Company.

• Allen & Company also underwrites Graphic Scanning and MCI.
82

• Directors on the board of MCI include a member of Allen &

Company and one director who (according to a 1978 edition of

Standard and Poor ) is or was a director of Xerox, IBM, and

RCA.

• The founder of MCI is John Goeken, head of Goeken Communications, who still owns stock, but is not involved in MCI decision

making.

Packet switching was developed by the Advanced Research Projects Agency

(Arpanet) of the Department of Defense in cooperation with a high-risk

research and development firm, Bolt, Beranek and Newman Inc. (BBN), one of

Telenet's parent companies. What other factors convinced Arpanet, BBN, and

perhaps others to develop packet switching? Was easy transfer to the private

sector taken into consideration?

Matters such as those described above are not under the control of

the regulator. How important are they? How can the regulating agency

monitor the effects of outside forces, in order to better predict industry

trends? Do these outside forces affect the Commission's ability to fulfill

its responsibilities as outlined by the mandate of the Communications Act of

1934? Questions such as these illustrate the problems facing the Commission

in further developing and defining the rationale, scope, and practice of

regulation in this area.

2. SOME EXAMPLES OF TYPES OF

INFLUENCES ON INNOVATION IN

TELECOMMUNICATIONS

The preceding section described a technology transfer from the Department

of Defense to the telecommunications industry. The Advanced Research Project

Agency presents one example of how some government programs can influence

innovation.
83

Besides packet switching, another interest of this agency was to sponsor

development of an electronic mail system by BBN, the Hermes message system.

This system was an outgrowth of the Data-Based Message Service (DMS) developed

for the Advanced Research Projects Agency by M.I.T., the University of Southern

California Information Sciences Institute, and BBN.

Interestingly many veterans of Advanced Research Projects Agency work are

also involved in the Personal Computer Network (PCNET) project, which is

composed of computer hobbyists in Palo Alto. This group is designing a system

which would allow hobbyists' computers to be interconnected over ordinary

telephone lines for messages, data processing, or file transfers.

The importance of these hobbyist activities should not be underestimated. First, they are a means of quickly introducing a large

number of people to the possibilities of [electronic message systems]. Second, the low capital cost of hobbyist equipment sharply

reduces the economic and technical barriers for a would-be entrepreneur working out of his garage to offer hybrid data processing/

communication services. Together these trends could result in

the creation of a broad constituency for more relaxed regulation

of computer communication.

2

An example of a formal technology transfer program can be seen at NASA.

One ongoing program at this agency is the Space Industrialization Concept.

(See Appendix C.) NASA also contracts with some carriers, such as Western

Union's Space Communications, Inc., or even parent companies such as Fairchild,

to help conduct their space program. For example, Fairchild participated in

1. Hermes is only one electronic message system; many are being

developed by firms such as Digital Broadcasting Corporation and Scientific

Timeshare Corporation, as well as by AT&T, Western Union, and the Postal

Service. For a complete description of these systems, see Kalba, Konrad

K., e_t_ al . : Electronic Message Systems: The Technological, Market and

Regulatory Prospects , April 1978.

2. See Kalba, Konrad K., et al . : op. cit. , p. 86.
84

construction of the space shuttle, Enterprise. This type of government/ industry

activity might also influence innovation.

Another factor that might influence innovation is congressional activity.

In September 1978, H.R. 14046, the Public Service Satellite Communications

Bill, was introduced into Congress. Actual research activity will be administered by NASA if the bill is funded. However, members of the House are

specifically concerned with communications technology applications which might

be in the public interest, but which are not within the capability of commercial

communications firms to provide in the near future. Some applications mentioned in the bill are below.

It is in the public interest to encourage the planning and development

of noncommercial communications satellite services in such areas as health care delivery, education, search and rescue, electronic mail,

teleconferencing, and environment data collection which cannot presently

be made available at affordable cost by technology now being used by com- mon carriers for producing conventional telephone and television services.

F. THE COMMISSION'S INQUIRY PROCESS:

FORUM FOR DIALOGUE WITH THE INDUSTRY

In the preceding sections, a number of cases pending decision before

the Commission were discussed. The Commission addresses these cases directly

or indirectly by means of an inquiry process in which interested parties are

allowed to comment formally on these cases. A decision regarding Advanced

Communications Service will be related to any rulemaking resulting from the

Computer Inquiry. Conversely, each inquiry involves several policy issues.

1. Representatives Ottinger, Rose, and Fuqua. H.R. 14046, Public

Service Satellite Communications System Bill, presented to the Committee

on Science and Technology, September 1978.
85

Because the Commission traditionally makes decisions on a case-by-case

basis, there has perhaps been less interest in seeing the similarities among

cases. We propose to test the feasibility of transferring knowledge gained

from one inquiry to another, and to use the PMS deregulation as a vehicle for

developing a more purposeful data- gathering approach. Information gathered by

evaluation staff may be used by the Commission in evaluating its procedures.

We began to examine commonalities among cases by conducting content

analyses on materials that were either directly or indirectly related to the

public message services deregulation. Specifically, the analyses included:

• Comments submitted to the Commission by parties wishing to

participate in the decision-making processes of five inquiries: —Western Union Monopoly Inquiry —Computer Inquiry —Telex/TWX Inquiry

—Gateway Inquiry

--MTS/WATS Inquiry

• Witness testimony, before the Subcommittee on Communications of

the House Interstate and Foreign Commerce Committee, in regard to

H.R. 13015, the Communications Act of 1978.

During the analysis, we found that specific issues in each case could be used

to help identify generic issues which cut across cases. This process is

illustrated in Figure III-3. In the figure, generic issues are listed

in the lefthand column. Their specific expression in each inquiry is shown

across the columns. It should be noted that the generic issue has not been

identified in every inquiry. This does not necessarily mean that there is not

one. In time, this list will be expanded to include other generic issues.

More work on this matter must be done as the evaluation progresses.

A generic issue of great interest to ETIP is, "Will deregulation encourage technological innovation?" (Issue IV). In the Western Union Monopoly

Inquiry, the specific issue is, "Will deregulation encourage entry of innovative public message services technology?" Figure III-3 shows that the
86

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evaluation may also shed light on a number of other important and relevant

research questions. These might be investigated as the project advances.

To clarify the interrelationships of these questions, two generic issues

are discussed in more detail below.

1. FAIR CHARGES AND

INTERCONNECTION

The seventh generic issue listed in Figure III-3 concerns nondiscriminatory service charges and interconnection. The Commission is presently

considering whether to grant permanent authority for the international

carriers to operate in all existing gateways, and is examining the fairness of Western Union's charges to international carriers for landline haul

(domestic transmission) of messages to and from the gateways. The following questions arise:

• What is fair competition? Should Western Union be required to serve other carriers and interconnect for message transmission?

• How does one determine whether a rate increase is justifiable

in terms of increased costs or in terms of the need to maintain

revenue?

• Is the domestic public message services market viable?

• How can consumers of regulated services be assured that the

rates they are paying are reasonable?

• How can the Commission improve rate regulation? Are better

accounting techniques called for, and if so, what kinds of

economic information should be required by the Commission?

Just as international record carriers interconnect with Western Union,

competitive carriers may interconnect with AT&T's network. Although the

basic issue has certain similarities, the question of interconnecting with

1. Gateway refers to a location where international carriers take over message transmission from the domestic carrier. Originally, gateway was a term of art that largely meant Washington, New York, and San Francisco.

Gateways today are New York, Washington, Miami, New Orleans, and San Francisco.
88

AT&T is more complicated. AT&T's long-distance telephone monopoly was

granted in part to protect the viability of small telephone companies

throughout the nation, especially in rural, low-density areas. The current telephone rate structure is based on a system of division of revenues in which AT&T reimburses these small companies for use of their local

facilities for interstate transmission. This system does not presently

take into account interconnection and reimbursement from other common

carriers. If other carriers with Execunet-like services are allowed

to interconnect, how should the system of division of revenues be changed?

The following questions should be answered even before that one:

• Is competition in long-distance telephone service in the

public interest?

• What is the dividing line between private line and long-distance

telephone service (MTS/WATS and Execunet-type services)?

The question of the survival of small telephone companies is an important issue in telecommunications today. In fact, the Rural Electrification

Commission (which loans large amounts of money to these companies) has

even suggested that the nation's rural telephone operators should be allowed

to provide "total telecommunications" services so that they can meet the

impact of advancing telecommunications competition. Pending legislation

on this issue calls for a new definition of telephone service:

[Telephone service] shall be deemed to mean any telecommunications

service for the transmission of voice, data, sounds, signals, pictures,

writing, or sign of all kinds by wire, radio, light, or other electromagnetic systems, and shall include all lines, facilities, or systems

used in the rendition of such service, including community antenna

and cable television facilities, but shall not be deemed to mean

1. AT&T has proposed a system known as ENFIA which might alleviate

this problem.
89

message telegram service, or radio broadcasting services or facilities

within the meaning of section 3(o) of the Communications Act.l

It should be noted that one of the PMS deregulation activities is to redefine

message telegram. This problem of definition and others are discussed below.

2. REDEFINITION OF OBSOLETE SERVICES

The fifth generic issue listed on Figure III-3 concerns redefining regulatory services when traditional definitions become obsolete. The descriptors

"telegram" and "telegraph" no longer seem adequate. In the case of this

proposed deregulation therefore, the definitional question is "What are

public message services?" Technological descriptions provided the necessary

boundaries at one time. This is no longer true. For example, electronic

message service is an alternative public message service. But what is electronic message service?

[Electronic message service] is not traditional voice telephone

service, traditional telegraph service, or traditional telex or TWX.

It is not video or slow scan video. It is not terminal to computer

or computer to computer data communications . . . [and] for the

purposes of this study, the various forms of facsimile service

can be considered a variation of [electronic message service] only

to the extent they are part of an integrated service which is

primarily digital and character-oriented.

The definitions do not represent a consensus on the part of the

authors of this report —nor, we suspect, of FCC members and staff

concerning EMS boundaries .... By focusing on emerging terminalto-terminal, digital message systems, the burden of also covering

conventional facsimile systems, TWX and telex, the "hybrid" systems

(i.e., involving both electronic transmission and manual delivery)

such as Western Union's Mailgram (and others being considered by

the U.S. Postal Service), financial transaction systems, or

1 A "Dramatic Change in Rural Telephone Systems to Broadband Facilities

Providing 'Total Communications' as Common Carriers Proposed in REA Study;

Proponents See Rural Systems Better Able To Meet Competition." Telecommunications Reports. Vol. 44, No. 17, May 1, 1978, pp. 3-7.
90

telephone based audio message systems—to mention only a few of

the technologies and services that could be encompassed under

the [electronic message service] rubric—has been lessened.

1

Once public message service is defined, we must determine how to regulate

this market and how to accomplish a transition. Separating regulated and nonregulated business of a carrier in order to define fair rate of return and

identify cost allocations is a difficult problem. Also, just as alternatives

to PMS have developed, demand for heterogeneous services and the seeming

inadequacy of technological descriptions to define service categories may

also produce alternatives to services such as Telex/TWX that were granted

protection in the past in order to maintain revenue for a monopoly carrier

and/or to insure the public adequate service.

The number of alternative Telex/TWX services is increasing. The subject

of the Telex/TWX inquiry is whether Western Union's proposed rate increase

for Telex/TWX services is justified. Telex/TWX revenue is used to subsidize

the provision of public message services by Western Union. If public message

services seem viable, is it desirable to continue the Telex/TWX monopoly?

Will data gathered from analysis of the public message services deregulation

help to answer questions like the following:

• If public message services is a viable market, does it exhibit

characteristics which might help to distinguish competitive from

natural monopoly markets?

• Is the costly and complicated process of separating cost allocations

of carriers engaged in regulated and nonregulated services warranted?

Or should all services be deregulated and, if so, to what extent?

1. Kalba, Konrad K., et_ jil_. : Electronic Message Systems: The

Technological, Market and Regulatory Prospects , Kalba Bowen Associations,

Inc. and the Center for Policy Alternatives, Massachusetts Institute of

Technology in fulfillment of FCC Contract Number 0236, April 1978, pp. 2-3.
91

• Would closing the Telex/TWX market to competition hinder the development of a competitive marketplace for the industry as a whole?

In particular, what impact would closing the Telex/TWX market to

competition have on value-added carriers?

• Can the transition from monopoly to competition be handled similarly

for other market segments if the public message services deregulation is smooth and beneficial?

This problem of defining regulatory boundaries also occurs in the other

inquiries. Examples from the Computer Inquiry, the Gateway Inquiry, and

the MTS/WATS Inquiry follow.

A solution to the Computer Inquiry seems to require a redefinition

of data processing. The Commission has already decided that data processing

should remain unregulated, but wants to establish a new definition which

is more sensitive to the role of hybrid services and distributed networks

that rely on intelligent terminals. Most inquiry commentors expressed the

belief that a clearcut technical distinction between data communications

and data processing is impossible. However, the Commission believes that

some definitional distinction is necessary unless data processing services

are also to be regulated.

In the Gateway Inquiry, the definition of the term "gateway" is at

issue. In this age of satellites, the technical justification for gateway

traffic systems has largely disappeared. The international record carriers

believe they are able to deliver their services more cheaply and efficiently

through the telephone system (WATS line) than through Western Union. Should

the gateway concept be retained? If so, then criteria for defining a gateway

must be developed.

In the WATS/MTS inquiry, an important question is whether the two services

are "like" services. According to the Commission rules, like charges should

be billed for like services. Discriminatory pricing is a central issue

here. Are users of monopoly services being charged excessively to subsidize
92

lower prices in competitive markets? In particular, are higher rates for

MTS being used to subsidize WATS? The same facilities are used for both

MTS and WATS, which AT&T claims are distinct services. If WATS and MTS

are like services, then the Commission must increase its surveillance of

AT&T in order to insure that no discriminatory charges are made. What

standards should there be for like services? How much regulatory interference should there be? Would a decision in this inquiry have any effect

on the use of WATS as a public message services alternative?

Concepts that need defining include: a market; the threshold of competition in a market; a natural monopoly market; and even the telecommunications

industry itself. A workable and realistic redefinition of public message

services may suggest ways to define these other concepts as well. The

search for clear definitions is actually a search for regulatory boundaries.

By altering its perception of those services, it is altering the scope

of its activities.

Unclear regulatory definitions are often blamed for a carrier's reluctance to offer new services and equipment. For example, AT&T has requested a

declaratory ruling on whether it can offer the Advanced Communications Service, because definitions of communications and data processing are unclear.

If confusing regulatory definitions do indeed cause industry uncertainty,

then the Commission and ETIP may want information to help formulate flexible,

realistic definitions or perhaps even uncover an alternative to the entire

definitional process. Some work at the operational level in industry will

probably be nessary to determine, for example, how messages are actually

transmitted.
93

G. SUMMARY

This chapter has attempted to show that the telecommunications environment in which the proposed deregulation will take place is complex and

changing. As the evaluation progresses, research into the areas discussed

will be required for correct interpretation of the evaluation findings.

The chapter has also shown that such issues as cross-subsidization, rate

of return, cost allocation, network integrity, market structure, price

discrimination, definitions, regulatory reporting requirements, equipment

and service standards, etc., are well-entrenched issues which arise among

different inquiries and within the context of broad debates.

The effects of the deregulation of the public message services market,

properly monitored and analyzed, might provide information to policy makers,

regulators, and other stakeholders for regulating and guiding the evolution of

the marketplace to an optimal state, with greater assurance and less hesitancy

than in the past. For example, if knowledge about issues can be generalized

from case to case, guidelines for determining fair rate of return, fair competition, etc., which would facilitate decision making, might be developed.

This project should contribute to a more purposeful data-gathering approach.

It may not only provide knowledge for ETIP , but might also help the Commission

to increase its influence on the market structure of the telecommunications

industry.

95

IV. PRESENT SITUATION

A. OVERVIEW

The present situation in regulated telecommunications has been likened

to a three-dimensional chess game. Since there is considerable uncertainty

at any given moment, the next move is always problematic. The deregulation

of public message services is a small move in this large and complicated

intercourse.

Although its relevance to the "public" side of regulated telecommunications is important, the proposed deregulation is also noteworthy because

it should lead to actual open competition for public message exchanges.

We expect competition to lead to lowered costs for PMS, which in turn should

increase demand. However, if new companies do not emerge to offer public

message services, or if the public opts not to buy new public message services, then the service cost reductions and technological innovations that

we expect will not occur. Along with the deregulation, other things must

happen. For example, any petitions objecting to the deregulation must

be handled. Common carriers must apply to the Commission to offer public

message services in the marketplace. Finally, customers must be available

to support a profitable operation for more than one public message carrier.

The main events, which are expected to mark progress of the evaluation

towards a successful conclusion, are known as the logic. Section B of this

1. The term deregulation is used here to denote a change in policy,

practice, or rules which reduces (but does not necessarily eliminate) the

burden on the regulatee.
96

chapter introduces the events. Within each event, many activities will

occur to signal the success or failure of expectations of ETIP and the

Common Carrier Bureau of the Federal Communications Commission. The dominant

elements in the logic are, of course, the Commission and public message

services commerce. The balance of this chapter presents our findings to

date about these two components.

Section C contains a description of the Commission, emphasizing the

role of the Commissioners and the Common Carrier Bureau (the Commission's

arm in common carrier regulation). The Communications Act of 1934 and

the official rules and regulations as expressed in the Code of Federal

Regulations Volume 47 (47 CFR) also are treated as a separate, important

component of the Commission's regulatory process.

A description of Western Union's approach to competition (as perceived

by onlookers) and an historical view of the company were included in Chapter

III. In Section D of this chapter, we will scrutinize more closely Western

Union operations, service offerings, and public message services and their

relationships to other services offered by the company. Speculations on

the potential market for PMS will be offered. Our study shows that current

volume of services traditionally considered PMS may be a misleading indicator

for the potential volume of electronically transmitted public record messages.

For instance, a significant portion of First Class Mail (15 billion pieces,

or almost a third) seems to be candidate for electronic message transmission

perhaps by the USPS 1 ECOM service. Using this figure, the potential volume

of messages categorized as PMS is much larger (330 times) than the current

2

message volume statistics would indicate.

1. See "USPS Announced Electronic Mail Service: Crosses Regulatory

Rubicon," EMMS , Vol. 2, No. 18, September 15, 1978, pp. 9-10.

2. Message volume for 1977 is 4,529,684. U.S. Federal Communications

Commission, Statistics of Common Carriers, 1977 Computer Printouts, Table 24.
97

The final section of this chapter discusses selected other services and

carriers which might be affected by the deregulation. Potential public message services competition from the USPS and the specialized common carriers

will be examined. Also, we describe the resources of two specialized resale

carriers, Graphnet Systems and Telenet, since some members of this group will

probably enter the deregulated PMS market.

The evolution of a competitive marketplace seems to depend on whether

small companies such as Graphnet and Telenet can compete with larger carriers.

An analysis of their service characteristics and resources indicates that,

despite sizable differences between Western Union and these carriers in terms

of capital investment in service network, the smaller companies have a nearly

equivalent functional capability to supply public message services. Both

Graphnet and Telenet are very innovative firms; Graphnet develops its own

equipment interface packages, and Telenet introduced packet switching technology commercially. The detailed description of the specialized resale

carriers also illustrates the type of background information which would

be gathered and analyses which would be conducted on any entrants into the

deregulated market. This information would have to be validated by more

direct contacts in the industry (just as material on the Commission was

validated by staff of that agency).

B. LOGIC OF THE EVALUATION

In January 1979, the Commission approved a policy change to open the

PMS market to competition. The public message services deregulation has

been chosen as the vehicle for conducting an experimental evaluation of

the effects of deregulation. The evaluation's primary purpose is to obtain
98

information about the agency, the industry, and the commercial impacts of

changes in the regulatory process.

The hypothesis of the evaluation is that a competitive PMS market will

be an environment in which carriers offer a greater variety of superior

and less expensive public message services to the market. The changed rules

and regulations governing PMS commerce must conform with the policy intent

of the Commission—reducing PMS regulation and encouraging competition.

Formal interviews and informal discussions with ETIP and CCB staff,

and examination of relevant data and documents, have pinpointed seven major

events which we expect to occur. We will measure the effects of the deregulation and will determine specifically whether these events—or logic

occur. Other measurements will be chosen in part according to actual effects

of the deregulation. For example, one event in the logic calls for the CCB

to develop a streamlined process for administering PMS regulation. The

first step would be be confirm that the event had occurred. Other decisions

regarding the event would follow: should it be investigated in terms of

Commission staff time, turnover rate, industry costs, greater simplicity,

improved attitude or responsiveness of industry, etc.? The level of rigor

with which each issue should be investigated would also considered.

In this way, the data is more likely to be useful. The following events

represent a logic for the proposed evaluation.

EVENT I : The CCB drafts a M0&0 and rulechange intended to end Western

Union's monopoly, open commerce to competition, and reduce

future regulation of PMS.

EVENT II : After public notification and appropriate deliberation, the

Commission authorizes CCB revised rulemaking to go into

effect.

EVENT III : The CCB streamlines the process for administering ongoing

PMS regulation as per the open-competition policy established by the Commission.
99

EVENT IV : Established carriers and other interested businesses submit

applications to enter the open (deregulated) PMS market.

EVENT V : The structure of PMS commerce is observed to change in

terms of carriers, customers, services, transmission

facilities and equipment, prices and profits.

EVENT VI : Systematic evaluation and research demonstrates improvement in PMS commerce as per the Commission's mandate

for common carrier commerce, and CCB and ETIP goals for

the evaluation.

EVENT VII : CCB and ETIP transfer knowledge gained through study

as evidenced by useful applications of findings.

Chapter V presents a detailed description of participants and activities,

and potential products, measures, and information uses for each event. The

evaluation is still in an early phase, and therefore, expectations concerning

major events are subject to redefinition by ETIP or the Federal Communications

Commission.

Figure IV-1 illustrates the relationship of the expected events to

a model of current PMS commerce which is used for measurement purposes.

(See Figure VI-3.) The figure points out the distinction between the first

five events, which focus on achieving reformulated public message services

commerce, and Events VI and VII which focus on processing information on

whether Events I to V occurred as expected.

The main elements of the evaluation's logic can be broken down as follows

the Federal Communications Commission (regulator of PMS); the status of PMS

before deregulation; and the status of PMS after deregulation. Each of these

is described below.
100

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101

C. THE FEDERAL COMMUNICATIONS COMMISSION:

REGULATOR OF PMS

The regulation process associated with PMS is similar to that employed

is the other sectors of commerce. The Commission's regulatory process has

four major parts: the Communications Act of 1934; a Commission composed

of seven members; the Code of Federal Regulations, containing telecommunications regulations; and the Common Carrier Bureau, which routinely administers

the policy and rules governing common carrier regulation. Findings to date

about these elements are presented below.

1. THE COMMUNICATIONS ACT OF 1934

The Commission receives its authority from the Communications Act of

1934, as amended. The mandate, or statement-of-purpose clause, is contained

in Title I, Section I:

For the purpose of regulating interstate and foreign commerce in

communications by wire and radio so as to make available, so far

as possible, to all the people of the United States a rapid, efficient , Nation-wide , and worldwide wire and radio communication

service with adequate facilities at reasonable charges , for the

purpose of national defense, for the purpose of promoting life

and property through the use of wire and radio communication, and

for the purpose of securing a more effective execution of this

policy by centralizing authority heretofore granted by law to several agencies and by granting additional authority with respect

to interstate and foreign commerce in wire and radio communication,

there is hereby created a commission to be known as the "Federal

Communications Commission," which shall be constituted as hereinafter provided, and which shall execute and enforce the provisions

of this Act. [Emphasis added.]

Title II of the Act gave the Commission tools and powers to regulate telecommunications, similar to those used by the Interstate Commerce Commission

for transportation regulation. In fact, it incorporated provisions of the

Interstate Commerce Act. Under the "new" powers granted to the Commission,

it could require carriers to:
102

• interconnect with other carriers and establish through routes

(formalization of the Kingsbury Commitment);

• file rate schedules;

• submit contracts made by any carriers; and,

• obtain a certificate of public convenience and necessity from

the FCC should expansion or construction of new interstate lines

be desired.

Also, the Commission was given authority to review not only carriers'

charges, but their "practices, classifications and regulations" and to determine whether these were fair. The Commission could also initiate investigations of proposed changes in rates and suspend proposed rate schedules

for up to five months pending investigation. In addition, Congress instructed

the Commission to keep abreast of new technologies, so that their benefits

would be made available to the public of the United States. Title III

adopted the substance of the Radio Act of 1927 to govern broadcasting and

all radio licensing. Titles IV through VI set fortn general administrative

procedures that were used in most federal regulation in 1937.

2. THE COMMISSIONERS

Decisions regarding major disputed cases are made by the Commissioners.

Their findings in these cases set precedents for subsequent Commission

actions, including routine staff decisions. The Commissioners also control

resources and, to some extent, the agenda of activities of Common Carrier

Bureau staff. In both capacities, the Commissioners influence the character of telecommunications regulation and commerce, including public message

services.

1. See Loeb, Guy. The Communications Act Policy Toward Competition:

The Sound of One Hand Clapping , March 1977.
103

3. CODE OF FEDERAL REGULATIONS, VOLUME 47

The Code of Federal Regulations is a codification of the general and

permanent rules, published in the Federal Register , for the Executive departments and agencies of the Federal Government, including the FCC. CCB

rulings comply with Volume 47 of the Code of Federal Regulation (47 CFR)

,

which applies to telecommunications. Each Part within 47 CFR contains

rules governing general or specific operational responsibilities. For

example, Part defines Commission organization, including delegations

of authority, Privacy Act regulations, meeting procedures, etc. Part 1

is known as "Practice and Procedure" and describes hearing and rulemaking

proceedings as well as general rules regarding procedures for complaints,

tariffs, applications, and other reports involving common carriers.

There are over 300 pages of regulations which apply to common carrier

commerce, including public message services. The Parts of 47 CFR that

are most relevant to public message services are the eight below:

Part 21 "Domestic Public Radio Service" (requirements for licensing

basic transmission facilities)

Part 35 "Uniform System of Accounts for Wire Telegraph and OceanCable Carriers" (stipulations for approximately fifty

categories of accounting, ranging from "communication plant"

to "retirement units")

Part 41 "Telegraph and Telephone Franks" (requirements governing

provision of "free" service)

Part 42 "Preservation of Records of Communications Common Carriers"

(hundreds of "items" ranging from "corporate and general" to

"operations" that must be retained by regulated common carriers)

Part 43 "Reports of Communication Common Carriers and Certain Affiliates" (twelve types of reporting requirements ranging from

"annual reports of carriers and certain affiliates" to "reports regarding services performed by telegraph carriers")

Part 61 "Tariffs" (filing requirements for "change in rate structure

of an existing tariffed service," for "new service offerings,"

and for assorted other circumstances)
104

Part 63 "Extension of Lines and Discontinuance of Service" (specific

requirements for extension of transmission lines, and discontinuance, reduction and impairment of licensed common carrier

facilities)

Part 64 "Miscellaneous Rules Relating to Common Carriers" (includes

domestic telegraph speed of service studies such as "instructions for the conduct of terminal handling speed of

service studies" and "participation in data processing by

communication common carriers")

Together, these requirements determine what business decisions are

subject to Commission review, and the character of the review. Parts 61,

"Tariffs," and 63, "Extension of Lines and Discontinuance of Service by

Carriers," are considered most important because they govern the services

carriers can offer, the prices they can charge, and whether or not they

can expand or contract the facilities used in the provision of services.

With open public message services commerce, market forces are expected to

exercise control over prices so tariff requirements are expected to be

more lax. Requirements for requests to construct additional facilities

will also be reduced by the deregulation. A statement justifying the need

for additional facilities, for instance, will probably not be required.

These written policies and rules are important in their relationship

to Commission actions and Congressional intent and to Common Carrier Bureau

organization and process and the behavior of commerce. For example, the

stipulations in 47 CFR must be within the purview of the 1934 Act as per

its latest amendment. Also, the Commission's decisions specify the language

of each stipulation. In turn, CCB staff develop forms and protocols for

handling carriers' applications that must be consistent with the intent

specified in language in 47 CFR. Finally, the stipulations define which

carrier actions are subject to FCC review. For these reasons 47 CFR is

an essential component of public message services commerce. In general,
105

the present language in 47 CFR reflects the recent monopoly tradition.

Stipulations require very close scrutiny of prices and rate of return.

4. THE COMMON CARRIER BUREAU

Figure IV-2 outlines the basic organization of the Federal Communications Commission. Staff are assigned to one of thirteen major units.

About 12 percent of the Commission's 1,900 employees are assigned to the

Common Carrier Bureau (CCB)

.

OFFICE

AND

BUREAUS

Commissioners

7 members

I. I Office of Executive

Director

Office of Plans and PolicyOffice of Chief

Engineer

Office of General

Counsel

Office of Administrative Law Judges

Common

Carrier Bureau

I

Review

Board

I. Broadcast

Bureau Cable

Television Bureau

Field

Operations

Bureau

Safety and Special Radio

Service Bureau

Office of Opinion

and Review

Source: FCC Office of Public Information Bulletin, "The FCC In Brief*

FIGURE IV-2: BASIC ORGANIZATION OF FCC

1. Appendix D, "Findings about Information Sources Available at the

Commission and Elsewhere," is a more detailed account of the research activities

of ETIP and its contractor at the Commission during the initial phase of the

project.
106

Staff members assigned to each branch of the Common Carrier Bureau

develop "specializations" in administering specific Parts of 47 CFR. Figure

IV-3 illustrates the organization of the Bureau in relation to the Parts

of 47 CFR administered by each branch.

Most of the staff are either attorneys, economists, engineers, public

utility specialists, managers, administrators, or secretaries and assistants.

A great deal of common carrier interaction with CCB operations involves

applications to change business practices. For example, if The Western Union

Telegraph Company wanted to change the location of a station, it would first

submit an application to the Domestic Facilities Branch of the Facilities

and Service Division of CCB for approval to construct additional transmission

lines. (This is known as a request for 214 authority as per Part 63 of

47 CFR.) Then, if authority to offer a new service or to change a rate

is desired, the carrier must also submit a tariff to the Tariff Review

Branch of the Tariff Division, in compliance with Part 61 of 47 CFR.

These different types of applications are known as filings; filings

are approved, disapproved (or denied), or withdrawn. Agency approval or

disapproval is known as a ruling. Tariff applications, however, are not

"approved." For example, Part 61 of 47 CFR concerning rates stipulates

that a tariff filing may be considered effective if there is no Commission

decision to the contrary within a prescribed period of time. In other

words, the tariff is deemed effective if the Commission finds no compelling

reason to deny it. A carrier has the right to make a tariff filing at

any t ime

.

The number and types of activities required to act on a filing seem

to vary according to application classification and the amount of disagreement between CCB staff and the carrier submitting the filing about
107

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the application's content. Most filings are routine and require only simple,

low-cost activities to produce a ruling. However, some are quite complex

and require a heavy investment in activities. Examples of the latter case

would be a disputed filing about which CCB has received a complaint or a

filing from a monopoly carrier, which must fulfill many agency requirements

before a change can be authorized.

Western Union's PMS filings represent only a small portion of the regular workload for CCB. Using one indicator of workload, we found that about

1.3 percent of 1,876 tariff filings received between September 1976 and

April 1978 related specifically to PMS. This represented about 14 percent

of Western Union's total tariff filings during the 20-month period. A

similar study of a smaller sample of filings that involved extension of lines

and supplements to existing equipment also showed that only a very small percentage of filings was related to public message services.

Figure IV-4 illustrates another finding on CCB operations. Tariff

filings from companies other than those with Bell or Western Union account for

64 percent of the total. Essentially, the international record carriers,

specialized carriers, and other enterp'rises that are comparatively small in

2

terms of yearly revenue, generate the majority of the CCB's filing workload.

Also, preliminary data, taken from courtesy logs and used as a proxy

of total tariff filings show that CCB has been experiencing a significantly

increased workload. Figure IV-5, total tariff filings per month, demonstrates

this phenomenon.

1. CCB Tariff Review Branch Courtesy Logs, September 1976 through

April 1978, and sample of facilities filings reviewed by UI staff, Summer

1978. See Appendix D also.

2. A study of CCB staff time actually spent on different types of

tariffs has not been conducted. A count of tariffs is not a completely

accurate representation of staff time allocation because, as tariff re- viewers have indicated, applications involving monopoly services are more time-consuming to process.
109

/Lease 2.0%

Telex/TWX 2.1%

Satellite 1.8%

Other 2.5%

PMS 1.3%

Source: CCB Tariff Review Courtesy Logs, September 1976 to April 1978

FIGURE IV-4: TARIFF FILINGS PER CARRIERS, 9/76 TO $8

14C

12C100'

80.

60.

40

20

+ + SO JJ BJFMAMJ JA SON D J FM A 1976 1977 1978

Source: CCB Tariff Review Courtesy Logs, September 1976 to April 1978

FIGURE IV-5: TARIFF FILINGS PER MONTH
110

Although PMS accounts for only a small portion of CCB activity, we

are told that the processing method for public message services filings

is similar to the branch procedures described in the following sections.

The style of CCB operation and the types of common carrier information used

by staff of each branch are emphasized. For more detailed information,

see Appendix D.

a. DOMESTIC FACILITIES AND INTERNATIONAL AND SATELLITE BRANCHES

International and Satellite Branch handles all of the international

carriers and the domestic satellite carriers. Domestic Facilities handles

all other types of carriers. Basically, both branches process the same

types of applications. The discussion below will focus on the Domestic

Facilities Branch.

Domestic Facilities is divided into four groups: the telephone and

telegraph group handles filings from the two established monopoly common

carriers; the second group handles specialized common carrier filings; the

third group handles filings of other types of carriers such as microwave

common carriers; and the fourth group advises those who are applying for

214 authority for the first time. The branch currently maintains files

on approximately 15,000 transmission stations which it has licensed.

A sample of 183 facilities applications was analyzed for number of

applications per carrier, type of applications, and geographic extension,

of network. An additional 51 applications were studied in greater detail.

Of these, 40 specifically complied with Section 63.03 of Part 63 which concerns supplementing existing facilities, considered to be a minor action.

1. Part 63 does allow companies such as Western Union to submit blanket

filings covering a set of applications. The sample described in this section

does not include any blanket filings.
Ill

Filings were submitted by Bell, independent telephone companies, or jointly

by Bell and independent companies. Separate filings must be processed for

each point-to-point extension of a carrier's network. A review of all facilities applications for a carrier would seem to be necessary for an accurate

understanding of the nature and extent of the planned expansion. The average

processing time was 17.5 calendar days. All applications were approved.

These filings also reveal which carriers are leasing, renting, or purchasing facilities from other carriers rather than constructing their own.

All requests (new constructions, purchases, etc.) gave probable costs, for

example, maximum yearly rental costs. Two requests were for special temporary

authority (e.g., satellite transmission of Madison Square Garden events

to cable television stations). These two requests took 20 and 21 days to

process—slightly longer than the average—and were also approved.

The remaining 11 filings concerned Section 63.01 and requested the following types of changes: installing/extending of cable and carrier systems

and rerouting interstate channels. These are considered to be major actions

because environmental impact must be taken into consideration before approval

can be granted. Each application on file contained a "Telephone Wire Application" form, and copies of the requests were sent to the Secretary of Defense

and Governor of the state affected by the proposed change. The average processing time was 42.5 days—twice as long as for other types of facilities

applications.

b. TARIFF REVIEW BRANCH

As we mentioned previously, Part 61 of 47 CFR governs tariffs. Many of the

specific sections of Part 61 deal with definitions and format. Section 61.38

concerns economic support data. Section 61.58 concerns notice requirements.

All tariffs must bear the stamp of the Secretary of the Commission if

hand delivered, or the mailroom stamp if mailed. Stamped tariffs are routed
112

to Tariff Review. In September 1976, to offset a time lag that had developed,

Tariff Review requested that the carriers provide them with courtesy copies

of the tariff filings at the same time that the original is delivered to

the Secretary's Office or mailed. Another reason for this request was that,

since emergence of the specialized common carriers and more competition

in the marketplace, Tariff Review receives more requests for information

about tariff filings and has a greater need for current information than

ever before.

A daily log of tariff courtesy copies that are received is kept. This

log records which carriers filed and also contains a brief summary of each

tariff filing. Submitting a courtesy copy, however, is not mandatory, and

another official count is compiled in tabular form showing only a count

of the original tariffs received monthly.

All courtesy copy logs as of April 1978 were analyzed. A comparison

of courtesy copy count to official count showed that approximately 18 percent

of all tariffs were not included in the courtesy log. One Tariff Review

staff member hypothesized that this 18 percent consisted of minor filings,

but no one has determined exactly which filings are submitted without courtesy

copies. Analysis of the courtesy copies revealed the distribution of tariff

activity by type of carrier and the fluctuations over time in volume of

tariff filings by type of tariff for each carrier. (See Appendix D for

examples.) We understand that Tariff Review is considering making courtesy

copies mandatory.

Each reviewer specializes in a particular type of carrier. One staff

member, for example, handles all specialized carriers. This is a recent

innovation in their procedures. However, because review process for monopoly

carriers is so time consuming, these carriers are divided among reviewers.
113

One reviewer is assigned AT&T, another is assigned Western Union, and so

forth. Reviewers also assist newly licensed common carriers submitting

tariffs for the first time.

Two checklist forms are used by the tariff review staff: one for the

tariff itself and the other for cost support material (61.38). Both checklists assist the reviewer in examining the format only. Content analyses

of cost support data are not included on the checklist form and, in fact,

are not written unless a problem exists. Sometimes even if a petition is

received, the cost support analysis will be described verbally to the attorney

handling the case.

Each reviewer has the option to recommend consulting the Tariff Review

supervisor about problem filings, for example, those that may prompt a petition or complaint. A tariff that involves a complaint or a problem may

take one to two weeks to be checked out finally by "higher-ups" in the Bureau.

Staff time spent in the Tariff Review process is difficult to measure.

One reviewer interviewed said that:

Even for an established carrier, to check the format of a new

tariff may take half an hour or 45 minutes depending on the length

of the tariff in order to make sure they have all the pieces,

proper notations, symbology, etc. Western Union's format is

standardized and might take only 5 minutes to check. However,

total review time for Western Union tariffs may run into hours

because of the monopoly situation. A revised tariff, on the other

hand, may take only five minutes. Time required for a reviewer

to analyze cost data also varies. A detailed analysis of AT&T may

take half a day—or a year; others can be completed in half an hour.l

Some of a reviewer's time is also spent in contact with the carriers

themselves. A great deal of time may be spent assisting a smaller carrier

1. UI Staff Notes: Interview with FCC/CCB staff, Tariff Review,

Summer 1978.
114

which is less familiar with tariff requirements. In this situation, the

reviewer may check the carrier's tariff format before the tariff is actually

filed, so that the tariff does not have to be rejected for a simple error

in symbology, organization, etc., and resubmitted. Tariffs are not reviewed

for content until submitted. (See Appendix D for sample checklists used

by tariff reviewers.)

Although reviewers are assigned to specific categories of carriers, all

tariffs are routed through every reviewer before the staff person assigned

actually takes over—part of a makeshift system of checks and balances.

Research staff found only an informal system for tracking the tariff and

cost support material through the review process.

Appendix D contains examples, obtained from a review of the public

files, of information on the number of applications and the types of common

carriers regulated by the Commission. In examining these tariffs, we paid

particular attention to service and financial information about Western Union

and the specialized carriers. Types of information contained in the tariff

included: carrier's name, names of other carriers participating in the

tariff, types of services (classes and subclasses), rates, and points of

service. The detail and clarity of the information varied.

We prepared a draft memorandum describing Graphnet, a specialized resale

carrier, almost entirely from information in Graphnet ' s tariff. With FCC

permission, we contacted Graphnet ' s Washington representative and submitted

copies of the memorandum for verification. On the whole, the tariff information was accurate, but it did not seem to give a complete picture of the

company's operations. For example, information probably of interest to

the evaluation that was not contained in the tariff included: the fact that
115

the company develops its own equipment interface packages, and the fact

that it manufacturers some specialized hardware devices.

Table IV-1 gives notice periods and petition periods for different

types of applications. Figure IV-6 shows the time constraints under which

Tariff Review staff must work in order to complete analysis of a problem

tariff prior to a Commission meeting.

c. TARIFF PROCEEDINGS BRANCH

In some instances, Tariff Review receives a petition regarding a tariff

filing and orders a formal legal proceeding. Tariff Proceedings then becomes

involved. This branch operates in association with Tariff Review and receives

its analysis if a potentially serious violation, such as discrimination,

unfair profits, or predatory prices, is identified. It is important to note

that Tariff Proceedings deals with the same issues as Tariff Review but brings

to bear a more formal and legalistic approach. This branch has a staff

of ten professionals, primarily attorneys.

d. COMPLAINTS AND SERVICE STANDARDS

The fifteen staff members of this branch monitor the quality of services

provided under carrier tariffs, process complaints, and examine applications

for change of service.

About 3,000 complaints a year are received. Processing activities vary

according to the type and seriousness of the complaint. Some are referred

to other authorities such as a state public utilities commission. Some require only minor actions, such as an apology and reimbursement of a consumer

by a carrier. More serious complaints can lead to the type of special proceedings for resolving difficult filing disputes.
116

TABLE IV-1: NOTICE/PETITION PERIOD GUIDELINES

NOTICE PERIOD* PETITION PERIOD TYPE APPLICATION

(Unofficial Designation)

15 days

70 days

90 days

petitions must be received

within 7 days

petitions must be received

within 15 days

petitions must be received

within 25 days

minor; unimportant

as far as rates

medium; e.g., new

equipment

major; e.g. , rate

change activity;

controversial

*Tariff automatically becomes effective on the scheduled effective date if no action taken by the Commission to either suspend or reject the tariff filing.

If a party does file a petition or objection, or if FCC staff has questions,

FCC can order extension to 90 days. FCC is not really locked into these time

periods since Congress passed law that it could use its own discretion regarding

90-day notice period.

Source: 47 CFR, Section 61.58; interview with CCB staff, August 1978.

Tariff

Fll ing Effective

dat e: Date

90 Days:

1st 25 35 45 55 66 75 85 90 day days

i 1 1 T J^ 1 f T,

25 days n - — - - 2.-2 week Analysis Reeularly

to more TIME REVIEWERS period submitted Scheduled

receive days ACTUALLY HAVE TO DO being to Meeting

petition for ANALYSIS (while also reviewed Minutes*

to carrier working on normal by

suspend to work flow) "higherreply ups"

*Tariff analysis in formation must be submitted to Minutes 16 days prior to

regularly scheduled meeti ng. All scheduling is dependent on a tariff effective date to a certain extent. For example, regular meeting must be before

tariff effective date, or Commission must defer date

Source: Interview with Tariff Review Staff, May 1978

FIGURE IV-6: SCALE SHOWING TIME CONSTRAINTS AND STEPS OF TARIFF ANALYSIS IN

PREPARATION FOR REGULARLY SCHEDULED COMMISSION AGENDA MEETING

(90-day Notice Period)
117

e. ACCOUNTING AND AUDITS BRANCHES

These branches have staffs of 7 and 20 members respectively. (About

half of the Audit staff is assigned to field offices in New York.) These

branches help develop accounting methods and category definitions and audit

regular reports for compliance with procedures and accepted standards of

accounting accuracy. Altogether, data in 114 categories ranging from "radiotelegraph rent expenses" to "interest costs" and "regulatory expenses" are

examined.

f. ECONOMIC STUDIES

The Economic Studies Branch publishes the Statistics of Common Carriers

which contains nearly complete information on the monopoly carriers (including COMSAT, the international monopoly satellite carrier), the independent

telephone companies, and the international record carriers. (However, there

is almost no information available about the specialized common carriers.)

The latest published data on the carriers is two years old. More current

information can be obtained from computer printouts that are compiled

before publication of the Statistics .

Part of the branch's operation is to review monthly and annual reports

from carriers and to draw on random inspections by CCB Field Office personnel

and others. This review captures data on total message traffic per office

and message handling speed, and on other concerns as well, including service

accessibility to consumers, number of personnel, etc.

g. THE FCC INQUIRY PROCESS AND

LINE SUPPORT ACTIVITIES

To handle a problem filing, the Commissioners may initiate a formal

inquiry proceeding. The inquiry process, illustrated in Figure IV-7, involves

a great deal of time and effort for both Commission staff and members of
118

FCC announces

area of inquiry

and requests

comments from

interested

parties

.

Designates

deadlines for

comments and

replies

^

Comments and

replies are

received and

analyzed by

assigned FCC

staff

If additional information

is needed, a second round

of comments and replies

can be scheduled

-^-

FCC releases

Memorandum

Opinion &

Order and/or

proposed rulemaking regarding

area of inquiry

Source: Urban Institute interviews with CCB staff, Summer 1978

FIGURE IV- 7: STEPS IN THE FCC/CCB INQUIRY PROCESS

industry and government. At any given time, however, routine decisions

and special decisions with "minor" consequences are made. Decisions that

coincide with a shift in policy may advance or may not advance the new

policy direction.

In the marketplace, Commission policy formulation is experienced as

a series of inquiries and subsequent decisions (or rulemakings). This

inquiry process, which elicits comments from interested parties, was set

up to provide the Commission with necessary information for its decisions.

The process also provides the Commission with an indicator of the effect

of policy change on market structure. The legalistic, adversary relationship that exists under inquiry conditions also imposes ex parte restrictions

on direct contact between Commission staff and industry. The type and

quality of information on which the Commission decisions are based
119

depends partially on what information each commenting party decides to

submit. Logically, each commentor will base his decision on advice of legal,

technical, and corporate staffs, and their unique expertise and interests.

Under these circumstances, assigning Commission staffs to inquiries

according to their knowledge of the issue makes great sense, and this is what

the Commission does. The Telex/TWX Inquiry, for example, was assigned

to Tariff Division staff; the Computer Inquiry, which was difficult to

categorize, was assigned to Policy and Rules staff. Common Carrier Bureau

administration, support groups, and division managers play a less direct

role in most regulatory issues; they provide analytic, strategic and staff

support. Important cases call for more analytic and tactical support.

In these cases, responsibility for processing a filing is commonly divided

among staffs from many CCB branches and divisions.

When the inquiry process does not resolve the problem, the matter

is designated for a hearing. The Hearing Division is responsible for

both preparation and presentation of the CCB's case, and responsibility

for the ruling is passed on to the Administrative Law Judges. If a case

cannot be settled, it can be brought before the Federal or United States

District Courts, the Court of Appeals, or even the Supreme Court (if that

legal body should agree to hear the case).

5. SUMMARY

Although the Commission has authority to take action against a carrier

over unfair rates and other violations, its operations seem to be directed

more toward responding to complaints than initiating action. This statement

is based on the opinion of Commission staff. No existing comparison (to

our knowledge) shows the average ratio of self-initiated activity to total

activity within the Commission.
120

However, a dramatic increase over the last three decades in conditions

warranting special decision making by the Commission can be documented.

For example, prior to 1950, FCC Decisions and Reports totaled 14 volumes,

from 1950 to 1965, another 30 volumes were added, and from June 1965 to

date, over 55 volumes were added. The differences in cost and staff time

between complex decision making and routine decision making has not been

adequately studied either. Further, the industry costs of complying with

regulation are unknown, although they are assumed to be high.

Allocating more time and resources to decision making does not seem

to be an adequate solution. The problem is highly complex—perhaps so

complex only a fragmented approach is possible. However, any experimental

evaluation program which is implemented should try to produce information

to assist Commission staff in making these decisions. If useful information

can be gained and staff expertise and time are used efficiently, cases

requiring special decision making should decrease. Industry and government

costs might be reduced, or perhaps more importantly, common resources could

be allocated to other areas.

Next we will explore the current status of public message services

commerce.

D. THE WESTERN UNION TELEGRAPH COMPANY AND PMS COMMERCE

1. THE WESTERN UNION TELEGRAPH COMPANY

Western Union's plant is worth about $1.2 billion when allowance for

depreciation and amortization is deducted from the company's $1.7 billion

investment in terrestrial facilities and a satellite. Fully 93 percent,

1. FCC Public Information Office: Information Bulletin, Information

Services and Publications, March 1978.
121

or approximately $1.6 billion of the investment, is in existing terrestrial

facilities including $159 million in plant under construction. About 5.5

percent, or $93 million of the plant investment, can be attributed to the

satellite. The Western Union network is built around Infomaster, a central

processing computer that routes, bills, and records most of the messages

handled.

The Western Union Telegraph Company estimates that in 1977 the cost of

operating the PMS portion of the Infomaster network was about $143 million.

In addition, the Company reports that it has allocated $212 million during

the last ten years for development of the PMS operation.

Since 1942 the number of persons employed by Western Union has been

reduced by 81 percent. Today there are about 12,000 employees divided about

equally among three functional categories—line operation, construction and

maintenance, and other. Figure IV-8 illustrates the relationship among these

categories. A comparison of the percentage of employees staffing the line

operation function now and the percentage 20 to 30 years ago shows that

modern telegraphy is now less labor intensive. In preparing for competition,

carriers—including AT&T—are putting much more emphasis on marketing than

2 they did in the past.

1. The categories are broken down as follows: line operation includes

telegraph operators and messengers; construction and maintenance includes

foremen, linemen, cablemen, and laborers; and other includes supervisors,

engineers, clerical, sales and building services staff;

2. For example, see , "Behind AT&T's Change at the Top," Business Week,

November 6, 1978, pp. 114-139.
122

Western

Union

Functions:

Line Operation

(3,181)

Construction/

Maintenance

(3,984)

Other

(4,489)

27%

34%

39%

25

Percent Employees*

(Total 11,654)

50

* Total 11,654 based on all employees except officials and managerial assistants,

Source: FCC Statistics of Common Carriers, 1977 . Table 28, "Employees of

the Western Union Telegraph Company Classified by Occupational Groups, and

their Average Basic Hourly Rates of Pay as of October 31, 1977."

FIGURE IV-8: THE WESTERN UNION TELEGRAPH COMPANY, PERCENTAGE OF

EMPLOYEES BY FUNCTION

2. PMS REVENUE AND SERVICE CHARACTERISTICS

Though a distant second to the Bell System in terms of total revenue

from telecommunications, The Western Union Telegraph Company dominates the

hardcopy message side of the industry.

The 45,296,842 messages classified PMS exchanged in 1977 represent less

than one message per year for every four Americans. In sum they account for

less than .3 percent of the $43 billion in revenues generated through regulated telecommunications. The services which might be exposed to competition

by the proposed deregulation include:
123

1. Mailgram

2. Full Rate Telegram

3. Domestic handling of international public message services

4. Money Order

5. Telex/TWX (when in conjunction with PMS)

6. Personal Opinion

7. Tel(T)ex

8. Press

9. Night Letter

10

.

INFO-COM

The first four services account for 95 percent of PMS revenue, so the discussion below will focus on them.

Figure IV-9 indicates the percentage of messages in each of these

classes for 1977. By far the largest percent, 53.8, are Mailgrams. A

Personal Opinion

Tel (T) ex INFO-COM

Press

Night Letter

1.5%

Telex/TWX

3.7%

Source: FCC's Statistics of Common Carriers (computer printouts), Message

Revenues of Domestic and Overseas Telegraph Carriers Shown According

to Class of Message, Year Ended December 31, 1977.

FIGURE IV-9: DISTRIBUTION OF PUBLIC MESSAGE SERVICES VOLUME BY PERCENT PER

CLASS OF MESSAGE
124

Mailgram is accepted and transmitted by Western Union, and delivered by

the United States Postal Service. It offers next-day delivery by USPS

letter carriers. For use of its transmission network, Western Union receives

a portion of USPS revenue generated by Mailgram. In 1977, Mailgram revenue

received by Western Union was over $44 million, or about 8 percent of the

company's total revenue.

The full rate telegram is the predecessor of the other public message

services and at one time was the most common. In 1977, it accounted for

only about 9 percent of the messages. Full rate telegram service enables

any member of the public to transmit hardcopy throughout the nation for

expedited delivery. A customer may initiate a message by calling one of

three Centralized Telephone Bureaus (CTBs), presenting it over the counter

at one of 5,200 Western Union stations, having it picked up by messenger,

or by using a tieline to Western Union's message transmission network.

A copy of every telegram is retained in Western Union's records in case

the communication must be verified later. Options associated with full

rate telegram include:

• common text for multiple addresses,

• confirmation of telephone-delivered telegrams by Mailgram or regular mail, and

• a report to the sender documenting time of delivery.

Domestic transmission of transoceanic communications or "cablegrams" is

currently the second most active public message service. (Seventeen percent

of total volume compared to Mailgram' s fifty-four percent.) After these

outgoing or incoming messages are received from the international carriers,

Western Union handles them like full rate telegrams.
125

Telegraphic money order is the third largest service class, with

6 million money transfers in 1977. Through this service, the general

public may use Western Union's network to transfer funds electronically

from anywhere in the United States to any of the company's domestic

stations.

Table IV-2 presents a detailed breakdown of messages and revenue

for 1977 for each class of public message service. The far right column

shows the average amount of revenue generated per message, which is $3.24

overall. The average revenue per message for the four top services is

$4.47. Perhaps the most noteworthy characteristic of the figures in this

column is the comparatively wide range of values. For example, Western

Union reportedly generates $1.72 per Mailgram, while press messages, an

infrequently used service, bring in $13.68 per message. The rate-per-word

for press messages is lower than for Mailgram; however, press messages

are usually much longer, and this accounts for the difference in revenue.

The public message services represent an estimated 28 percent of

Western Union's $525,905,946 in annual operating revenue. Figure IV- 10

illustrates the relationship among revenue from PMS and Telex, TWX, and

nontransmission services like leasing transmission channels to the Government Services Administration and Department of Defense.
126

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FIGURE IV- 10: WESTERN UNION OPERATING REVENUE BY TYPE OF SERVICE, 1976.

a. PMS REVENUE AND VOLUME IN PERSPECTIVE

During the last ten years the proportions of revenue from various

classes of service have shifted dramatically. For example, the latest

data show that (non-PMS) Telex and TWX account for about 40 percent of

Western Union revenue while in 1967 only 9 percent came from TWX. The

PMS portion, on the other hand, dropped from about 45 percent in 1967

to about 28 percent in 1976.
128

Between 1945 and 1976, Western Union's total actual operating revenue

almost tripled. Figure IV-11 illustrates this increase over time. Corrected

for inflation, however, the figure would show little growth.

Revenue

in $

Millions

600 --

500 i400 --

300 --

200 -

100 -

YEAR 1945 1950 1955 1960 1965 1972 1976

(REVENUE) (183) (178) (228) (262) (305) (433) (525)

Source: FCC. Statistics of Common Carriers, 1976. Table 23,

FIGURE IV-11: WESTERN UNION OPERATING REVENUE, SELECTED YEARS 1945-1976

As Figure IV-12 below demonstrates, AT&T and other telephone carriers,

account for the largest portion of regulated interstate telecommunications

commerce, 83 percent. The rest is scattered among television, with 9 percent,
129

radio, with 4 percent, non-PMS telegraph, with 1.7 percent, "other" (including

COMSAT, Land Mobile, Specialized Microwave and Miscellaneous), with 2 percent,

and PMS, with .3 percent.

Non-PMS Telegraph

1.7%

Other

2%

Source: FCC. Statistics of Common Carriers, 1976.

FIGURE IV-12: DISTRIBUTION OF REVENUE IN REGULATED

TELECOMMUNICATIONS COMMERCE, 1976.

b. PMS AND INFOMASTER

Figure IV-13 provides an outline of the Infomaster system, with special

emphasis on PMS. The network can be seen as a collection of local telephone

loops and AT&T long lines, intermediate stations, and Infomaster that connects
130

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sender to receiver. Most messages (64 percent according to the FCC) that

are fed into the Infomaster network are accepted or delivered via telephone

or terminal.

Figure IV-14 illustrates the relationship of Infomaster to the entire

set of Western Union services. It is important to note that Infomaster is

over ten years old. By computer standards, that equals roughly two generations. Thus there is some question about the adaptability of Infomaster

compared with that of a central processor used by a newer carrier. One

area where Infomaster seems vulnerable is in its flexibility in receiving

input from senders. Western Union has quite strict limitations, and a large

number of potential customers for PMS have terminals that cannot be interconnected to the Infomaster network. According to Graphnet, there are an estimated one million terminals that cannot be reached by Western Union.

E. POTENTIAL COMPETITORS IN DEREGULATED PUBLIC MESSAGE

SERVICES COMMERCE

Electronic message transfer is a wide open field. Most of the new

specialized carriers primarily serve business markets. Most have capabilities for resale or transmission that could be applied to provide a

variety of services including both traditional public message services

and PMS alternatives outside the bounds of regulated telecommunications.

For example, a major portion of USPS First Class Mail service could be

provided by regulated PMS carriers.

One set of recognizable signs of potential competition for the PMS

market leads to an underground movement built on a patchwork of privately

1. Federal Communications Commission Docket No. 78-96. Reply Comments on Behalf of Graphnet Systems, Inc., dated August 1978, p. 61.
132 1 1

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leased commercial systems. For example, we found it possible to move

hardcopy text by using "services" offered by word processing firms.

This was inconvenient and expensive, but workable. We suspect that it

is also possible to purchase, on a customer walk-in or phone-in basis,

interstate transfer services that use small private computer terminals.

For the moment, these patchwork arrangements seem to signal the market

for such services rather than actual competition.

Much more significant forms of competition to potential PMS providers

may come from any number of major corporations with extensive private communications networks. For example, a large hotel chain could easily open

its message transfer system to the public and establish itself as a public

message services carrier.

However, the United States Postal System and the specialized common

carriers are more certain competitors in an open PMS market. The USPS

might capture a large share of the market with its proposed ECOM service.

For the SCCs, this deregulation will allow their first official entry

into the market.

The most important comparisions between these potential competitors

are:

• the great difference in size and capital resouces between

Western Union or USPS and the SCCs such as Graphnet, and,

• the great similarity between Western Union and the SCCs

in capability to provide telecommunications services.

For example, Western Union has about 100 times more employees than Telenet

or Graphnet, while USPS has nearly 6,000 times more. The total combined operating revenues for all of the SCCs represent only about .2 percent of the total
134

yearly revenue from regulated telecommunications commerce. The discussion

below regarding the USPS and the specialized carriers is presented primarily

to show how the services and operations of new entrants to the public message

services market would contrast with those of Western Union. More such comparisons must be made in the future.

1. THE UNITED STATES POSTAL SERVICE MAIL

The United States Postal Service's upcoming Electronic Computer-Originated Mail (ECOM) demonstration to be held in Rockville, Maryland, will be

targeted at a market for approximately 15 billion electronic message transfers. (See Chapter III for a description of ECOM, Western Union's involvement,

and other implications of the service, such as possible intrusion into data

processing industry.) The new service will be aimed initially at 750 large

corporations with computer capacity and billing volume sufficient to make

2 ... ECOM a viable alternative to regular mail. Reportedly, a significant number

of Mailgrams originate from the computers or terminals of large companies

and are transmitted to the general public. ECOM is expected to slow the

growth rate for Mailgram, but not to reverse it because a large percentage

of Mailgrams are voice-originated. Experts predict that computer-originated

message transmission will have a growing, rather than static, market as more

and more firms acquire compatible equipment. Postmaster General William

F. Bolger said that:

[T]he best estimate is that hardcopy is going to be there

in future years despite forecasts that telephone-television

connections and home printouts might reduce volume.

1. FCC. Statistics for Common Carriers, 1976 ; and FCC staff estimate of

specialized common carrier revenue, summer 1978.

2. "Postal Service Plans Test of Electronic Mail Delivery." The

Washington Post, November 22, 1978.
135

According to a newspaper article, an RCA study estimated that the current

volume of First Class Mail would rise another 4 percent by 1980, bringing the

yearly total to 100 billion—or about 1.2 pieces per American per day.

The RCA study also estimates that candidates for electronic computeroriginated messages may make up one quarter of this total. Based on these

figures, and assuming for a moment that public message services and ECOM

would vie for the same customers, USPS could expect to send 555 messages for

every message sent by public message services.

Other postal services also compete with PMS. Although volume of some

special classes is small in comparison with First Class Mail, it still

represents about five times more yearly exchanges than the entire public

message services market. For example, the Certified and Special Delivery

2 classes of Registered Mail account for about 270 million pieces per year.

2. THE SPECIALIZED COMMON CARRIERS

Table IV-3 breaks down service characteristics of AT&T, Western

Union, and eight specialized common carriers into 38 categories ranging from

transmission capabilities to service options. (See the Glossary at the end

of this report for definitions of terms used in this table.) Information

in this table will have to be further verified by the carriers. Also, the

service and technology characteristics of carriers are subject to a high rate

of change according to CCB staff interviewed. The table shows that at this

time carriers such as Southern Pacific Communications Corporation (SPCC),

MCI, American Satellite (ASC), RCA American, and Telenet have developed

1. Ibid. 2. United States Postal Service. Annual Report of the

Postmaster General, Fiscal 1977.
136

TABLE IV-3: SERVICE CHARACTERISTICS OF TEN CARRIERS (WESTERN UNION AND AT&T

COMPARED TO EIGHT SPECIALIZED COMMON CARRIERS)

SERVICE

CHARACTERISTICS WUTC AT£.T MCI SPCC RCA

j ASC

4 Telenet Tymnet

f

t Graphnet

IT&T

i CCSlUSTS Total

TRANSMISSION CAPABILITIES:

Microwave X X X X X 5 Satellite X 1 X X X 4 Coaxial 41. V 1 Open wire and other X X 2 Analog X X X X X X X X 7 Digital X X X 3 Audio/Video channels X X X 3 Voice channels X X Y X X X X 7 Facsimile channels X X X X X X 6 Low— SDeed data channels X X X X X X 6 Med'5 uc— speed data channels X X X X X X X X 8 High-speed data channels X X X X X X X ? 7 Voice-grade channels X X X X X X X 7 Telegraph-grade channels X X X 3 Wideband channels X X X X X X 6

SWITCHING CAPABILITIES:

Real- time X X X X X X X 7 Store and forward X X 2 Space Division X X X X 4 Time Division X X X X 4 Packet Switching X X X 3

STATION TYPES:

Voice station X X X X X X 6 Data terminal X X X X X X 6 Facsimile station X X X X 4 Teletypewriter X X ? X X 4

RATE STKUCiUKca:

Metered use X X X X X X 6 rxat race X X X X X X X 7 Per-message rate X X X 3

SERVICE OPTIONS

Full-period service X X X X X X X X X 9 Part-time service X X X 4 Message pick-up/delivery A a 3 Dedicated X I X X X X X X X X 9 Al] otaced 1 X 1 X X X Y Y. * -i Short-term service 1 X 1 X X X X X X X 8 1 Lcne-term service j X I X X jr A 5 ! Non-regv.lated services X I X 2 Domestic service x i X X X X X X X X 9 International service X X X X X 5 Transponder service 1 X 1

TOTAL PER CARRIER 32 32 20 25 21 18 17 18 2 8 ?

Source: Urban Institute Staff Interview with CCB Staff Summer 1978

Note: This chart must be further verified through direct industry contact
137

comprehensive telecommunications capabilites. Western Union offers every

basic type of transmission, rate structure, station type, and service option.

Its only "deficient" area is switching, where Tymnet leads everyone including

AT&T by offering every type but "space division." With "time division" and

"packet switching," which fosters heavily loaded high-speed data transmission,

Tymnet and Telenet appear to be in the vanguard of telecommunications transmission capability. Companies that would probably compete in an open PMS

market vary dramatically in size indications such as number of employees,

capital, yearly revenue, etc.; yet there is a similarity in their basic

capability to provide electronic message services.

One explanation for this might be that the cost of operating a telecommunications network has been significantly reduced by the introduction

of vastly superior forms of interconnect, transmission, and switching equipment, and consequent reductions in labor costs. Also the resale characteristics of this market may have substantially reduced, over the past few

years, the initial capital required to start and operate an electronic

message service. For example, Western Union claims to have spent recently

over $250 million on new facilities directly related to PMS. On the

other hand, Graphnet asserts that only a $4.75 million investment in owned

equipment would be required to duplicate Western Union's public message ... 2 services operation if transmission facilities are leased. Assuming these

estimates are accurate would mean that starting and operating a PMS-like

message transfer service is over fifty times less costly today than it

was when Western Union was investing in PMS facilities.

1. "Comments on Behalf of Western Union," Docket No. 78-96, p. 29.

2. "Reply Comments on Behalf of Graphnet Systems, Inc.," CC Docket

78-96, p. 41.
138

The balance of this section will focus on two specialized resale carriers rather than the general group. The discriptions will emphasize the

following: (1) information of the type that would be collected for any

carrier entering the public message services market; and (2) the current

and projected status of some actual services which are expected to

be affected by the deregulation.

a. GRAPHNET SYSTEMS, INC.

Graphnet is a 99.8-percent owned subsidiary of Graphic Scanning Corporation, a nonregulated company engaged primarily in providing specialized data

and message processing and delivery services. (Graphic is unregulated,

because it describes its primary service as data processing rather than

communications.) Graphic's Dial-A-Check service for the trucking industry

competes with Western Union's money order service. Its customized services

may also make competitive inroads into the PMS market.

In December 1976, Graphic entered into a five-year contract with

Citibank for Graphic's development and provision of customized

automated data and message processing systems and services. Among

the services offered under the agreement are the processing and

delivery of information by computer to terminals with teletypewriter, facsimile, "electronic mail" and electronic funds transfer

capabilities .1

A Graphnet service offering is known as the Fax Granr-^. This service

is advertised as an alternative to Western Union's telegram service. Facsimile service lends itself to a variety of applications, including:

Manufacturing : Engineering proposals. Drawing Bids, Specifications.

Banking : Money transfers. Credit details.

Legal: Depositions. Contracts. Wills and Trust Agreements.

Medical: Medical histories. Electrocardiogram test results.

Insurance: Policies. Claims. Medical Reports. Signatures.

1. Graphic Scanning Corporation. Prospectus dated April 13, 1977,

filed at the Securities Exchange Commission, April 15, 1977, p. 13.
139

General Business : Correct a crucial error in an ad to a client

customer. Alert law makers and public officials on legislation

critical to your business. Activate a last-minute promotion to

the trade. Critical news announcements to the media.

1

Graphnet Systems had 150 employees, claimed 20,000 customers, and generated $6.5 million in operating revenue in 1977. Sixty percent of the employees

were in sales. So far, Graphnet has invested $14.5 million in a sophisticated

computer system. The Graphnet operation could be considered a small-scale

equivalent of electronic message services provided through USPS. Although

cautious, Graphnet indicates the possibility of electronically transmitting

information that is customarily sent through regular mail or Mailgrams.

[T]he expanded network will have the capability of electronically transmitting computer and other machine-generated business data and documentation now customarily transmitted by

mail and, to a limited extent, by alternative electronic means

such as mailgram, and that a potential market exists for such

a service. However, any attempt to implement and market this

service on a larger scale would be dependent on completion of

the expanded network described above, the generation of substantial additional capital, a favorable regulatory environment

and favorable competitive conditions. Accordingly, no assurance

can be given that Graphnet will be able to market such service

or, if such marketing commences, that it will prove profitable.

Western Union is the dominant factor in this market.

2

According to Graphnet, the Commission's delay in authorizing it to

handle inbound international messages has hampered its efforts to expand.

Graphnet officials cite about $500,000 in lost revenue and a $14 million

loss to stockholders within the first two days of the FCC action nearly

two years ago. Essentially, Graphnet argues that it has been curtailed

3 in its ability to draw financing to support network expansion.

<g)

1. Graphnet promotional material. "Announcing the FaxGram . The

Faster Gram."

2. Graphic Scanning. Prospectus, 1977, submitted to the Securities

Exchange Commission, p. 13.

3. "Reply Comments on Behalf of Graphnet Systems, Inc.," Docket

No. 78-96, Appendix D, pp. 3-6. See also Appendix G.
140

Figure IV-15 illustrates Graphnet's current system, which uses leased

facilities. This system uses a variety of delivery and acceptance modes,

and can process raw input from customers into preprogrammed formats according

to their instructions. A number of ancillary operations are also possible.

The system can: (1) check the accuracy of individual operators who submit

raw information, (2) monitor characteristics of current input, and (3) produce monitoring reports about daily processing. In addition, the company

attempts to anticipate customer requirements for interconnection of new

terminals, and Graphnet officials report they have developed approximately

90 equipment interface packages.

Unlike established common carriers, which have developed networks which required their users to adapt their communications

needs to the operating criteria of such networks, Graphnet's

system . . . affords each customer substantial flexibility to

satisfy his particular communications requirements.!

Of course, one of the main determinants of expanded services will

be pricing. Figure IV-16 reproduces a chart used by Graphnet to advertise

its services. It shows a price comparison between Graphnet and Western

Union messages originated by Dataphone, word processor (CRT), computer, or

teleprinter and delivered by messenger. According to the chart, this subclass of Fax Granr5^ service is less expensive and faster than Western Union's

telegram service. Note, however, that this is simply a price comparision

from a consumer's viewpoint.

1. Graphic Scanning Prospectus, op cit . , p. 13.
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figure iv... FAX GRAM -SERIES

3

COST COMPARISON WITH TELEGRAM

FAX CRAM 3A

Oriyinalcd by: UMjphone, CRT.

Compolcr, Teleprinter MESSENGER DELIVERY

17.85

10.35

121. 65 .

120.25

LINES 2

words 20 40

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140

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DELIVERY WITHIN

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WITHIN 5 HOURS .

16

160

IB

180

30

300

Source: Graphnet Promotional Material, Summer 1978

FIGURE IV- 16: COST COMPARISON OF FAX GRAM^ AND TELEGRAM

b. TELENET COMMUNICATIONS CORPORATION

As we mentioned in Chapter III, Telenet's parent companies are investment

1 firms and securities brokers. The company's 1977 prospectus mentions that it

has incurred substantial losses because of investment in new construction.

Regardless, Telenet stock is termed "very steady considering the age of the

company," and it has amassed assets of $6.5 million.

1. Note that General Telephone & Equipment, the nation's largest independent

telephone company, has announced it intends to purchase Telenet. This action

would substantially increase this specialized resale common carrier's resources.
143

The company is headquartered in Vienna, Virginia, near its central

computer facility. In 1977, it had 114 employees and 165 major customers in

addition to customers who subscribe for data transfer on an hourly basis. At

last report, Telenet generates about $1.5 million of revenue per year.

Telenet has concentrated on providing low-cost data transfer services. Its

public data network serves 81 cities and is being expanded yearly. Most

terminals or computers interfacing with its system operate up to 1,200 bits

per second, but its leased network is designed to accommodate transmission

speeds of up to 56,000 bits per second.

Telenet has made a contribution in the area of interconnecting computers

and terminals that operate at different speeds and according to different

protocols. The company is a pioneer in packet switching. It started to

build a packet switching system for its leased transmission facilities in

late 1972, tested the network in 1975 and began operation in 1976. (Also,

see Chapter Ill's section on research and development funding.) Products

such as Telenet's TP4000 Host/Terminal Interface Processor incorporate this

new technology. The company is also associated with advances in data concentration that allow more messages to be transmitted per line per minute.

For example, Telenet and Digital Communications Corporation are working

together to develop a family of microcomputer-based systems called "Telenet

Processors." These machines pack and concentrate messages before transmission to improved transmission efficiency.

Telenet appears to have taken a unique approach to the organization

of its network. (See Figure IV-17.) It has a distinctly regional or

decentralized character, with major computerized switching centers, known

1. Telenet Corporation, Prospectus, submitted to the Securities Exchange

Commission in 1977. All information presented here is subject to further

direct verification with Telenet.
144

# Class I Central Office

• Class 2 Central Olflce O Class 2 Central Otllce scheduled lor Installation through March 1976

(I) Tsi.iixliorCiMi I >en,ie« Cliu I iKllllln schadulitf Im

Inilillslion t»y March 1970

To Europe

Source: Telenet Promotional Material, received at The Urban Institute

Summer 1978.

FIGURE IV-17: THE TELENET NETWORK, 1977

as Class One offices, around the nation. This characteristic could be a

vital asset in the future. In a report to the Commission on electronic

message systems, Kalba Bowen warned the Commission that there may be a

sudden surge of license applications to CCB for small computer terminal

interconnects, such as the surge that occurred when CB radios became

1. Kalba, Konrad K. , et al . Electronic Message Systems: The Technological Market and Regulatory Prospects, April 1978.
145

popular. Introducing many new computer devices on the nation's long

lines system could call for operations and technologies to control local

and regional input into the system. Telenet's control centers seem to

fit that need. This does not, however, mean to imply that the nation's

long lines system is a static resource. Other companies would also be

entitled to request Commission authorization to build such facilities.

147

V. A LOGIC FOR THE EVALUATION

A. OVERVIEW

A logic for the evaluation is organized around the seven main events

we expect to occur during the proposed deregulation. The actual intervention

is defined by activities which are expected to occur during the first three

events. Event I activities might be characterized as preparatory; e.g.,

completing a review of legal authority for deregulation. Event II concerns

obtaining Commission authorization for PMS deregulation. The first major

activities occur during this phase: (1) approval of the Memorandum, Opinion,

& Order (M0&0) , which announces the policy change and explains the Commission's

rationale for deregulating PMS; and (2) approval of the final rulechange.

Event III deals with streamlining Commission procedures for handling PMS

filings.

As of January 1979, most Event I activities have occurred. However,

the time schedule planned for revising the PMS rules has slipped. Although

the M0&0 was approved by the Commission on January 25, 1979 (an Event II

activity) , the revised draft rulemaking has not yet been scheduled for

submission to the Commission (an Event I activity) . The draft of revised

47 CFR rules and regulations is scheduled for release within 90 days of

the Commission's approval of the M0&0. These rules are expected to deal

with market entry and exit as well as business operations while a firm is

actually engaged in PMS commerce. The Commission is expected to consider

1. The term deregulation is used here to denote a change in policy,

practice, and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
148

adopting a revised rulemaking after an analysis of comments received during

the public notice period.

Event IV involves carriers applying to the Commission to enter the PMS

market. Although carriers may apply as soon as the policy change is approved,

interested firms are not expected to act until they have had an opportunity

to review the actual rulechange. Therefore, a more practical time for new

entrants to begin to market public message services is probably March or

April 1979, assuming that presentation of the draft rulechange before the

Commission occurs in February. During Event V, staff of ETIP, the ETIP contractor, and CCB plan to monitor commerce as PMS services and operations

change

.

Events VI and VII involve actual observation of commerce, analysis

of evaluation findings, and transfer of knowledge gained as a result of

monitoring the effects of the deregulation. Both of these events are

already under way. They are portrayed as final stages of the evaluation

since these types of activities will increase and step into the forefront

toward the end of the project. Also, in actuality, products occurring at

any time could be either subjects of analysis or results of analysis by

evaluators. Hopefully, these analysis and information transfer activities

will be timely in terms of the information needs of those expected to use

evaluations findings and in relation to real world events that might affect

the deregulation and evaluation activities.

The hypothesized effects of the intervention would affect (1) Commission process (for example, workload) and (2) the commercial sector and

innovation. In an initial attempt to set boundaries for this proposed

evaluation, a preliminary model for ongoing measurements and a preliminary
149

measurement set have been developed. The model is presented in Chapter VI of

this report and is illustrated with hypothetical examples, such as the way one

would track innovation in terminal equipment used for public message services.

Although measures outlined presently appear feasible at some level of rigor,

more work is needed to determine the degree of feasibility and rigor possible.

As already noted, we expect to update the model as industry trends

develop and user needs are better defined. Specifically, we expected to make

revisions as the intervention progresses and as we validate the model and

measures with industry and others. Events I through VI all conclude by reassessing the potential for useful evaluation. This step should ensure that

measures and comparisons assess agreed-upon goals, and that activities achieve

both interim and downstream objectives. Each event is discussed below.

B. EVENT I: COMMON CARRIER BUREAU DRAFTS AN M0&0 AND RULEMAKING INTENDED

TO END WESTERN UNION'S MONOPOLY, OPEN PUBLIC MESSAGE SERVICES

COMMERCE TO COMPETITION, AND REDUCE FUTURE PMS REGULATION

1. EXPECTATIONS

In general, the Common Carrier Bureau would like to see a successful

resolution of the Western Union Monopoly Inquiry. The Commissioners' vote

to authorize the findings and evaluation of the new rules and requirements

by those involved will determine success.

2. ACTIVITIES

Event I did produce a draft M0&0 to end the Western Union public message

services monopoly. Next, revised rules and requirements for the eight most
150

relevant Parts of 47 CFR will be promulgated. (See Chapter IV for a detailed

description of relevant Parts of 47 CFR.) When authorized by the Commission,

the draft Memorandum, Opinion, & Order, is expected to formalize a substantive

shift toward competition in FCC/CCB official policy and rules for public message

services.

The M0&0 will probably not attempt to define public message services.

This is to permit as much leeway as possible for new types of technologies

and services to enter the market. It is most likely that the final rulechange

will contain the revised definition of public message services. All references

to "telegraph" are expected to be deleted, and the public, nonexclusive, private

handling, and hardcopy characteristics of public message services will probably

be emphasized.

During Event I, representatives of relevant CCB branches participated

on a committee which conducted preliminary analysis of Parts of 47 CFR. This

process helped to point out areas where further legal research was required.

Also, early participation by each branch which will be affected by the rulechange should help to facilitate implementation of a streamlined CCB process

for administering those rules (Event III)

•

As of this writing, the specific and final changes of 47 CFR in regard

to PMS are not known. Therefore, a comparison of the draft rulechange and

the original PMS rules cannot be presented. We can, however, contribute to

a better understanding of the types of changes proposed and the implications

that specific changes might have for the outcome of the deregulation. Table

V-l shows how three sections of Part 63 might be compared with hypothetical

requirements for public message services carriers. The first three columns

of the table list current stipulations: 63.01 applies to information required
151

TABLE V-l: HYPOTHETICAL STIPULATIONS FOR PMS CARRIERS COMPARED TO CURRENT

CONTENT REQUIREMENTS IN SECTIONS OF PART 63 OF 47 CFR

63.01 Stipulations Re:

Current Information Required

in Typical Applications

To Extend Facilities

Information Currently

Required From Carriers Information

Required

From PMS

Carriers

For Extensions

Involving Small

Projects

(per 63.03)

For Supplementing

Facilities

(per 63.04)

a. Name and Address X X X

b. Location of Corporate Organization X X X

c. Name, Title and Address of Official X X X

d. Statement of Common Carrier Status X X X

e. Statement Regarding Extension into

Territory Not Currently Served

Statement Regarding Type of Services

X

X X

X

X *

f . Points Between Which Proposed

Facilities Located X X X

g. Description of Existing Facilities,

Specifically Channels X X

h. Description of Proposed Facilities, —Channels —Wires, Conductors, Coaxial Cables —Classes of Offices —If Telegraph, Method of Pickup

and Delivery X

X X

i. Present and Estimated Future

Requirements —Rerouting Contemplated —Circuits —Traffic Load Trends

V

X

X

j. Map or Sketch Showing —Route —Ownership Structure —Facilities to be Removed —Cities, Towns, Villages —Route Mileage —Important Operating Centers —State Boundary Lines —Special Typographical Features

X X

k. As Applicable, —If Construction: The Cost Estimate —If Leased: Terms, Lessor, Rental —If Purchased: Vendor, Assets —If Other: Type, Terms, Description

X

X

X

X

X

X

X

i

i 1. Factors Showing Public Need X

i

i m. Economic Justification, e.g., Added

Revenue and Cost X

!

n. Other Services Available; Why Existing Facilities Not Adequate X

1

o. Proposed Tariff Charges/Regulation X i p. Accounting Methods Explanation and

Proposed Method Performed X X

I

i q. Statement About Whether New Construction Requires Environmental

Impact Statement X X

* Revised definition of public message.
152

from carriers for authorization to extend facilities; 63.03 contains stipulations for extension of facilities for small projects (under a certain dollar

amount); 63.04 contains stipulations for supplementing facilities. As you

can see, the second and third columns contain fewer stipulations than the

first. However, even for extensions involving small projects, stipulations

1., m. , and n. apply. These require statements on public need; economic justification; and the inadequacy of current facilities. These stipulations

would be important under monopoly conditions. They hinder companies from

entering a market. A PMS rulechange might delete these requirements; if so,

the burden on the regulatee would be reduced.

Figure V-l illustrates the activities directly associated with Event I.

From left to right, the solid black line shows the flow of activities from

one event to the next. The broken line illustrates measurement and analysis

tasks, and information feedback to potential users of evaluation findings.

Likely participants are shown in parenthesis next to each numbered activity.

All CCB Branches, m. in the Participants Key, refers to the representative

from each CCB branch participating in an Evaluation Group (see Event II). The

identity of other participants should be self explanatory. A similar descriptive chart has been prepared for each of the other major events which follows.

These charts outline our best understanding to date of the plan for the evaluation and represent a starting point for development of the evaluation design.

Since most of the activities of the deregulation are projected and

therefore tentative, the sponsors have singled out some possible occurrences that could alter the course of the deregulation. As a rule, these

occurrences might seriously impair or even stop the progress of the deregulation. For this event, three are: (1) a finding that the Commission does

not have the authority to deregulate; (2) a finding by ETIP's contractors
153

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154

that expectations for the deregulation are implausible as measured by ETIP

criteria (see Chapter VI), and (3) an FCC finding that the draft rulemaking

violates Commission mandate or policy. The first two problems did not occur;

and the third is not expected to occur.

3. TIMEFRAME

Although all Event I activities were expected to be completed by January

1979, activities 8, 9, 11, 13, and 15, must still be accomplished.

C. EVENT II: AFTER PUBLIC NOTIFICATION, COMMISSIONERS AUTHORIZE

CCB REVISED PMS RULEMAKING TO GO INTO EFFECT

1. EXPECTATIONS

If the Commissioners' reaction to the rulemaking is positive and if the

notice period does not generate major conflicts, the Common Carrier Bureau

will have been successful. Ultimately, both ETIP and CCB will judge the

success of Event II by its actual downstream effects on the structure of PMS

commerce.

2. ACTIVITIES

The Commissioners will determine Event II activities because they alone

make all substantive changes in official policy and must authorize the M0&0

and rulechange. The Commission process for public notice, comment, and review

of proposed new rules will be the first opportunity for broadbased scrutiny

and reaction to the deregulation. (See Chapter IV for a description of this
155

process.) During this stage, it is possible that the M0&0 will be challenged.

Another Commission deliberation could result, £r the courts could "restrain"

the Commission from putting the rulemaking into effect.

Also, by virtue of its association with the project, ETIP will become

generally visible in telecommunications for the first time and can be expected

to answer questions about its role in this project. The Common Carrier Bureau

will be integrally involved in this event as well, examining comments during

the public notice period and supporting the Commission's decision-making

process.

A sample measurement set for the evaluation will probably be made available

for review by organizations that comment on the proposed rulemaking. Their

suggestions and information needs will thereby be taken into consideration

during the evaluation design. Table V-2 presents a draft of such a measurement

set. The columns on the table show expected events of the deregulation, issues

that might be measured, one or more possible measures for each issue; and

the source of measurement information, out of four possibilities, that would

probably be used. This table illustrates how ongoing decision making about

what to measure, how to measure, how much rigor of measurement and analysis

is needed, etc., depends on the actual occurrence of expected events. We

hope, by this process, to assure that measurement information is useful and

that resources for evaluation are not wasted. Comments received during the

public notice period will indicate industry's willingness to participate in

this evaluation. Their cooperation will be important to our data collection

effort. However, the Commission will maintain legal authority to require

certain information.
156

TABLE V-2: SAMPLE SET OF MEASURES

Expected Events

of PotentiallyMeasurable

Source (s) of Measurement Deregulation Issues Measures Information

Event III has

occurred; CCB streamlines

What minimum reporting requirements and

controls on rate of

• Ongoing monitoring

of deregulation

• Comparison of in-

• Indus try /FCC

• Indus try /FCC process return are necessary

in order to manage

and learn from the

deregulation?

tent of rulechange

with actual effects

ti What regulations

should be in force

• Ongoing monitoring

of deregulation

• Industry/FCC

during transition to • Reactions of car- • Indus try

competition? riers, including Western Union

it Is the public

interest adequately

• Survey of consumer reaction

• Consumers

protected? to the policy

change

• Complaints

• Monitoring of aggregate PMS and alternates

available

• Consumers

• Indus try /FCC

Event IV has

occurred;

carriers enter

PMS market

Does PMS deregulation encourage

technological innovation in market?

• Survey of PMS technology

• Analysis of rulechange

• Industry/FCC

• FCC

Event IV has

occurred;

If deregulation

does not lead to

• Survey of com- munications firms• Industry

carriers do competition, what remaining outside

not enter the

PMS market

are the reasons? • Survey of consumers who opt not

t-n hny PMS

• Consumers

Event V has occurred;Will new and improved PMS be

• Array of services

available

• Indus try /FCC

observed

change

available to the general public?• Types of customers • Industry/ Consumers

Event V has

occurred;

Will cost of PMS

be reasonable?

• Inventory of prices

• Description of pric-

• Indus try /FCC

• FCC observed

change

ing requirements

Event V has How adequate are • Survey of cus- • Consumers

occurred; new public message tomer satisfaction

observed

change

services? • Comparison to satisfaction with

alternate services

• Consumers/

PMS and

other

Event VI has What is a rigorous • Commission defini- • Indus try /FCC

occurred;

systematic

evaluation

definition of PMS? tion compared to market realities
157

Details of Event II description are illustrated as Figure V-2, which

employs the same conventions as Figure V-l. Some measures for Event II

products include an estimate of the match between policy intent and the actual

rulechange, an estimate of the match between anticipated and actual reactions

of regulated commerce to the rulechange, and a calculation of the percentage

change of significant PMS rules in 47 CFR after the rulemaking is approved.

Table V-l illustrates under Event I activities some hypothetical revised rules

for PMS and shows in microcosm how revisions and deletions of stipulations

from Parts of 47 CFR might be tracked. Table V-3 presents hypothetical findings for an actual measure.

During Event II we can also begin to address most of the conditions that

could undercut the potential for full evaluation of the effects of the deregulation. We recommend that an Evaluation Group of representatives from the

CCB, ETIP, and the ETIP contractor be formed. This group would meet regularly to accomplish such tasks as establishing priorities for transferring

TABLE V-3: PERCENTAGE CHANGE IN 47 CFR RULES AND REQUIREMENTS'

(Hypothetical)

Percent Stipulations Percent Stipulations Number of

Part of CFR Revised Deleted Stipulations

21 10 500

35 7 90

41 20 10 10

42 5 2 900

43 10 10 10

61 10 3 200

63 4 63 120

64 30 10 80

(a) Parts applicable to current PMS carrier; see Chapter IV for a description of each relevant Part.
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159

information from the evaluation, and overseeing the distribution of evaluation

resources. Evaluators should also begin developing criteria for judging the

significance of observed changes in relation to the Commission's mandate and

CCB and ETIP goals. For example, for purposes of the evaluation, what yardstick

of customer satisfaction should be used to measure whether public service

standards used by different carriers are adequate? Decisions about criteria

require a broad consensus of opinion and therefore discussions should begin as

soon as possible.

Because resolving most evaluation problems will require specific measurement information and other data, a Design Group should be formed to collect

information needed for project administration decisions. This Design Group

would meet regularly and would receive direction from the Evaluation Group.

Common Carrier Bureau staff, ETIP staff, and ETIP contractor staff would make up

this group. The primary benefit of this composition would be the exchange

of ideas about how to proceed. The ETIP contractor would undertake most applied tasks (such as data gathering)

.

3. TIMEFRAME

Event II started in January 1979. The proposed rulechange must be

presented before the Commission within 90 days after the approval of the

M0&0. The public notice period for new rules can take from 30 to 45 days,

and congressional legislation requires the Commission to defer final

authorization for an additional 23 days. Therefore, Event II may require

from two to five months to complete.

1. A 30-day public notice period includes 20 days for comments and 10

days for reply comments. Since the PMS deregulation is an important action,

Commission staff will probably have to designate a 45-day public notice period

(30 days for comments; 15 for reply comments).
160

D. EVENT III: COMMON CARRIER BUREAU STREAMLINES THE PROCESS FOR

ADMINISTERING ONGOING PUBLIC MESSAGE SERVICES REGULATION

1. EXPECTATIONS

CCB's success criteria for this event are the following (a) is the operation modified in a manner consistent with policy intent; (b) is the new

operation likely to lead to difficulties among carriers, such as disputes

about fair process; and, (c) will the new operation reduce staff allocations

to PMS transactions?

The ETIP criteria for Event III success focus on the question of whether

the new operations for PMS transactions will in fact mean less costly and

less intrusive ongoing regulation. If this is the case, ETIP will want to

determine how the operation was streamlined and how to determine what effects

the modified operation has on PMS commerce (an Event IV activity).

2. ACTIVITIES

The day-to-day activities of CCB staff who process public message services

applications are expected to change. The Bureau's Domestic Facilities Branch,

Tariff Review Branch, and Complaints and Services Standards Branch will probably

be the key participants in Event III. Common Carrier Bureau management is

expected to provide guidance and direction to CCB branches, consistent with

the intent of the rulemaking.

An effort to modify conventional Common Carrier Bureau operations will

probably stimulate innovative approaches for processing public message services

transactions. The practical benefits expected include more comprehensible

application forms, simpler formats for required reports from carriers, and
161

definitions and protocols for processing carrier and consumer filings. Checklists and criteria for branch-level decisions regarding applications, and

procedures for resolving disputes between carriers and complaints from PMS

customers might also be improved.

Event III could present difficulties or opportunities for the project.

Implementing new operating practices is not always a pro forma exercise.

The literature about federal policy initiatives refers to some situations

where implementation activities have not resulted in changed agency operations

considered consistent with the new policy. In some instances, the policy

could not be implemented at the operations level. At CCB, this is not expected

to be a problem. Branch staff seemed eager to identify ways to streamline

the process.

The description elements for Event III are illustrated in Figure V-3.

3. TIMEFRAME

Some of the activities for Event III are already under way; representatives of the relevant CCB branches participated on the rule analysis committee. During the committee meetings, the subject of how to implement the

changes in branch level operations frequently arose. This type of branchlevel participation should promote a smooth transition from policy intent,

as expressed in the rulemaking, to regulatory process, as indicated by plans

and protocols for PMS transactions. The bulk of activities for this event

will probably occur only after the Commission has authorized new rules and

requirements for PMS. Thus, assuming the draft rulechange is submitted

before the Commission in February, the branches will begin to complete plans

for implementing a revised PMS regulatory process in March or April 1979.
162

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163

E. EVENT IV: CARRIERS AND OTHER INTERESTED BUSINESSES SUBMIT

APPLICATIONS TO OFFER PUBLIC MESSAGE SERVICES

1. EXPECTATIONS

Although it is the keystone of the deregulation, Event IV is beyond

direct control of either the Commission or ETIP. If new carriers and businesses currently operating as common carriers apply to enter the public

message services market, the deregulation will fail to accomplish a major

goal—structural change and service improvement in PMS commerce.

CCB expects the establishment of an open PMS market and approval of the

rulechange will prompt one or more companies to pursue new customers in the

market. Also, within the timeframe for transition and limitations, specified

in the Commission's rulechange, Western Union may opt to discontinue or alter

the public message services it now provides. In any case, Western Union will

continue in public message services through its association with the United

States Postal Service. (See Chapters III and IV.)

ETIP plans to use measurement information about Event IV to start tracing

probable effects of the deregulation on commerce, particularly in the area

of technological innovation. In addition, measures of modified Common Carrier

Bureau operation will be used to determine the effects of efforts to streamline

regulatory process: Did the deregulation make it easier for carriers and

services to enter the public message services market?

2. ACTIVITIES

The activities for Event IV will focus on a number of decisions that

will be made by members of commerce, for example:
164

• Should PMS market potential be assessed?

• Should an operation for servicing PMS customers be designed and

tested?

• Should raw material for offering public message services be

purchased?

• Should applications to enter the PMS market be filed with the

Commission?

As the list indicates, a decision to enter PMS is weighed by company management against the "cost" of regulatory requirements and against considerations

related to profitable enterprise (e.g., market potential). Event IV also

involves activities of attorneys, market analysts, equipment suppliers, state

public utility commissioners, and the AT&T system representatives. All of

these groups are very likely to participate in launching new public message

services enterprises.

The combination of activities will probably vary with each company

according to its prior experience with telecommunications. Companies with

well-developed telecommunications computerized message switching systems,

or facsimile capability, and experience with the Commission may be easily

capable of offering these services. Other companies with similarly impressive

technical capability may have more difficulty entering the PMS market if they

lack experience in operating as a common carrier.

Common Carrier Bureau activities are expected to produce station licenses,

tariff filings, and other documents that will be required for entering open

PMS commerce. These documents and certificates—evidence of competition in

PMS commerce—will result from applications filed with the Common Carrier

Bureau in response to Event II and processed under the Bureau's modified regulatory operation, developed as part of Event III.
165

In another Event IV activity, ETIP and its contractor will take measurements of the regulatory process for PMS applications. We will use measures

established during Event III. Similarly, data we gather about carriers

entering the market should form the foundation of measures for impacts on

market structure that we expect to observe during Event V.

Description elements for Event IV are presented in Figure V-4.

3. TIMEFRAME

As we mentioned, market entrants could start offering public message

services around March or April 1979. We expect Event IV to extend over a long

period of time because businesses will probably be entering the public message

services market at various times throughout the evaluation.

F. EVENT V: PUBLIC MESSAGE SERVICES MARKET STRUCTURE

IS OBSERVED TO CHANGE

1. EXPECTATIONS

Event V is expected to monitor a change in the structure of public message

services commerce. The number of companies in the business, the services

available to customers, the prices for services, the facilities and equipment

used to provide services, and share of the market garnered by each company

supplying public message services will indicate the change. This event should

focus on the realization of ETIP's goals and the Commission's intentions in

opening PMS commerce.
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2. ACTIVITIES

PMS customers are primary participants in Event V, because their purchases

are essential to successful commerce. If customers purchase public message

services, revenues might be sufficient to promote innovative services. The

deregulation might also generate new customers for some established public

message services, such as money orders, and thereby bolster PMS commerce.

It is also possible that customers will initially reject new public

message services offerings, or that the deregulated PMS market will simply

lead to uncontrolled anti-competitive practices by the well endowed established carriers. For example, a short period of open competition in public

message services might be followed by virtual monopoly if another carrier

captures the market; without regulation, the Electronic Computer-Originated

Mail service proposed by the USPS might supplant fledgling public message

services carriers.

During Event V, ETIP and its contractor will trace changes in commerce

that occur as a result of Event IV activities. The data generated through

these activities will provide in turn the basis for analyses in Event VI.

The evaluators are expected to work closely with CCB staff and use existing

data for tracing activities, but information from companies, customers,

equipment manufacturers, etc., is also expected to be required. The Evaluation and Design Groups will probably be in contact with participants in

public message services commerce.

Figure V-5 illustrates the description elements for Event V.

3. TIMEFRAME

Event V could begin as early as March or April 1979.
168

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G. EVENT VI: SYSTEMATIC EVALUATION AND RESEARCH DEMONSTRATES

IMPROVEMENT IN PMS COMMERCE

1. EXPECTATIONS

One of ETIP's major expectations is that Event VI will supply evidence

for the hypothesis that removing of regulatory barriers leads to technological

innovation. ETIP recognizes that innovation in commerce can take a variety

of forms (e.g., variations of established technological applications, or original applications of new technologies). (See also Figure II-l which illustrates

some experimental technologies that could be used to provide public message

services.) The most important innovations will be those that serve the longterm general public interest.

ETIP also expects to learn how evaluation process and method apply to

the development of an administrative experiment and to the identification

of "generic" regulatory issues.

Though ETIP and CCB expect somewhat different products, both expect

to define success by the credibility and usefulness of these products.

2. ACTIVITIES

The main participants in Event VI will be ETIP and its contractor.

They will apply criteria for success to the combined data collected during

the deregulation, Events I to V. The task is expected to have three components. The first establishes whether a commercial effect (or anticipated

event) has occurred and whether it can be linked to the deregulation. If

1. Criteria for success are expected to derive from the Commission

mandate for orderly, safe, and affordable telecommunications services, and

ETIP criteria for a successful administrative experiment (see Chapter VI).
170

the link can be established, the second component compares data gathered about

the actual event with the hypothesized expectations about the event. These

hypothesized expectations are based on the criteria for judging the significance of observed changes previously agreed upon by ETIP, the ETIP contractor,

and the Commission staff. The third component is expected to establish whether

information gained from the evaluation will lend itself to generalization.

This event represents ETIP's influence at the Commission. Since CCB evaluation of a major policy change is rare, ETIP's influence should result in an

improved evaluation process for the Commission.

Specific activities for Event V will produce evaluation information and

involve: collecting and synthesizing data; modeling and analysis; drafting,

typing, editing, and reviewing reports; designing briefings; presenting

briefings and reports; etc. Analyses undertaken in Event VI are expected

to build on the type of measurement application illustrated in Chapter VI,

Figure VI-4, Expectations For Measurement Associated With The PMS

Deregulation.

ETIP has defined some other analyses that should culminate during

Event VI. These range from assessing deregulation effects on CCB and the

Commission and developing a model that describes relationships between

regulatory process and industry performance, to making determinations

about how deregulation leads to competition. If the project stalls, we

will attempt to explain why the deregulation did not result in competition

or technological innovation.

Figure V-6 illustrates the description elements for Event VT.
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172

3. TIMEFRAME

Preparation for Event VI has already begun. The recording, tracing, and

reassessing of evaluation potential associated with each event should produce

most of the data that will be needed for Event VI analyses. A date for event

completion has not been determined, and will be contingent on the development

of the project. A rapid negative or positive reaction from industry would

result in an earlier completion date. Although the timing in both cases would

be similar, Event VI products would be quite different. Event VI activities

will not be completed as quickly if the change in regulatory process and commerce is slow, but worth tracking. However, Event VI activities are expected

to be timely in relation to actual changes associated with the deregulation

and to the information needs of those who will probably use the evaluation

findings.

H. EVENT VII: CCB AND ETIP TRANSFER KNOWLEDGE GAINED FROM EVALUATION,

AS EVIDENCED BY PRODUCTS AND USEFUL APPLICATIONS OF FINDINGS

1. EXPECTATIONS

The Common Carrier Bureau expects that evaluation information from Event

VI will be useful to general CCB administration of common carrier regulations,

For example, the information might be particularly well applied to internal

management operations, such as procedures for developing a rulemaking.

ETIP is interested in using evaluation feedback to refine its approach

to administrative experimentation and to transfer knowledge to the universe

of experts and decision makers in the fields of commercial policy, regulatory

policy, administrative experimentation, or evaluation. ETIP also expects
173

to use evaluation findings in marketing its approach to other agencies that

might wish to establish an ETIP administrative experiment.

2. ACTIVITIES

CCB and ETIP will share responsibility for Event VII knowledge transfer

activities. ETIP and its contractor are expected to support the following

activities:

• ongoing identification of real users of evaluation information,

• final preparation and distribution of evaluation information,

• assessment of usefulness of distributed materials, and

• follow up response to questions and comments which the distributed

materials provoke.

Reports resulting from the evaluation are expected to cover topics

such as:

• impact of deregulation

• policy setting process description and analysis

• rule change process and steps in deregulation

• interim status

• requirements for regulation in a new competitive market

• implementation (transition to competition)

• regulatory system performance

• barriers to deregulation

• model solutions to generic problems

• techniques and methods for managing regulatory change

These reports should answer specific questions on the progress of the deregulation and substantive evaluation findings and may help to build a data base
174

which could be applied to other areas of the telecommunications industry and

to industry dynamics in general.

Figure V-7 presents the description elements for Event VII.

3. TIMEFRAME

Event VII is under way as this document and others that feed back evaluation findings show. Event VII will end when the last evaluation product has

been completed as per the terms of the ETIP/FCC working agreement.
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VI. AN ASSESSMENT OF THE

POTENTIAL FOR USEFUL EVALUATION

A. OVERVIEW

In this chapter we discuss many potential targets for evaluation findings,

and ask how measurement and analysis effort should be allocated among these

areas. In this initial effort to define the evaluation, we will (1) identify

a number of measurement information needs (Section B) and (2) construct a

preliminary model for organizing measurements, to show how specific measures

might be applied (Section C) . The chapter concludes with a brief summary

of findings to date on the potential for useful evaluation of the proposed

deregulation of PMS (Section D).

B. NEED FOR MEASUREMENT INFORMATION

This section identifies the individuals and organizations that are

expected to use evaluation information (i.e., the "market" for data on evaluation progress)

.

1. ETIP AND FCC

The sponsor class, composed of CCB and ETIP staff, is closest to the

actual evaluation. Together with officials at FCC and the Department of Commerce, they control resources used to shape activities. As sponsors, ETIP

1. The term deregulation as used here denotes a change in policy,

practice and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
178

and CCB share a need for rather specific data that can be used to guide the

project's ongoing activities.

ETIP and CCB expect to gain measurement information not only for internal

administration of the project and general performance monitoring, but also

for specific interests of their own. For example, ETIP wants data that will

help to define the relationship between regulatory processes and commercial

innovation. We have also detected a substratum of important information needs

in the CCB; for example, information on terminal equipment might help the

CCB to construct a system for differentiating "intelligent" communications

terminals from data processing equipment. Figure VI-1 illustrates other potential uses for information among different groups within ETIP and the

Commission.

Although measurement information needs such as these are very challenging,

they are small compared with the larger problem of the Commission's overall

measurement information shortage. There is virtually no formal framework

for comprehensive measurement of the effects of regulation on telecommunications

commerce, and there are more measurable issues that might be tracked than

there are evaluation resources. As we mentioned earlier, an Evaluation Group

will have primary responsibility for allocating these resources. However,

we welcome any suggestions that might contribute to a truly representative

measurement model. Developing a feasible measurement framework that will

provide useful information at a reasonable cost is a continuing task of this

effort.
179

PMS DEREGULATION SPONSOR STAFF

Measurement Information

For Sponsors' Interests

ETIP Regulatory

Process Effects Staff

Roland Welti

Dan Fulaer Bud Llbnan

NATURE OF INVOLVEMENT

IN PMS

i Assists In the evalua1 tlon design and monl-

~[ torlng of effects of

I PMTS deregulation

USES OF MEASUREMENT DATA FOR ETIP

• To discover how changes

In bureaucratic structure

and regulatory agency procedurea can encourage

the introduction of Innovative technology

Into the Marketplace

• To Identify links between regulatory

agencies, industry, government -protected

entities and the public

In order to Improve regulatory operations

• To develop an evaluation methodology which assures objective meas- urement for participants

and onlookers

• To determine optimum

methods and processes

for monitoring and evaluation of an ad- ministrative experiment

• To determine generic

Issues across regulatory agencies and whether or

not standard methods of

resolving Issues are

feasible

• To increase responsive

ness of the regulatory process to changes In

I ndus t ry , t echnology

,

and publ Ic need

CCB Program

Evaluation and Policy and

Rulea

Len Sawlckl Dave Irvlo Jim Smith

' Administers and

__^ supports CCB

i Branches and Groups ~HUSES OF MEASUREMENT DATA FOR POLICIES AND RULES

• To provide better • To devise an efficient regulatory problems clarification of the monitoring system for among CCB staff In- definitive bounds of the effects of CCB in- volved in specific regulation fluence in the market- areas of Investigation

• To test the continued place

desi rabl 1 1 ty of the • To test feasibility case-by-case approach of *'comral ttee" approach

to policy making In to facilitate Informa- today's marketplace tion flow about generic

-aw, TARIFF REVIEW AND

1 TARIFF PROCEEDINGS

Frank Patel la Judy Nitsche

Ken Levy

Dan Harrold

[Reviews "pet i tions for

| compI lance with the _jlaw a FCC rules and (regulations, regarding

irate regulation. Inter- 'carrier rates, fair 'competition, and 'economic viability of

'the marketplace

USES OF MEASUREMENT DATA FOR TARIFF REVIEW AND TARIFF PROCEEDINGS

• To test feasibility tion to policy makers

of deregulation in dif- ferent jegraents of

Industry.

• To define, first. where to relax require- ments, and then how to

change in order to en- courage a more competitive, economically

healthy marketplace

whl le still fulfilling mandate of Communications

Act

Implement and administer • To provide Infonaa-

• To Identify rules, regulations and reporting requirements for which use does not justify cost to either regulator or rcgulatee

COMPLAINTS AND

SERVICE STANDARDS

(Monitors quality of

'service, reviews conr- _Jplalnts, and review Ipetltlons for change

|of service

USES OF MEASUREMENT DATA FOR COMPLAINTS AND

• To help define the • To help define public public Interest service standards

SERVICE STANDARDS

• To set protocol for Intercarr ler relationships

FACILITIES BRANCH

21* Authorization

Reviews petitions for compliance with law, FCC* rules and regulations, .regarding station li- censes (radio/micro)

,

(extension of lines and

ic.on$.tructJon_j«rrai_ts_ _

Source: Informal discussions

with ETIP and FCC staff.

USES OF MEASUREMENT DATA FOR FAC 1

L

ITIES •To assess effect of In help determine real ex- • To Increase state-of- creased competition and tent of possible dangers the-art applications

Innovative technology from duplication of fac- and define links be- on the national commun- ilities, congestion In tween deregulation and ications network and network, etc. availability of Innova- tive technology to the publ ic

FIGURE VI-1: SPECIAL INTEREST MEASUREMENT NEEDS OF SPONSORS
180

2. OTHERS WHO MIGHT USE

EVALUATION INFORMATION

Another class of users is organizations and individuals who actually

participate in PMS commerce and are thereby subjects of the evaluation. This

diverse group of "participants" consists of carriers, who provide services;

customers, who purchase services; manufacturers and vendors, who supply raw

materials for public message services operation; labor unions, who represent

public message services employees; etc. The activities of these participants

will directly affect the results of the evaluation. Since their interests

are at stake, this group will have a great deal of use for measurement

information.

Other potential users of the information are involved in some aspect

of telecommunications commerce, but do not participate directly in public

message services. This group of "onlookers," the largest and presently least

defined class, includes all those associated with the project by virtue of

their willingness to act if presented with new information about the effects

of deregulation. CCB staff responsible for non-PMS matters, for example,

might alter their activities in light of evaluation findings. For example,

the tariff stipulations for price changes are being revised in response to

the PMS deregulation. If the new stipulations appear to improve price regulation, they will probably be tested by CCB staff in other, non-PMS, sectors

of telecommunications commerce.

Another onlooker, the National Telecommunications and Information Administration (NTIA) of the Department of Commerce, would like to determine whether

public message services can be made profitable and whether deregulation will

result in improved quality and quantity of services. We presume that NTIA
181

would reexamine its general policy on deregulation if substantiated information

showed that deregulation did not lead to the introduction of new and better

public message services.

Figure VI-2 below shows some outside organizations that might use measurement information. They are divided into participants and onlookers according

to the categories defined above. Specific questions that concern participants

and onlookers have been identified. The entries on Table VI-1 are a sample

from the larger set included in Appendix E. The far right column contains

our best current understanding of potential use of measurement data. The

middle columns include information on where to pursue measurement data. Questions about specific uses for data are on the left. The far left columns

identify the source documents used to gather this information.

Sources for the measurable issues which appear on this table are:

(1) comments of RCA Global Communications regarding Graphnet and Telenet's

applications to enter the international market and (2) the FCC's Authorized

User Decision . This table illustrates how information from the evaluation

might be used to clarify the issue of whether the international market should

be fully open to competition; for example:

• If many innovative technologies for providing PMS develop, resulting

information might show whether state-of-the-art technology decreases

or increases technical inef ficiences of the underlying network (Issue

No. 5).

• If market demand for public message services increases after deregulation, more evidence might become available showing whether the

international market for PMS and other data communications services

can support competition (Issues Nos. 7 and 8).

1. We have identified roughly 250 specific individuals and organizations in the onlooker category. Appendix F is a list of members of this group

organized in terms of association with the following major cases currently

facing the Commission: the Computer Inquiry, the Gateway Inquiry, the Telex/

TWX Inquiry, the WATS/MTS Inquiry, and the Western Union Monopoly Inquiry.
182

ONLOOKERS

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• If a variety of innovative PMS technologies and applications

evolves after deregulation, information about the characteristics

of new public message services and the carriers which provide them

might help to determine whether resellers should be fully regulated (Issue No. 11).

These examples make many assumptions about the effects of deregulation.

Measurement decisions will probably be revised as actual reactions of industry to the deregulation become known.

C. EVALUATION MEASUREMENT

1. MODEL FOR MEASUREMENT

Figure VI-3 illustrates our current understanding of the status and

associations of these components. The diagram provides an essentially static

view of the dynamics of PMS commerce, but it represents a starting point or

baseline for subsequent measurement efforts. The basic form was constructed

using discussions and interviews with CCB staff and others with knowledge

about PMS regulation and commerce.

The basic measurement approach is related to the elements (or components)

of the evaluation, described in Chapter IV. The FCC is represented in terms

of the Commission (A) , PMS policy and rules (B) , CCB organization and process

(C) ; the PMS sector of regulated telecommunications commerce, represented

by Western Union (WUTC) , USPS, and the other carriers in PMS during the evaluation (D); service networks (E) ; message senders (F) ; message receivers (G)

;

raw materials and support (H) ; the general public and onlookers (I); and the

status of PMS commerce (J)

.

Descriptions of the boxes and arrows in Figure VI-3 are presented in

Tables VI -2 and VI-3. The first table describes the basic role of each
185

0-

THE FEDERAL

co.

v :rj:acAT:oKS COMMISSION

®

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A. The Commission

• PMS Agenda Items Pendtng

• Mandate In Question

for FKS

Q>

PMS Policy and Rules

High Number of CFR Stipulations

Monopoly Oriented Policy and Definitions for PMS

C. CCB Organization and Procea

for Regulating PMS

1 Ch lef

Management Policy and Rules

- Tariffs

- Facilities and Services

- Complaints/Standards

Accounts/ Audits

- Economics Bearings

10 PMS Facil. Filings Per Year

20 PMS Tariff Filings Per Year

Staff time to handle PMS Filings varies—can be very tine con- suming due to monopoly conditions

General Public

and Onlookers

Some complaints

Comments Congressional

activities k

0—

Carrier, WATS, USPS, etc. Virtual Monopoly

30 filings per year

14 reports per year UD

THE PUBLIC

MESSAGE SERVICES MARKETPLACE

f Z. Service Network ©

F. Senders

$146 million purchase

per year

few social users

$4.47 per message

Approx. ten message services available <!>

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Central Telephone Bureaus Infomaster System

fev in/out modes

45 million messages Basically computerized- message switching

Receivers "

45 million messages

54 percent mallgram

KhH

MarerSnT* ani^ <;..~-^-r Standard rate, leased lines Terminal equipment

type/price

J. Status of Coaaierce

.3 Percent of Total Telecommunications Revenue

FIGURE VI-3: COMPONENTS OF PMS REGULATION AND

COMMERCE, CURRENT STATUS
186

TABLE VI-2: DESCRIPTION OF COMPONENTS OF PMS REGULATION AND COMMERCE

Component Description

A. The Commission • Sets policy for PMS within bounds prescribed by

(7 -members

:

Congress and Courts; oversees PMS according to mandate

Commissioners) for orderly, efficient and reasonably priced services

• Determines which services covered by PMS resources

B. Official • Represents the combined documented policy and rules

FCC/CCB which FCC/CCB employ to administer ongoing PMS

Policy and regulation (e.g., 47 CFR)

Rules for PMS

C. CCB Organiza- • Administers "process" of the offices, divisions, and

tion and branches according to official PMS policy and rules.

Process

D. PMS Sector • Company (ies) that develop and supply public message

of Commerce services (e.g., management and company policy)

• Submits filings and applications to CCB re PMS

E. Network • Represents facilities, equipment, and labor involved

(owned/leased) in moving messages from acceptance through delivery.

F. Message • Purchasers of public message services (individuals

Senders or organizations)

• Includes access modes (tieline, teleprinter, etc.)

G. Message • Receives messages via PMS (individuals or Receivers organizations)

• Includes mode of reception (tieline, teleprinter,

etc.)

H. Raw • Firms supplying basic goods necessary for the con- Materials duct of the carriers' business, particularly the

and Support service operation

• Includes investors and inventors

I. General • Those not regularly participating in PMS commerce,

Public and but perhaps commenting to the Commission about PMS

Onlookers

J. Status of • Percentage of total telecommunications commerce

Commerce attributable to PMS
187

TABLE VI-3: LINKS BETWEEN COMPONENTS OF PMS REGULATION AND COMMERCE

Number of

Link Description of Link

1. • The Commission's authority to administer regulation for

PMS and resources for processing filings

2. • The CCB's PMS-related items for Commission deliberation

and/or authorization (e.g., notice of inquiry, notice of

opinion and rulemaking)

• Statistics of common carriers

• Public message service rulings

3. • The requirements of official CCB/FCC policy and rules for

PMS

• CCB activities like "act on tariff applications" within

90 days of petition by carrier

4. • Applications and filings from carriers responding to

policy and rules for PMS regulation

5. • The rulings of CCB's regulatory process in response

to carrier applications and filings

6. • The directives carriers supply to manage their service

network

7. • Need of and money from customers who purchase PMS services

8. • Messages to sender via service operation

• All contracts with carrier regarding message reception

9. • Service network revenue

10. • Need and money to purchase basic goods for service network

11. • The basic goods in terms of finances, equipment, lease

arrangements, expert advice, etc., supplied for service

operation __

12. • The comments, complaints, recommendations, etc., regarding

public message services
188

component in ongoing PMS commerce and regulation. The second table provides

information about the links between individual components. For example, arrow

3, from PMS policy and rules (B) , to CCB organization and process for regulating

PMS (C) represents the CCB staff activities that are governed by specific stipulations of 47 CFR. Review of carrier tariff filings is such an activity.

Possible indicators of the status of each component in the deregulation

are listed inside the boxes. (Data describing indicators are based on our

preliminary findings discussed in Chapter IV.) For example, senders (F) currently spend about $146 million on public message services per year. These

funds and other indicators (e.g., amount of social use) link senders to the

service network (E, Infomaster) that transmits messages (8) to receivers

(G) and generates revenues (9) for regulated companies which actually supply

public message services, that is, the carriers (D).

Figure VI -4 builds on the previous diagrams and tables. The left portion

(identical to Figure VI-3) represents current status of PMS commerce and regulation, while the right portion shows how indicators are expected to change

after public message services deregulation. Our preliminary set of indicators of change is listed in the column on the far right. Each indicator is

associated with a particular component (shown in Figure VI-3). The arrows

across the top represent the events (described in more detail in Chapter V)

which are expected to mark progress of the project. For example, an indicator

that the intervention has started is "Vote for PMS Item." Before the intervention begins, the Commission agenda will have the PMS MO&O and rulechange

items pending; after these items are approved, the agenda is expected to have

no PMS items pending.
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The information derived from measurement activities is expected to facilitate an empirical understanding of potential effects and impacts of the deregulation. For example, the deregulation might cause Western Union to discontinue some services and stations, with a resulting reduction in certain kinds

of jobs. "Telegraph operator" jobs might decline as the composition of Western

Union's service network and offerings shifts, and the Communications Workers

of America or the United Telegraph Workers Union might respond by protesting.

Measurement information for "number of employees by type" would help to resolve

this type of problem by indicating the pattern of employment loss for the

last ten years.

Figure VI-5 illustrates how the deregulation might produce some of these

effects. The center box represents an implemented open competition policy

for public message services. The middle portions represent some of the effects

the policy change is expected to generate within specific groups associated

with PMS. The outside boxes contain a fuller description of who or what will

experience these effects. For example, the lower left shows that international

record carriers such as RCA Globcom, Western Union International, and Hawaii

Telephone might ultimately be affected if deregulation brings changes in public

message services technology.

2. EVALUATION MEASURE CONSTRUCTION AND APPLICATION

a. MEASURE CONSTRUCTION

In practice, each of the indicators for potential measurement shown on

Figure VI-4, such as "attributable cost of regulation" or "process rate," combines many smaller, more specific measures. The same is true for the measures

described in Figure VI-5. For example, if PMS is revived, we might expect
191

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to find computer business equipment manufacturers increasing the production

of terminals for sending or receiving public message services. In that case,

a measurement scheme for capturing the "change in rate or productivity for

terminals" might be necessary.

Since the applications and filings submitted to the Commission are

important indicators of how the structure of commerce might shift (and are

in fact the first tangible clue that it is about to shift) , the "process rate"

measure is essential to tracking the effects of the deregulation. This measure

is based on the yearly number of PMS applications and filings in compliance

with relevant Parts of 47 CFR per carrier. (See Basic Indicator "C" on Figure

VI-4.) Figure VI-6 illustrates a system for aggregating data to measure the

process rate for public message services regulation.

b. MEASURE APPLICATION

A HYPOTHETICAL EXAMPLE

The deregulation is expected to touch off numerous effects that should

become evident upon close examination of the structure of PMS regulation and

commerce. To establish which effects can be attributed to PMS deregulation,

the most prominent lines of effect will have to be traced, in a series of

evaluation iterations. Figure VI-7 on page 195 illustrates this process.

It should be emphasized, however, that the figure is hypothetical and actual

measurement would require much more definition. All traditional terminal

equipment would have to be identified, along with specific manufacturers,

sales prior to deregulation, etc.

Also, as an illustration only, the following typology of categories

of teleprocessing terminals is presented. A list of PMS terminal equipment,

compiled as part of the evaluation, might be similar to this:
193

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A. Low-Speed Teletypewriters (0-1200 bps)

- Buffered or unbuffered

- Limited intelligence

- Used on dial-up or leased lines

- Population Applications—time sharing, message switching

B. Low-, Medium-, and High-Speed Video Displays (300-9600 bps)

- Alphanumeric or graphic

- Mostly buffered with moderate intelligence

- Used on dial-up or leased lines

- Popular applications—fast-response data base inquiry systems

C. Remote Job Entry Systems (2400-9600 bps)

- Card reader, printer, operator console as a minimal configuration

- CRT display, tape, diskette capability optional

- Mostly buffered, frequently programmable

- Used on dial-up or leased lines

- Popular applications—card reader, line printer, access to batch

j ob queue

D. Transaction Terminals (300 bps-50,000 bps Loop Line)

- Low cost per workstation, driven by buffered, shared controllers

- Mostly buffered and designed around particular application

- Used mostly on leased lines

- Popular applications—retail point-of-sale, banking, credit

checking , supermarket checkout

E. Intelligent Terminals (2400-9600 bps)

- Buffered, programmable, highly modular

- Substantial functional capability independent of host CPU (e.g.,

local data entry, transaction edit and/or verification, and

data base look-up independent of hose CPU)

- Can function as combination of remote data entry station controller,

remote display controller, communications concentrator or applications processor

- Can control such devices as teleprinters, CRTs (both local and

remote), transaction terminals, tapes, diskettes, disks, and

on-line storage

- Used on either dial-up or leased lines and can perform substantial

functions without connection to host CPU^

Figure VI-7 illustrates how we determine what change can be attributed to

the deregulation initiative and what cannot. The sequence from left to right

shows the evaluation phases that would take place if the deregulation was

found to have caused an increase in manufacture of innovative, or nontraditional,

1. FitzGerald, Jerry and Tom Eason. Fundamentals of Data Communications , John Wiley and Sons, Inc., 1978, p. 85.
195

.1
196

terminal equipment used for public message services (e.g., some new type of

facsimile device) . The ovals across the top indicate the types of answers

which each phase of measurement activity should produce. For example, the

first phase should establish that deregulation has occurred. Findings associated with a host of specific Commission measures, including those listed

in the boxes over phase one, would lend the support for this conclusion.

After deregulation is demonstrated, the second measurement phase should

establish the existence of competition, using many measures including those

listed in the figure. One ancillary effect of competition is a change in

the amount and types of equipment used in PMS. During phase three, categories

of equipment, like those listed in the figure, are examined separately to

determine which category (ies) show the greatest change. In this example,

the number of sending and receiving terminals in PMS is found to be the

category most changed by the competition resulting from deregulation.

In phase four , the shift in number of terminals is examined more carefully. The figure illustrates a simple pre/post, control group format for

determining the relative magnitude of the shift in terms of percentage of

communications terminals connected with FMS. The control group in this illustration might be terminals connected exclusively with private networks.

Terminals would be subdivided into types. All types—traditional and nontraditional—might initially be included in this assessment.

The shaded areas at the top of the bars on the "post" graphs indicate

the increase in terminal use for public message services after the deregulation. The upper graph represents control group use; the lower graph,

general public message services use. Comparing the graphs reveals a

significant change in PMS terminal use after deregulation. Comparing the
197

types of terminal equipment used for PMS before deregulation with types used

after deregulation, we can calculate the percentage of nontraditional terminal

equipment used. Phase four findings demonstrate that the number and types

of nontraditional terminals used in public message services applications is

high.

Phase five measurement determines the status of "new" terminals , in

terms of years in PMS-type functions. For example, existing types of private

terminals that are converted to PMS applications are not as "new" as terminals

manufactured, after deregulation, specifically for PMS. The graph for this

phase shows the results of a hypothetical survey of the average age of terminals in PMS operation by type and model number. Phase five results in the

finding that a specific percentage of terminals in use for public message

services were manufactured and purchased after the deregulation.

The terminal type and model number information collected during phase

five should introduce phase six measurement activities, which consist of

identifying manufacturers of nontraditional terminals that are introduced

into PMS after deregulation. The companies chosen to illustrate phase six

were selected from a list of over 300 manufacturers of "nontraditional

terminal devices."

Phase six activities identify one company, Centronics, as a prime

supplier for terminals for public message services applications. Closer

examination in phase seven shows that Centronics' monthly per-unit

production of innovative terminals is rising dramatically. The shaded

portion of the graph illustrates this finding.

1. U.S. Federal Communications Commission. "An Overview of the Domestic

Telecommunications Industry and the Commission's Policies Concerning Terminal

Equipment and Private Line Service," (undated), pp. 50-66.
198

Thus, if results of these phases are found to be credible, systematic

evaluation should allow us to attribute effects on technological innovation

(in terms of innovative terminals) to the deregulation. The example sketched

above represents one sample of many measurement possibilities which might

be pursued during the evaluation. Evaluation findings such as those illustrated above might contribute to a more intensive analysis designed to determine whether the effects of deregulation are peculiar to the public message

services environment. The plan for that level of analysis will be included

in an applied evaluation design that will be developed as the intervention

becomes better defined.

D. FINDINGS CONCERNING THE POTENTIAL

FOR USEFUL EVALUATION

This section briefly assesses the proposed ETIP/FCC project in relation

to characteristics that indicate high potential for useful evaluation in an

administrative experiment. The following characteristics are included:

1. There should be short- and long-term goals which can be

expressed in measurable terms.

2. There should be a set of in-place or planned activities

that sponsors agree can be expected to lead to achievement

of both interim and downstream goals.

3. There should be measures and comparisons for assessing

progress and whether or not goals have been accomplished.

4. There should be defined uses for evaluation findings,

including data about interim progress.

Using these characteristics to measure this project's potential for

useful evaluation, we find first that public message services deregulation

goals are still imprecisely stated. For example, there is general agreement
199

that any regulations imposed on PMS carriers should be less burdensome than

those imposed on Western Union during the monopoly period. However, it is

not yet clear whether "less regulation" means the smallest possible set of

rules or just a smaller set than the previous one.

Second, the project needs better standards for performance. For the

evaluation to show that competition exists, an acceptable indicator of the

threshold between monopoly and competitive market conditions should be

available: Is competition a certain number of carriers present in a market,

or should percentage of market share also be taken into consideration? It

will be necessary for ETIP and CCB to establish more precise, measurable

goals and more acceptable measures of status in relation to those goals.

Third, no mechanism presently exists in CCB for transferring information

from the PMS evaluation to other areas of telecommunications regulation where

it might be used. In order to relate findings about the revised regulatory

process and the effects of the deregulation to other areas of inquiry, such

as Telex/TWX or MTS/WATS, this organizational mechanism for information transfer

must be in place.

There is also the question of how ETIP and CCB plan to distribute

findings from the evaluation to the outside world. For instance, members of

other organizations, such as the National Telecommunications and Information

Administration, might be invited to participate in the project's Evaluation

Group. (The Evaluation Group is discussed in Chapter V.)

Both ETIP and CCB must be more specific in chosing priorities among

their many interests, for measurement in connection with the evaluation.

Some priorities must also be established for those outside of the project

who might use evaluation findings. Since more measurements might be
200

taken and more uses for results might be found than can be accomplished, a

full-scale evaluation design for the project will have to be based on the

choices of ETIP and CCB staff participating in the Evaluation Group, and on

findings from analyses of early "participant" reactions to the Commission

policy change and rulemaking. Basically, the tradeoff will be between

decisions concerning priorities and the actual resources available for

information collection.

Finally, since any change in public message services regulation will

take place in a fast-changing policy environment, it will be subject to the

effects of decisions made outside of the Commission, by other entities, such

as the Congress and the courts. Unanticipated policy shifts might require

modification of the evaluation design. Therefore, a function for tracking

reaction to the deregulation and developments in other areas of regulated

telecommunications should be established. This will insure that PMS deregulation is seen in the context of the telecommunications industry as a whole

and that expectations for use of evaluation findings are reasonable.

Given the relatively modest size of the present PMS market, an evaluation

of the magnitude contemplated here is reasonable only if it can be expanded

to affect a larger segment of telecommunications. Such an expansion might

occur in a number of ways. The final definition of public message services,

for example, might affect the scope of the project. A relatively broad definition might result in large impact; that is, a large number of firms, offering a wide variety of new services using different technologies, might decide

to enter a broadly defined PMS market, to seek the advantages of deregulation.

The project might also be expanded sequentially by application of the information obtained to pending Commission decisions and/or by transfer of the
201

evaluation process itself to those decisions. (See Chapter III for examples

of regulatory situations requiring Commission decision making.)

The project does present several important opportunities, which were

mentioned earlier in this report, for both the Commission and ETIP. In summary, these include:

• An opportunity to test the role of competition in a telecommunications market traditionally considered a natural monopoly;

• An opportunity to gain knowledge regarding: (1) the effects of

regulation on technological innovation and (2) the complex of

factors which may facilitate or hinder introduction of innovative

services and technologies into the marketplace;

• An opportunity for the Commission to analyze and implement procedural changes, including a more purposeful data-gathering approach,

which might be transf errable to the process of deregulating other

monopoly markets or more routine activities;

• An opportunity for the Commission to test new empirical standards

on which to base its decisions; and,

• An opportunity to test whether information gained about technical,

economic, and/or political core issues can be generalized from

the public message services deregulation to other areas of inquiry.

(The evaluation may also serve as a vehicle for moving to broader

sets of generic issues. As noted in Chapter III, the Commission

has before it several decisions which will influence innovation.)

We believe that this evaluation (properly monitored and analyzed) will

be of great interest to government, industry, and the research community. The

process by which public message services and technologies enter the marketplace should prove valuable information for all concerned with the telecommunications industry.

203

BIBLIOGRAPHY
204

ARTICLES

Abelson, Philip H. "The New Discoveries," The Wilson Quarterly , Summer

1978, pp. 65-73.

"Behind AT&T's Change at the Top." Business Week , November 6, 1978,

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"Charles Ferris —The Big Wheel at the FCC." National Journal , October

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EMMS —Electronic Mail & Message Systems . Vol. 2, No. 16, August 15,

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"Exxon Moves onto IBM Turf." Business Week , February 13, 1978, p. 80.

Fiber Optics and Communications Newsletter . Vol. 1, No. 7, August 1978.

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Holsendolph, Ernest. "Western Union's Monopoly Challenged; Western Union

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Jacobs, Ira. "Atlanta Fiber System Experiment: Overview," The Bell

System Technical Journal , Vol. 57, No. 6, Part 1, July-August 1978,

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Jones, William H. "Analysts Charting AT&T Woes," The Washington Post , September 18, 1977, Section F, pp. 1 and 5.

Kamien, Morton, I., and Nancy L. Schwartz. "Market Structure and Innovation:

A Survey," Journal of Economic Literature , Vol. 8, March 1975, pp. 1-37.

Mitnick, Barry M. "Deregulation as a Process of Organizational Reduction,"

Public Administration Review , July/August 1978, pp. 350-357.

. "Factor Price Changes and Factor Substitution in an Evolutionary

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Economic Journal 84, December 1974.

"The New Telephone Industry," Business Week . February 13, 1978, pp. 68-78.
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ARTICLES, Continued

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"R&D Spending Patterns." Business Week , July 3, 1978, pp. 58-65.

Reingold, Nathan. "0 Pioneers!" The Wilson Quarterly , Summer 1978, pp. 55-64.

"Satellites: How the % Birds* Are Changing TV," TV Guide (Washington-Baltimore

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"Science in Europe/British May Use Telephones, TV's, to Tap Data Bank."

Science , Vol. 201, July 7, 1978, pp. 33-34.

Schuyten, Peter J. "Xerox is Entering Telecommunications." The New York

Times, November 17, 1978.

Schwartz, M.I., et al. "The Chicago Lightwave Communications Project," The

Bell System Technical Journal , Vol. 57, No. 6, July-August 1978, pp.

1881-1889.

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Trebling, Harry M. "Plight of the Telegraph Service," MSU Business Topics , Summer 1967. Graduate School of Business Administration, Michigan

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Uttal, Bro. "Selling is No Longer Mickey Mouse at AT&T," Fortune , July 17,

1978, pp. 98-104.

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206

GOVERNMENT DOCUMENTS

American Satellite Corporation. Domestic Communications Satellite Service;

Regulations and Rates Applying to Interstate Services Between Points

in the United States and to Such Interstate Service When Connected with

Overseas Facilities of Other Carriers , Federal Communications Commission,

Tariff F.C.C. No. 1, issued March 26, 1974, effective July 1, 1974.

American Telephone & Telegraph Company, Long Lines Department. Wide Area

Telecommunications Services (WATS), In the Matter of , Docket No. 21402

before the U.S. Federal Communications Commission.

"Code of Federal Regulations, Title 47," Federal Communications Commission,

(Communications Act of 1934).

Fairchild Industries, Inc. "Prospectus," dated February 9, 1978.

Graphic Scanning Corporation. "Prospectus," dated April 13, 1977, filed

with the Securities Exchange Commission.

Graphnet Systems, Inc. Memorandum Opinion and Order and Notice of Inquiry

Proposed Rule Making , before the U.S. Federal Communications Commission,

CC Docket No. 78-95, File No. W-P-C-1430; and CC Docket No. 78-96;

adopted March 9, 1978, and released March 28, 1978.

International Telephone and Telegraph Corporation. "Form 10-K-Annual Report,"

received March 30, 1978, filed with the Securities and Exchange Commission.

MCI Communications Corporation. "Annual Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934," filed June 29, 1978,

with the Securities Exchange Commission.

. "Prospectus," dated September 29, 1977.

National Aeronautics and Space Administration. Report on NASA Five-Year

Planning, Fiscal Years 1978 through 1982 , draft, dated February 14,

1977, Washington, D.C. : National Aeronautics and Space Administration.

National Aeronautics and Space Administration, Technology Utilization

Office. Spinoff 1977; An Annual Report , by James J. Haggerty,

January 1977, Washington, D.C, Government Printing Office, 116 pp.

Radio Corporation of America. "Form 10-K: Annual Report Pursuant to Section

13 or 15(d) of the Securities Exchange Act of 1934," filed April

3, 1978, with the Securities and Exchange Commission.

. "RCA Stock Option Plans," dated May 1, 1978, filed with the

Securities Exchange Commission.

Tele-Communications, Inc. "Supplement dated December 23, 1977, to Prospectus

dated October 13, 1977; The Tele-communications, Inc., Employee Stock

Purchase Plan," filed with the Securities Exchange Commission.
207

GOVERNMENT DOCUMENTS, Continued

Telenet Communications Corporation. Letter of transmittal, transmittal

No. 33, and prospectus to U.S. Federal Communications Commission

(Cost support materials re: application for volume discount), Tariff

F.CC. No. 1, Section 61.38 data, received December 28, 1977, Tariffs

Branch, F.CC.

Tymnet, Inc. Data Communications Services , Federal Communications Commission,

Tariff F.CC. No. 1, Section 61.61 data, received at The Urban Institute,

Summer 1978.

Tymshare, Inc., "50,631 Shares, Tymshare, Inc., Common Stock" (Prospectus),

filed December 8, 1977, with the Securities and Exchange Commission.

U.S. Congress. House of Representatives. A Bill to provide for a research,

development, and demonstration program to establish an experimental

public service satellite communications systems , H.R. . 14046, 95th

Congress, 2nd Session, 1978.

U.S. Department of Commerce, Bureau of Standards. Experimental Technology

Incentives Program. Experiments in Communications Regulation , Project

Plan for ETIP Project 161, August 1, 1977.

U.S. Department of Commerce, Office of Telecommunications. Federal Regulations Relevant to the Structural Development of Telecommunications

Industries , by R. B. Johnson, Office of Telecommunications Report 77-

135, Springfield, Virginia: National Technical Information Service,

November 1977.

U.S. Federal Communications Commission. "Domestic Public Point-to-Point

Microwave Radio Service—Specialized Common Carrier Services," Federal

Register 36, No. Ill, June 9, 1971, pp. 11144-11173.

. "In the Matter of Regulatory Policies Concerning the Provision

of Domestic Public Message Services by Entities Other than the Western

Union Telegraph Company and Proposed Amendment to Parts 63 and 64 of

the Commission's Rules," Common Carrier Docket No. 78-96, 1978.

. "Memorandum of Law," by Dick Severy to David Irwin, dated December

7, 1977.

"An Overview of the Domestic Telecommunications Industry and the

Commission's Policies Concerning Terminal Equipment and Private Line

Services" (no date).

. Press Wireless, 21 FCC 331 (1956).

. Report by the Federal Communications Commission on International

Telecommunications Policies , statement by Richard E. Wiley, Chairman,

before House Committee on Interstate and Foreign Commerce on International Communications Services, March 23, 1977.

. Statistics for Common Carriers, 1976.
208

GOVERNMENT DOCUMENTS, Continued

U.S. Federal Communications Commission/Common Carrier Bureau. Points

Memo: Public Record Message Services Experiment —FCC /Experimental

, Technology Incentives Program (ETIP) , June 1978.

U.S. Federal Communications Commission/Public Information Office. Information Bulletin: Broadcast Services , January 1977.

. Information Bulletin: Cable Television , January 1977.

. Information Bulletin: Educational Radio , January 1977.

. Information Bulletin: Educational Television , July 1977.

. Information Bulletin: Field Operations Bureau , June 1977.

Information Bulletin: Information Services and Publications , (No date).

Information Bulletin: Regulation of Wire and Radio Communication , April 1977.

Information Bulletin: Safety and Special Radio Services , April 1977.

. Information Bulletin: Safety and Special Radio Services , April 1977.

Information Bulletin: Subscription Television (STV-Pay TV) , June 1977.

United States Transmission Systems, Inc. Explanation and Data Supporting

United States Transmission Systems, Inc., Specialized Leased Channel

Service , Federal Communications Commisison Tariff FCC No. 1, filed

August 29, 1977.

. Justification for tariff revisions, U.S. Federal Communications

Commission, Tariff F.C.C. No. 1, Section 61.38, filed August 29, 1977.

Western Union Telegraph Company. Public Message Telegram Service Regulations and Schedules of Charges. Federal Communications Commission

Tariff F.C.C. No. 255, received at The Urban Institute Summer 1978.
209

PRESENTATIONS

Disher, John H. (Director, Advanced Programs, Office of Space Flight,

National Aeronautics and Space Administration). "Plans and Projections

for Space Industrialization," a_t Special Seminar Series: Near Earth

Space Utilization, MIT Department of Aeronautics & Astronautics, Fall

1976.

Freitag, Capt. Robert F. (Deputy Director, Advanced Programs, Office of

Space Flight, National Aeronautics and Space Administration). "NASA

Philosophy Concerning Space Stations as Operations Centers for Construction and Maintenance of Large Orbiting Energy Systems," a_t the International Astronautical Federation Congress, Anaheim, California.

October 10-16, 1976.

Kline, Richard L. "The Space Station and Space Industrialization," a_t the Bicentennial Space Symposium, jointly sponsored by the AAS and

AIAA, Washington, D.C., October 6-9, 1976.

PROMOTIONAL MATERIALS

American Satellite Corporation. "ASC President Assures Business Leaders

of Continuing Availability of Roof-Top Satellite Systems," September

7, 1978.

. The American Eagle , Vol. 3, Number 1, Spring 1978.

"American Satellite 5-Meter Antenna Stations Now Enjoy Exclusive

> Routine Approval* from FCC," September 7, 1978.

• "Background American Satellite Corporation," submitted to Science

Policy Research Division, Congressional Research Service, Library of Congress," September 1, 1978.

. "SDX: Satellite Data Exchange Service," received at The Urban

Institute, Fall 1978.

. "Sperry Univac to Expand New Satellite Communications Network,"

September 7, 1978.

Graphnet Systems, Inc. "Fax Gram: The Faster Gram by Graphnet," received

at The Urban Institute, Summer 1978.

. "Fax Gram: User Guide" (1975).

ITT Corporate Communications Services, Inc. "CCSE: Corporate Communication

Switching Equipment" (06-2-11-77), received at The Urban Institute

Fall 1978.

. "ITT Unit Inaugurates New Telephone Service For Interoffice

Business Communications," Press Release, August 17, 1978.
210

PROMOTIONAL MATERIALS, Continued

"SPNS: Switched Private Network Service," received at The

Urban Institute, Fall 1978.

. "Your Switching Alternative for Private Communication Services,"

(CCS 0178), (no date).

ITT United States Transmission Systems, Inc. Letter from J.C. Reynolds,

President, to Sharon Kir by, The Urban Institute, dated October 5,

1978; and general service descriptions included.

• "One of the Best Business Connections You Can Make" (0478),

received at The Urban Institute October 8, 1978.

. "USTS Private Line-Rate Schedule," effective date September

1, 1978.

RCA America Communications, Inc. "What every company president should

know about domestic satellite communications," by Andrew F. Inglis,

President, received at The Urban Institute, September 18, 1978.

Tymnet, Inc. Configuration of Network Map, received at The Urban Institute,

Fall 1978.

. General information on services, received at The Urban Institute,

Fall 1978.

. "How to Use Tymnet," dated April, 1978, received at The Urban

Institute, Fall 1978.

. Letter from Ronald A. Bamberg, Manager Corporate Marketing, to

Sharon Kirby, The Urban Institute, dated September 26, 1978.

. "Subscribers Directory," dated April 1978, received at The

Urban Institute, Fall 1978.

Western Tele-Communications, Inc., "Background Information," received

at The Urban Institute, Summer 1978.

. "Company Statistics as of December 31, 1977," received at The

Urban Institute, Summer 1978.

. Descriptive materials regarding system, received at The Urban

Institute, Summer 1978.

. Network Configuration Map, "Microwave Systems," received at

The Urban Institute, Summer 1978.

. "WTCI Receives Government Contract for Fiber-Optic System,"

received at The Urban Institute, Summer 1978.

. "WTCI To Do Remote Video Transmissions For The 1978 U.S. Open,"

received at The Urban Institute, Summer 1978.
211

OTHER STUDIES

Borchardt, Kurt. Actors and Stakes: A Map of the Communications Arena

(Computers-and-Communications) , Harvard University, Program on Information Resources Policy, Working Paper W-78-8, June 1978.

Gabel, Richard and Marianne Karydes. Policy Research Estimate—Prepared for

the Office of Telecommunications Policy , September 1973.

Kalba, Konrad K. , et al. Electronic Message Systems: The Technological

Market and Regulatory Prospects , (Submitted to the Federal Communications Commission in fulfillment of FCC Contract Number 0236), April,

1978.

Loeb, Guy Hamilton. The Communications Act Policy Toward Competition:

The Sound of One Hand Clapping , Harvard University, Program on Information Resources Policy, Working Paper W-77-1, March 1977.

MISCELLANEOUS MATERIALS

Bell, Jay. "The FCC/ETIP Regulatory Experiment," Working Paper 1198-70-01

(draft), The Urban Institute, Washington, D.C., May 3, 1978.

Dunn and Bradstreet. Million Dollar Directory 1978 , Dunn and Bradstreet,

New York, New York, 1978.

Moody's Investors Service. Moody's Bank and Finance Manual , Moody's Investors

Service, Inc., New York: New York, 1978.

. Moody's Industrial Manual , (2 volumes), Moody's Investors Service,

Inc., New York: New York, 1978.

National Register Publishing Company, Director of Corporate Affiliations , 1978 , National Register Publishing Company, Skokie, Illinois, 1978.

Rosenthal, Congressman Benjamin S. The Reluctant Messenger , Washington,

D.C., September 1974, 70pp.

Standard and Poor's Register of Corporations, Directors and Executives : United States and Canada, 1978 . (3 volumes), Standard and Poor, New

York, New York, 1978.

Transcomm, Inc., Evaluation of Experimental Feasibility at the Federal

Communications Commission , Final Report , ETIP Project No. 154, Order

713410, February 13, 1978.

United States Postal Service. Annual Report of the Postmaster General,

Fiscal 1977.
212

GENERAL BACKGROUND MATERIALS ON TECHNOLOGICAL INNOVATION

Books ;

National Science Board, National Science Foundation. Science Indicators

1976 , 304 pp., Washington, D.C., Government Printing Office, 1977.

[Note especially Chapter 7.]

Articles:

Abernathy, William J., and James M. Utterback. "Patterns of Industrial

Innovation," Technological Review , June/ July 1978, pp. 41-47.

An eke r-Johnson, Betsy. "Current Policies and Options for the Future," The

International Journal of Research Managment , Vol. XX, No. 1, January

1977, pp. 7-12.

Anderson, Frederick, et al. "A New Strategy for Environmental Control,"

from Environmental Improvement Through Economic Incentives . Resources , No. 59, (April-July 1978).

"The Breakdown of U.S. Innovation." Business Week , February 16, 1976,

pp. 56-68.

Clark, Timothy B. "Carter's Assault on The Costs of Regulation," National

Journal , August 12, 1978, pp. 1281-1285.

Levy, Lawrence. "Needed: Institutional Breakthroughs," The International

Journal of Research Management , Vol. XX, No. 1, January 1977, pp. 21-

24.

Lewis, Jordan D. "Its Impact on Technological Change," The International

Journal of Research Management , Vol. XX, No. 1, January 1977, pp. 13-16.

Nason, Howard K. "Perceptions of Barriers to Innovation," The International

Journal of Research Management , Vol. XX, No. 1, January 1977, pp. 17-20.

Schnee, Jerome, and Erol Caglarcan. "The Changing Pharmaceutical R&D Environment," Business Economics , Vol. 11, No. 3, May 1976, pp. 31-38.

Williams, Robert *I£ "Politics and the Ecology of Regulation," Public

Administration , Vol. 54, Autumn 1976, pp. 319-331.

Miscellaneous:

Gordon, Nancy M. "Regulatory Processes: A Conceptual Framework" September

10, 1975 (Developed at National Academy of Sciences.)

National Science Foundation. "Applied Science and Research Applications (ASEA):

Programs in Brief" (no date).
213

GLOSSARY OF TERMS

USED IN THE REPORT

This glossary contains definitions of technical

terms used in telecommunications as well as terms

specific to telecommunications regulation such as ruling or filing. The sources for definitions

were (1) internal materials provided by staff of

the Common Carrier Bureau; (2) interviews with

Common Carrier Bureau staff; and, (3) terms used

in Fundamentals of Data Communications by Jerry

FitzGerald and Tom S. Eason, John Wiley & Sons,

New York, New York, 1978. The latter terms are asterisked in list.
214

ALLOCATED: Common user services (e.g., telephone, Telex).

ANALOG TRANSMISSION: Transmission technique where an electrical parameter

such as frequency or amplitude of a carrier's signal varies continuously

with intelligence being transmitted.

BPS: Bits, pulses, or units of information per second.

*BANDWIDTH: The difference between the highest and lowest frequencies in

a band, such as 3000 cycles bandwidth in a voice grade line (300-3300

cycles)

.

*BAUD: A unit of signaling speed equal to the number of discrete conditions

or signal events per second.

BROADCAST COMMUNICATIONS: Distinguished from point-to-point communications

because the message travels publicly to anyone with appropriate reception equipment.

CARRIER, COMMON: Organizations licensed and regulated by the U.S. Federal

Communications Commission or the various state public utility commissions

which supply communication services to users at published prices.

CARRIER SYSTEM: A means of obtaining a number of channels over a single

path by modulating each channel upon a different "carrier" frequency

and demodulating at the receiving point to restore the signals to their

original form.

CHANNEL: A path for transmission of electromagnetic signals. Synonym for

line and link. Compare with circuit.

CIRCUIT: A means of two-way communication between two data terminal

installations. Compare with channel, line.

COAXIAL CABLE: Cable with a sheathed outer conductor tube surrounding

conductor material having a common axis.

COMMUNICATION PROCESSOR, FRONT-END: An auxiliary processor that is

placed between a computer central processing unit and transmission

facilities. This device normally handles housekeeping functions

such as management of lines, translation of codes, etc., which

would otherwise interfere with efficient operation of the central

processing unit. Synonym for front-end computer.

COMPUTER, CENTRAL: In data transmission, the computer that lies at

the center of the network and generally does the basic centralized

functions for which the network was designed. Synonym for host

computer.

CONCENTRATOR: Equipment designed to improve the efficiency of data or voice transmission by allowing terminals or lines to compete for and

share transmission channels.
215

*DATA COMMUNICATIONS: 1. The movement of encoded information by means of

electrical transmission systems. 2. The transmission of data from one point to another.

DATA TERMINAL EQUIPMENT: For example, a modem. May also include computertype terminals in certain cases.

DEDICATED: Full-time private line (e.g., point-to-point voice channel).

DIAL-UP: The use of a dial or push-button telephone to initiate a stationto-station telephone call.

DIGITAL: Transmission technique where intelligence is coded into discrete

pulse forms.

DIRECT DISTANCE DIALING (DDD): The automatic establishment of toll calls in

response to signals from the calling device of the originating customer.

EXCHANGE: A defined area (usually a city, town, or village and its environs)

served by a communications common carrier, within which the carrier furnishes service at the exchange rate and under the regulations applicable

in that area as prescribed in the carrier's filed tariffs.

*FACILITIES: The elements of the telephone plant that provide a complete

connection, exclusive of the customer's equipment.

FACSIMILE (FAX): Transmission of pictures, maps, diagrams, etc. The image

is scanned at the transmitter, reconstructed at the receiving station

and duplicated on some form of paper.

FILING: Any formal request, other than tariff filings, from regulated

carriers and consumers for FCC action. A typical example finds a car- rier submitting forms to gain FCC approval of a plan to expand existing

facilities.

FLAT RATE: Fixed charge regardless of amount of use (non-usage sensitive).

*FOREIGN EXCHANGE (FX) : Service that connect a customer's telephone to a telephone company's central office not normally servicing the customer's

location.

FULL PERIOD SERVICE: 24 hours/day, 7 days /week.

HARDCOPY: A printed copy of machine output in readable form for human beings;

for example, reports, listing, or summaries.

*HARDWARE: A generic, somewhat slang term used to include all equipment,

both computer and communications, contained in a system. Contrast

with software.
216

HERTZ: Cycles per second.

HIGH SPEED DATA: Above 9600 bps.

INTERFACE: A share boundary, for example, the boundary between two subsystems

or two devices.

LASER: An acronym for Light Amplification by Stimulated Emission of Radiation,

denotes a device which produces an extremely intense beam of light con- trolled in both intensity and direction.

LINE, LEASED (OR PRIVATE): A line furnished to a subscriber for his

exclusive use.

LINE, LOCAL LOOP: A communications line connecting several terminals in the

region of a single controller to that controller.

LINE SWITCHING: The switching technique of temporarily connecting two lines

together so that the stations directly exchange information.

LOCAL LOOP: See Loop, Local.

LONG-TERM: Service over one month.

LOOP, LOCAL: That part of a communication circuit between the customer's

location and the nearest central office.

LOW SPEED DATA: to 150 bps.

MEDIUM SPEED DATA: Above 150 to 9600 bps.

*MESSAGE: A communication of information from a source to one or more

destinations, usually in code. A message is usually composed of three

parts: (1) a heading, containing a suitable indicator of the beginning

of the message together with some of the following information

source, destination, date, time, routing; (2) a body containing information to be communications; and (3) an ending containing a suitable indicator of the end of the message.

MESSAGE PICK UP AND DELIVERY: E.g., telegram service.

MESSAGE SWITCHING: The switching technique of receiving a message,

storing it until the proper outgoing circuit and station are available, and then retransmitting it or forwarding it toward its

destination.

MICROWAVE: Terrestrial microwave relay carrier.
217

*MODEM: A contraction of the words "modulator-demodulator." A modem is a device for performing necessary signal transformation between terminal

devices and communication lines. They are normally used in pairs,

one at either end of the communication line.

MODULATION: The process by which some characteristic of one wave is varied

in accordance with another wave. This technique is used in data sets to

make business-machine signals compatible with communication facilities.

MODULATION, PULSE CODE (PCM): A form of modulation in which the modulating

signal is sampled and the sample quantified and coded so that each

element of information consists of different kinds or number of pulses

and spaces.

*MULTIDROP (MULTIPOINT): A line or circuit interconnecting several stations.

MULTIPLEXING: The subdivision of a transmission channel into two or more

separate channels. This can be achieved by splitting the frequency

range of the channel into narrower frequency bands (frequency division

multiplexing) or by assigning a given channel successively to several

different users at different times (time division multiplexing).

*OFFICE: The common designation for any facility in the public switched

network at which switching takes place.

*OFFICE, TOLL: An office that terminals a toll trunk.

*ON-LINE: 1. Pertaining to equipment or devices under the direct

control of a central processing unit. 2. Pertaining to a user's

ability to interact with a computer. 3. Pertaining to a user's

access to a computer via a terminal.

OPEN WIRE AND OTHER: Open wire is wire usually strung from telephone

poles. Other types Include undersea cable and optical systems.

PACKET SWITCHING: A form of real-time (with on-line delays) time division switching exclusively for data transmission where data pulses

are separated into individually addressed packets of constant

length.

PER MESSAGE RATE: Usage sensitive on a message-by-message basis.

Customer billed only for length of time it takes to send message;

or billing may be based on the number of words per message, as in

telegram service.

PICTURE-PHONE: An AT&T tradename for a telephone service that permits

the user to see as well as talk with the person at the distant end.

POINT-TO-POINT COMMUNICATIONS: Distinguished from broadcast communications because the message moves privately from a single sender to

a single receiver.
218

PRIVATE LINE: A channel or circuit furnished a subscriber dedicated to his

exclusive use. Same as private wire.

REAL-TIME SWITCHING: Circuit-to-circuit switching on immediate basis; e.g.,

circuit switching used in message telephone service (MTS)

.

RULEMAKING: The formal process of bringing about change in the official rules

and regulations.

RULING: The final disposition reached when a filing has been processed

by FCC.

SATELLITE: Geostationary satellite in space.

SERVICE BUREAU: An installation where the user can lease processing time

on a central processor and peripheral equipment. The user supplies the

programs and data to be processed, the bureau processes the data and

delivers the results to the user. The program and data for processing may be delivered or sent between user and center in any of

several forms: cards, punched tape, magnetic tape, etc. Data

communications may be used between the user and the center to move

the information electrically. The bureau may also provide such

services as keypunching the data and preparing it for processing.

See also computer utility.

*SOFTWARE: A generic, somewhat slang term for a computer program, sometimes taken to also include documentation and procedures associated

with such programs.

SHORT TERM: Service up to one month.

SPACE DIVISION SWITCHING: Each channel physically separated during

switching—thus, separated by space; e.g., No. 5 XBar machine of

AT&T. May be common control or step by step.

STORE-AND-FORWARD SWITCHING: Synonymous with message switching,

used for switching written records such as teletypewritergenerated message which need not be transmitted on real-time

basis.

*SWITCHED NETWORK: A system consisting of a number of terminal

points that are able to access one another through a series of

communication lines and switching arrangements.

*SWITCHED NETWORK, LINE-SWITCHING: A switched network in which

switching is accomplished by disconnecting and reconnecting

lines in different configurations in order to set up a con- tinuous pathway between the sender and the recipient.
219

*SWITCHED NETWORK, STORE-AND-FORWARD: A switched network in which the storeand-forward principle is used to handle transmissions between senders

and recipients.

*TERMINAL, CRT: CRT is the acronym for Cathode Ray Tube, i.e., a video

display device associated with a terminal. See terminal, video.

TELEGRAPH-GRADE: Up to 150 signal events per second (baud) carried on direct (on/off) basis.

TELEGRAPHY: A system of communication for the transmission of graphic

symbols, usually letters or numerals, by use of a signal code.

*TELEPRINTER: A teletype or teletype device, consisting of a keyboard and

a printing device.

TELETYPEWRITER: Same as teleprinter.

TERMINAL: 1. A point at which information can enter or leave a communications network. 2. An input /output device designed to receive or send source data in an environment associated with the job to be performed

and capable of transmitting entries to and obtaining output from

the system of which it is a part.

*TERMINAL, VIDEO: A terminal using a video display as a readout device,

in contradistinction to a teleprinter, which uses a printer device.

Synonym for CRT Terminal.

TIME DIVISION SWITCHING: Separation is in time realm. Also called Time

Division Multiplex; e.g., may be used with PCM (pulse code

modulation)

.

TIMESHARING: A method of operation (in an on-line system) in which

computer facilities are shared by several users for different purposes

during the same time period. Although the computer actually services

each user in sequence, the high speed of the computer makes it appear

that the users are handled simultaneously.

TRANSPONDER SERVICE: Case where carrier leases the entire capacity of one satellite transponder (approximately 36 megahertz) to a customer.

*TRUNK: A communication channel between switching devices or central

offices.
220

*WORD: 1. In communications, six characters (five plus a space). 2. In

computers, the unit of information transmitted, stored and operated

upon at one time.

VOICE CHANNEL: Any channel used to transmit human voice signal (may be

analog, digital, and of various bandwidths).

VOICE-GRADE CHANNEL: Designates a channel which is a nominal 4 kilohertz

channel which may be suitable for transmitting data, telegraph, and

facsimile as well as voice.

WIDEBAND CHANNELS: Analog channels greater than or equal to 48 kilohertz.
NBS-114A (REV. 9-76)

U.S. DEPT. OF COMM. BIBLIOGRAPHIC DATA

SHEET

1. PUBLICATION OR REPORT NO. NBS TN 1104 Vol. 1

iMIbv*'".. i«i m,

L. _-i ..

3. R«<slfi*enf $ Accession No,

4. TITLE AND SUBTITLE

The FCC Public Message Services Policy Change:

An ETIP Evaluability Assessment Report

5. Publication Date September 1979

S.l^onjjJngGfpnizatJon Code

7. AUTHOR(S) James Beii 5 Sharon Kirby, The Urban Institute;

Roland G. Weiss, NBS; Steve Watson, The Urban Institute

8. Performing Organ. Report No.

9. PERFORMING ORGANIZATION NAME AND ADDRESS 1% Pmject/Task/Work unit No.

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, DC 20234

The Urban Institute

2100 M St., NW

Washington, DC 20037

11. Contract/Grant No. 7-35822

12. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, state, zip)

Same as above

13. Type of Report & Period Covered Interim

I4.3jitisit#ig -JSgeftcy <3o*»

:

15. SUPPLEMENTARY NOTES

| | Document describes a computer program; SF-185, FIPS Software Summary, is attached.

16. ABSTRACT (A 200-word or teas (actual summary of moat significant information. If document includes a significant bibliography or

literature survey, mention it here.)

This document is a report of work in progress toward evaluating effects of the

recent decision of the Federal Communications Commission to open public message

services to competition. It is one product of the Regulatory Processes and

Effects Project of the Center for Field Methods (ETIP). The broader project,

described elsewhere, is attempting to analyze the effects of changes in regulatory

processes on industrial innovation. The joint ETIP/FCC project will involve

measuring whether the FCC policy change leads to increases in competition,

technological innovation, and public benefit.

The first two chapters provide an introduction and synopsis. Chapter II examines

the setting in which the decision occurs in terms of historical developments,

industry trends, and views held by various observers. Chapter IV describes the:

Commission's mandate for regulation, process for implementing this mandate in

terms of regulations and operations, and current industry status. The fifth

chapter describes the evaluation logic. The last chapter is an assessment which

shows that there are many choices to be made to target the evaluation. A

glossary of terms and bibliography are included. Seven appendices are bound

separately.

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only the first letter of the first key word unless a proper name;

separated by semicolons) Administrative experimentation; economic deregulation; evaluability

assessment; evaluation; Experimental Technology Incentives Program; Federal

Communications Commission; regulatory experimentation; regulatory policy;

technology innovation; telecommunications.

18. AVAILABILITY £cx] Unlimited

I I For Official Distribution. Do Not Release to NTIS

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The FCC Public Mess

Services Policy Change:

An ETIP Evaluability

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NOV 3 1973

The FCC Public Message

Services Policy Change:

An ETIP Evaluability

Assessment Report -- Volume 2

US0.S3

no. mom

James Bell 1 Sharon Kirby 1 Roland G. Weiss2 Steve Watson 1

•The Urban Institute 2100 M Street, NW

Washington, DC 20037

Center for Field Methods

Experimental Technology Incentives Program

National Bureau of Standards

Washington, DC 20234

^T 0F

<v

\iTU-- no tioA v » £—

U.S. DEPARTMENT OF COMMERCE, Juanita M. Kreps, Secretary

Luther H. Hodges, Jr., Under Secretary

Jordan J. Baruch, Assistant Secretary for Science and Technology

\)^ NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director

Issued September 1979
National Bureau of Standards Technical Note 1104/2

Nat. Bur. Stand. (U.S.), Tech. Note 1104/2, 1 10 pages (Sept. 1979) CODEN: NBTNAE

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Stock No. 003-003-02117-2 Price $11. Sold in sets only. (Add 25 percent additional for other than U.S. mailing)
iii

ABSTRACT

This document is a report of work in progress toward evaluating effects

of the recent decision of the Federal Communications Commission to opei

public message services to competition. It is one product of the Regulatory

Processes and Effects Project of the Center for Field Methods (ETIP) . The

broader project, described elsewhere, is attempting to analyze the effects

of changes in regulatory processes on industrial innovation. The joint

ETIP/FCC project will involve measuring whether the FCC policy change leads

to increases in competition, technological innovation, and public benefit.

The first two chapters provide an introduction and snyopsis. Chapter III

examines the setting in which the decision occurs in terms of historical developments, industry trends, and views held by various observers. Chapter IV

describes the: Commission's mandate for regulation, process for implementing

this mandate in terms of regulations and operations, and current industry

status. The fifth chapter describes the evaluation logic. The last chapter

is an assessment which shows that there are many choices to be made to target

the evaluation. A glossary of terms and bibliography are included. Seven

appendices are bound separately.

KEY WORDS: Administrative experimentation; Economic deregulation;

Evaluability assessment; Evaluation; Experimental Technology Incentives Program:

Federal Communications Commission; Regulatory experimentation; Regulatory policy;

Technological innovation; Telecommunications.

ACKNOWLEDGEMENTS

This report could not have been completed without the assistance and

cooperation of many people. First and foremost we would like to thank the

Federal Communications Commission staff who provided invaluable information

both about Commission operations and about issues that are currently being

debated within the telecommunications industry. In particular, we wish

to acknowledge:

o David Irwin, Chief of Policy and Rules;

o James Smith, Policy and Rules;

o Charles Oliver of Program Evaluation;

o Frank Patella, Judy Nitsche, Ken Levy, and Daniel Harrold of

Tariff Review and Tariff Proceedings;

o Jim Ferris, Complaints and Service Standards; and

o Robert James (Domestic Division) and Helene Bauman (International

Division) of the Facilities Branch.

We would especially like to thank Leonard Sawicki, Program Evaluation Branch,

who provided assistance throughout the effort including reviews and comments

on the preliminary drafts of this report.

Staff of both The Urban Institute and The Experimental Technology

Incentives Program of the Department of Commerce participated on committees

reviewing this report and offered advice during the course of research.

We would like to thank Victor Berlin, Bud Libman, and Dan Fulmer of ETIP

and Robert Sadacca, John Waller, Joe Nay, Lucile Graham, Michael Mulkey,

Bill Foskett, Paul Nalley, John Heinberg, and Richard Schmidt of The Urban

Institute

.

Our initial contact with the industry produced a gratifying response.

We would like to thank the common carriers which expressed interest in our experimental evaluation of the effects of changes in interstate telecommunications regulation. In some cases, carriers submitted information

about their operations.

The telecommunications industry is indeed fast moving and complex.

We found that the publication Telecommunications Reports provided valuable

information about developments in the industry. Mr. Fred Henck, publisher

of Reports , very kindly gave us permission to quote his journal.
VI

We also appreciate the fine job done by Erica Sweeney who edited this

report. Finally, we would like to thank the many people who helped to

prepare the report. Staff who assisted us include: Rraig Jones, (Ms.) Mike

Mai one, Mary Sarley, John Fortunato-Schwandt , Ilona Bush, and Barbara Shunney.

We are especially grateful to Copper Wilson who, in spite of coming

to the project during the final report writing, took responsibility for

primary secretarial support, worked long hours to meet deadlines, and

also made valuable contributions to the content of the report.

James Bell

Sharon Kirby

Roland Weiss

Steven Watson
VX1

PREFACE

Regulatory agencies and regulatory reform are subjects of great interest

today, and the effects of regulation on technological innovation and productivity in American industry are of special concern. Many reforms and changes

in the regulatory process are being proposed, and some are being made. Each

change represents an "experiment" in the operation of our society, even if no one carefully determines the result of that "experiment."

Since 1974, the Experimental Technology Incentives Program (ETIP)

located in the Center for Field Methods of the National Bureau of Standards

has pursued an understanding of the relationships between government policies

and technology-based economic growth. This goal is based on three premises:

o Technological change is a significant contributor to social and

economic development in the United States.

o Federal, State, and local government policies can influence the

rate and direction of technological change.

o Current understanding of this influence and its impact on social

and economic factors is incomplete.

ETIP seeks to improve public policy and the policy research process in order

to facilitate technological change in the private sector. The program does

not pursue technological change per se . Rather, its mission is to examine

and experiment with government policies and practices in order to identify

and assist in the removal of government-related barriers and to correct

inherent market imperfections that impede the innovation process.

ETIP assists other government agencies in the design and conduct of joint

projects. Key agency decision makers are intimately involved in these

experiments to ensure that the results are incorporated in the policymaking process. ETIP provides its agency partners with both analytical

assistance and funding for the experiments while it oversees the

evaluation function.

In 1977, The Urban Institute's Program Evaluation Group was awarded a significant contract ($856,000 over 15 months) as a result of competitive

bidding on a U.S. Department of Commerce Request For Proposal. Under this

contract the Program Evaluation Group provided analytic support and data

collection services to ETIP. This work was the foundation for the Regulatory

Processes and Effects Project (RPE). The Regulatory Processes and Effects

Project, through this analytic support work, will analyze the process and
Vlll

attempt to document the results of ETIP's regulatory projects, which investigate whether private sector innovation is generated by changes in regulatory

agencies. In December 1978, the Regulatory Processes and Effects Project

moved from The Urban Institute to the Performance Development Institute (PDI) as the result of a competitive award process.

Regulatory Processes and Effects Project teams are conducting short,

exploratory efforts, significant explorations of expectations and reality,

and assessments of fully developed regulatory process changes under various

regulatory situations. * The following regulatory agencies are (or have

been) involved:

Environmental Protection Agency (Air, Pesticides, and Water),

Federal Communications Commision,

Food and Drug Administration,

Federal Energy Regulatory Commission,

Federal Trade Commision,

Interstate Commerce Commission,

Nuclear Regulatory Commission,

Occupational Safety and Health Administration, and

State Public Utility Commissions (Electric Power).

The Regulatory Processes and Effects Project not only helps to develop

actual regulatory administrative experiments, but also helps formulate a generalizable body of methods for implementing and assessing the effects

of regulatory changes on commerce, industry, and technological innovation.

1. ETIP prefers to use the strategy of "administrative experimentation"

when applicable. An administrative experimentation stragegy (1) helps to

bring about a change in the performance or operation of an agency, and

(2) improves the understanding of the relationship between the change introduced and the results observed. Thus, an administrative experiment is con- ducted more in the sense of carefully evaluated change, and not in the social

sciences sense of change controlled by the researcher, according to certain

prescribed rules, solely for research purposes. A "quasi-experimental" re- search design may be the best that one can do. See , for example, Campbell,

Donald T. , "Administrative Experimentation, Institutional Records and Nonreactive Measures," Improving Experimental Design and Statistical Analysis , Stanley, J.C., ed .

, Chicago: Rand McNalley, 1967. Thompson, Charles W. N.

,

and Rath, Gustave J. "The Administrative Experiment: A Special Case of

Field Testing Or Evaluation," Human Factors , Vol. 16, No. 3, June 1974,

pp. 238-252. Thompson, Charles W. N. "Administrative Experiments; The

Experience of Fifty-Eight Engineers and Engineering Managers," IEEE

Transaction on Engineering Management , Vol. EM-21, No. 2, May 1974,

pp. 42-50.
IX

In each situation, team members from ETIP, the ETIP contractor (PDI)

,

and the regulatory agency jointly analyze an initiative in regulation, or

its implementation as an experiment, and/or perform an assessment of its

effects. Other interested parties are also involved, and the work is

conducted under the management and review structure of the Regulatory

Processes and Effects Project. Consequently, knowledge gained from

similar projects can be shared.

This document concerns the development of an effort with the Federal

Communications Commission (FCC). In fall 1976, ETIP regulatory staff

began to investigate the possibility of developing a joint project with

the FCC. With the assistance of a small contract (Transcom, Inc.), it

conducted preliminary background research on the Commission and developed

three ideas in the area of international telecommunications.

Preliminary discussions continued between ETIP and FCC for several

months. During this time, the discussions revealed the need for a con- siderable amount of definitional and economic research on the telecommunications industry. The Common Carrier Bureau (CCB) Program Evaluation staff

proposed alternatives that included public message telegraph services

deregulation, 2» 3 and a Commission attorney began to investigate the legal

issues involved.

In June 1977, ETIP and FCC staff agreed that there was sufficient mutual

interest in the development of a joint project to justify requesting formal

Commission approval for continued work. The Commission granted formal

approval in July 1977. ETIP and Commission staff then developed a joint

project plan and interagency agreement. The plan, used by ETIP to obtain

National Bureau of Standards' approval, describes:

a project to be carried out with the Federal Communications

Commission (FCC) to identify, design, implement, and assess

1. The initial proposals were entitled: "Eliminating Time Delay

in the Section 214 International Facilities Construction Authorization

Process"; "Elimination of The Requirement That International Record Carrier

Rates Be "Cost Justified' with Section 61.38 Support Data (Rate Deregulation For Existing Carriers)"; and "Expanded Communications Carrier Ownership of Satellite Earth Stations for International Telecommunications."

Transcom, Inc. International Telecommunications Experimental Ideas For

The Experimental Technology Incentives Program , December 7, 1976, 34

pages.

2. Sawicki, Leonard S. Program Evaluation, Common Carrier Bureau of

the Federal Communications Commission, Draft of Internal Working Memorandum

(undated)

.

3. The term deregulation is used here to denote a change in policy,

practice, and/or rules which reduces (but does not necessarily eliminate)

the burden on the regulatee.
X

one or more administrative experiments . . . intended to

obtain knowledge of the agency and commercial impacts of

changes in the FCC regulatory process.

1

ETIP and Commission staff agreed that the public message telegraph

services deregulation, if implemented, might be a change to investigate.

Common Carrier Bureau staff expressed an interest in also using the proposed project as a prototype or test of ETIP's evaluation process, and

suggested that, if successful, the process might be used in other areas within the Commission.

In October 1977, the staffs of the CCB, ETIP, and The Urban Institute

began conducting research. The following activities were included:

o A review of legal authority was completed in December 1977.

2

o The Urban Institute interviewed CCB staff about Commission procedures and specific plans for public message services deregulation.

o The Urban Institute drafted, verified, and revised an initial

report of findings based on these interviews. *

o CCB staff drafted a briefing memorandum outlining the characteristics of the change.

o In July 1978, the Western Union Monopoly Inquiry proceeding

became part of the focus of the ETIP/Urban Institute research

effort to evaluate the impact of a decision, if implemented,

to open competition.

An official Memorandum, Opinion, and Order opening public message

services commerce to competition was prepared by CCB staff and approved by

the Commission on January 25, 1979. The Commission does not view this

decision to change its policy as an experiment. The decision was made for

reasons of policy and not for purposes of research. What is regarded as experimental is the evaluation process being developed, and the ways in

which it can be applied. The Commission has expressed a strong interest

in evaluation results as noted by Commissioner Ferris.

1. U.S. Department of Commerce, Bureau of Standards, Experimental Technology Incentives Program. Experiments in Communications Regulation , Project

Plan for ETIP Project 161, August 1, 1977.

2. U.S. Federal Communications Commission. "Memorandum of Law," from

Richard Severy to David Irwin, dated December 7, 1977.

3. Bell, James: The FCC/ETIP Regulatory Experiment , Working Paper Number

1198-70-01 (Draft), The Urban Institute, Washington, D.C., May 3, 1978.

4. U.S. Federal Communications Commission. "Points Memorandum,"

by David Irwin, et al .

, Summer 1978.
XX

.... I intend to ensure that the Commission monitors the

effects of this policy change. This evaluation will be undertaken by staff of the Common Carrier Bureau in cooperation with

the Experimental Technology Incentives Program (ETIP) of the

National Bureau of Standards. This will enable the Commission

to check its expectations of public benefits, based on today's

reasoned judgment, against subsequent events in the marketplace .1

A proposed rulechange will be presented before the Commission, probably in April or May, 1979, and will be finalized after a public notice

period. The process that the Commission and ETIP will use to manage

the evaluation of the impact of the PMS deregulation over time is

currently being developed.

This report contains our findings to date about the operations of the

Commission and a logic for the proposed project, and assesses important

situations and issues in telecommunications. Using these findings and ETIP/

FCC criteria for success, the report also discusses the possibility of

developing a useful evaluation. It represents the result of approximately

27 person months of ETIP and Urban Institute staff time.

This project will also facilitate communications between the Commission,

industry, and others, such as Congress, that might be interested. We hope

that the report will encourage their interest and suggestions. We also

hope that this report and subsequent products of the evaluation will con- tribute to our understanding of evaluation process and methodology, theories

about innovation, effects of regulation, and other subjects of interest to

members of government, the research community, and industry.

The Regulatory Processes and Effects Project has been screening regulatory situations which might be appropriate for evaluation as administrative experiments. During the coming year, the methods we are developing

will be made more widely available to users. We welcome inquiries from

regulatory agencies that wish to draw upon our experience to date. For

further background the reader may wish to consult the Management Plan for

the Regulatory Processes and Effects Project and the latest proposal to ETIP , Proposal in Response to ETIP Solicitation No. EO-78-3603 .

This document was prepared and submitted under Department of Commerce

Contract #7-35822 by the Regulatory Processes and Effects Project. The report

represents work in progress at this time, and will be revised and updated

1. U.S. Federal Communications Commission News Release. FCC Ends

Western Union Telegram Monopoly; Conditionally Approves Graphnet's Application for Domestic Service (CC Docket Nos. 78-95-96)," Report No. 14735,

Action in Docket Case, January 25, 1979 —CC, Separate Statement of

Chairman Charles D. Ferris.
Xll

periodically, as we advance and receive additional information. These

reports are used for information exchange on the development of methodology

and on substantive results.

It should be noted that the usefulness of the findings about this

deregulation can be increased or decreased by the competency of the evaluation.

The evaluation must be perceived as thorough and impartial, and it must

produce useful findings.
X11X

Page

ABSTRACT iii

ACKNOWLEDGEMENTS v

PREFACE vii

CONTENTS (Volume II) xiii

A. PUBLIC MESSAGE SERVICES CHRONOLOGY (1844 Through January 1979)

Developed by Steven Watson and Sharon Kirby.

B. EXECUNET CHRONOLOGY WITH BRIEF INTRODUCTION (July 1975 Through

June 1978), Developed by Sharon Kirby.

C. SPACE INDUSTRIALIZATION CONCEPT AND IMPLICATIONS FOR TELECOMMUNICATIONS,

by Copper Wilson and Roland Weiss.

D. FINDINGS ABOUT INFORMATION SOURCES AVAILABLE AT THE FEDERAL

COMMUNICATIONS COMMISSION AND ELSEWHERE, By Sharon Kirby and James Bell.

E. POTENTIAL USES OF INFORMATION AND POTENTIAL MEASURABLE ISSUES,

Developed by Steven Watson, James Bell, Sharon Kirby, Paul Nalley

and Roland Weiss.

F. POTENTIAL USERS OF INFORMATION, Developed by Sharon Kirby.

G. FCC NEWS RELEASE ANNOUNCING END OF WESTERN UNION MONOPOLY AND

CONDITIONAL APPROVAL OF GRAPHNET'S APPLICATION FOR DOMESTIC

SERVICE (CC Docket Nos. 78-95-96).

APPENDIX A: PUBLIC MESSAGE SERVICES CHRONOLOGY

(1844 Through January 1979)

(SOURCE: TELECOMMUNICATIONS REPORTS)

Developed by

Steven Watson

Sharon Kirby

A-l

PUBLIC MESSAGE CHRONOLOGY

"Public message telegraph service Is ordinary telegram

service, in which the carrier. . .accepts either written

or oral messages at a public office or via the public

telephone network, transmits those messages to its public

office in another city, and delivers the messages either

in written or oral form to the designated recipient. No

customer terminal equipment is required. Unlike the

customer using public long distance telephone service, the

telegram customer does not subscribe in advance to any

service and get his premises connected to the network."

Graphnet Systems, Inc. , 64 FCC 2d 1023 (1977)

1844

1856

First telegraph line established between Baltimore and Washington.

Western Union is authorized by acts of the Wisconsin and New

York Legislatures to provide the service.

1861

1880s

A transcontinental system is established.

The Postal Telegraph Cable Co. becomes a domestic competitor with

Western Union.

1910

1929

The Mann-Elkins Act established the Interstate Commerce Commission's

regulatory authority over telephone and telegraph communications.

Western Union's regular telegram service hits its peak. Main

competitor becomes Postal Telegraph.

1934 The Communications Act is passed and the Federal Communications

Commission created.

1943 Congress adds domestic merger section 222 to the 1934 Communications Act. The purpose of this legislation is to assure that

the merger of Western Union and the Postal Telegraph Co. would

not violate antitrust laws.

FCC holds hearing (Docket 6517 10 FCC 148 [1943] ) and finds that

the public interest would be best served by a monopoly in the

domestic public telegraph service. Certain "natural monopoly"

conditions of the market were cited. The House Interstate

Commerce Committee's general preference for a competitive market

structure is overcome by the financial difficulties faced by the

Postal Telegraph Co. and by the need to assure a sound telegraph

industry to meet the contingencies of war. Western Union granted

monopoly.

1945 Western Union telegram service hits second peak and enters

declining period. There begins a growth of leased telegraph

services—which in 1977 only constituted approximately 28 percent

of Western Union revenues.
A-2

1956 Press Wireless 21 F.C.C. 311 (1956). The FCC denies the request

by another carrier to initiate a service that would partially

compete with already extant service offerings by Western Union.

Western Union's monopoly position is found justified at that

time. The Commission stated:

. . .Although Western Union is not entitled as a matter

of law to the exclusive grant of pick-up and delivery of

international traffic in the hinterland, the obligation

it has to provide such service at all times, whether

traffic be heavy or light, carries with it the privilege

of continuing to provide service and reap the revenues

of a heavy traffic volume unless it is unable to do so in a manner which will serve the public interest, or some other carrier will provide service which is so superior as to support a filing that a public interest

would be served by a grant of its application.

1958 Western Union enters the exchange (Telex) telegraphy business,

which will soon begin subsidizing other Western Union operationsincluding PMS.

1959 Above 890 Decision . Microwave technology has partially eroded

former economies of scale in the communications industry.

In Docket 11866, the FCC clears the way for the private operation

of point-to-point, long-distance microwave facilities.

1969 Western Union begins a major moderization effort centering upon

its new computer switching facility.

January 1970 Western Union begins its Mailgram service. This service is

a means of communications by which customers input messages

to Western Union which are then transmitted via WU facilities

to a post office of the USPS for inclusion as preferential

mail in the next day's postal delivery. Within a decade this

service will constitute half of all public messages.

April 1971 Western Union acquires TWX from AT&T.

1971 Specialized Common Carrier Decision Docket 18920. This decision

established the current FCC policy in favor of competitive entry

into the specialized commmunications field. This decision leads

to private line services such as MCI and Southern Pacific.

1972 Free Direct Access 40 FCC 2d 1082 (1972). WU believes that

the FCC interpretation of Section 222 in this case represents

a bar to the delivery of the hinterland portion of any international message by any entity other than Western Union.
A-3

1976

January 1977

1973 Western Union inagurates its three Central Telephone Bureaus , which provide natural access to Western Union services through

In-Wats telephone service. Today almost three-fourth's of all

public messages are requested in this manner.

1974 Graphnet Systems, Inc ., 44 FCC 2d 800 (1974). Graphnet authorized to perform specialized "facsimile" transmissions, in which

it "photographs: messages by an electronic scanning process,

sends the signals over inter-city transmission facilities, and

delivers hard copy images of the original messages to facsimile

terminals at the destination point."

Resale and Shared Use Decision , Docket 20097.

FCC authorized Graphnet and Telenet to offer international communications services. International record carriers (IRCs) oppose.

Permission not yet granted by overseas administrators.

Graphnet contracts with ITT World Communications and RCA Global

Communications (Globcom) and FCC approves implementation of

outbound portion of the agreements in tariff —but not inbound.

June 1977 Graphnet files a Section 214 application for authority to provide

certain communications services between the gateway locations of

the U.S. IRCs and Graphnet subscribers in the hinterland of the

U.S. Approval of such authority poses a direct threat to Western

Union's monopoly concerning public message services. FCC rules that

Graphnet tariff does not extend to inbound delivery of international

communications. Graphnet files petition for reconsideration.

September 1977 Several filings by Graphnet regarding proposed tariff services.

Files amendment to its tariff in order to clarify that authorizations granted re ITT Worldcom and Globcom extend to any IRCs with

which they enter agreements. Files a supplement to its petition

for reconsideration of the FCC order which rejected tariff revision

intended to implement that portion of intercarrier agreement with

ITT Worldcom providing for handling of inbound international messages. Graphnet says its supplemental pleading prompted by Court of

Appeals Execunet decision and Globcom' s "free direct access" pleading.

Logic : Graphnet believes limitation to one-way service weakens its

competitive position and makes it nearly impossible to compete with

Western Union, which offers both inbound and outbound service to

its customers.

Western Union files another opposition pleading.

Logic : Western Union (WU) believes result would be to "exacerbate

the diversion of WU's landline haul revenues that is already occurring

by virtue of the implementation of the Graphnet-ITT agreement."
A-4

October 1977

January 1978

March 1978

The U.S. Court of Appeals for the District of Columbia denies

a motion of Graphnet for summary reversal of the FCC's order

granting the application of ITT Domestic Transmission Systems,

Inc., to provide a domestic data service. Court grants a FCC

motion to remand the matter for futher proceedings.

TRT Telecommunications Corporation says Graphnet 's application

to provide services between gateway locations of the U.S. IRCs

and hinterland locations "should be conditioned so as to require

that all outbound traffic transferred by it to the IRCs be

distributed in accordance with the international formula."

Logic ; "The ultimate consequence of approving the present

Graphnet scheme could be to undermine the international formula

provisions that have been so carefully worked out by the Commission

within literally the past few weeks and to substitute for them an arrangement which would make the distribution of outbound traffic

a function of factors having no relationship whatever to the

public interest."

WU asks FCC to deny Graphnet 's amended application to provide

for direct delivery to any subscriber terminal and for mail or telephone delivery to the general public.

Logic : Public convenience does not require the service; diversion

of significant volumes of traffic would have an adverse effect on

WU and its users; and proposed service would violate the Commission's

free direct access policy. Also, WU said, amended application would

undermine the purposes of the new "international formula."

In a related filing, WU says that if Graphnet 's application is

granted and company becomes a public message carier, "there would

be no basis on imposing on Western Union, but not Graphnet, the

special requirements of regulations" such as specified in Parts

63 and 64 of the regualtions. (Part 63 deals with the requirement

that WU secure FCC approval before replacing public offices with

agencies or reducing the hours or quality of services at public

offices. Part 64 requires WU to conduct speed of service studies

of all types of messages, including those delivered by telephone,

messenger, telefax, TWX, telex and over-the-counter.

FCC denies RCA Globcom's petition for reconsideration of its order

allowing Graphnet and Telenet to offer international communications

services.

FCC orders hearings on WU's proposal to earn by 1981 a 28 per cent

rate of return on investment in its TWX and Telex message communications services. (TWX/Telex subsidizes PMS.)

FCC endorses staff decision to let Graphnet provide private-line

(PL) facsimile service to 11 European countries, and for Telenet to

provide PL data transmission to Britain. Assume foreign approvals

may be difficult to obtain.
A-5

Graphnet asks the U.S. Court of Appeals to review the FCC's decision

rejecting certain Graphnet tariff revisions which would have permitted

the company to delivery to its subscribers overseas-originated

message communications, and denying Graphnet 's petition for reconsideration of the June 1977 FCC order which rejected tariff change

proposing to offer the same services at no additional charge to the

sender or recipient.

At Commission meeting, FCC members suggest less detailed telegraph

regulation. At approval of routine rule change involving speed

of service reports, Chairman Ferris asks, "Why are we involved in

this?"

Western Union Monopoly Inquiry FCC 78-96. The FCC issues a M.0.&0.

initiating an inquiry into the regulatory policies concerning the

provision of domestic public message services by entities other

than Western Union Telegraph Company. Hinchman notes that public

message service has changed considerably in its character since

the grant of monopoly in 1943 and that message volume has decreased

considerably. Technological innovation may even make the traditional

market obsolete. Inquiry subjects to include: alternative ways

to provide PMTS; how widespread is demand; PMS' future; essentiability of PMS to public in light of other alternatives such as Mailgram. Scope of inquiry to be as narrow as possible in order

to avoid delay of Graphnet decision. In addition, Commission

says it plans to also review its "free direct access" policy.

June 1978 ITT and Globcom consolidate briefs regarding FCC decision to allow

Graphnet and Telenet to offer international communications services.

They say that FCC decision permits Graphnet, Telenet "to compete

with the existing international carriers, without subjecting these

new competitors to same competitive restrictions it previously

planned on the IRCs .

Western Union Information Systems withdraws from the commercial

market.

Logic : Less dependence on Bell. As a result of move, TWX will

transfer from Bell facilities to Western Union; provision made

for growth of TWX network; and introduction of higher speed

exchange services made possible.

Deadline for comments in FCC's telegraph inquiry postponed to

June 15 at request of Western Union.

1978 The USPS begins experiments in electronic message services

which would supplant public message services of Western

Union.

January 1979 Commission announces a formal inquiry proceeding in connection

with ECOM service.

APPENDIX B: EXECUNET CHRONOLOGY WITH BRIEF INTRODUCTION

(July 1975 Through June 1978)

(SOURCE: TELECOMMUNICATIONS REPORTS )

Developed by

Sharon Kirby

B-l

THE MCI EXECUNET CONTROVERSY

Execunet is a metered-use service offered by MCI Telecommunications

Corporation whereby a subscriber operating any push button telephone (or rotary

dial telephone and tone generator) can reach any telephone in a distant city

served by MCI simply by dialing a local MCI number followed by an access code

and telephone number in the distant city. In July 1975, taking the position

that Execunet was not a private-line service and was not included in the 214

authorization, the Federal Communications Commission (FCC) issued two ordering

clauses: (1) it rejected MCI's tariff insofar as Execunet was concerned and

(2) it ordered MCI to cease and desist offering Execunet.

MCI objected on the grounds that FCC had participated in ex parte meetings

with the American Telephone and Telegraph Company (AT&T) before public hearings

had been held; that the FCC rejected MCI's tariff more than eight months after

the tariff had been in effect (a situation that had not been tolerated in the

case of FCC v. Home Box Office ); and, finally, that Execunet is a private line,

foreign exchange (FX) service and the 214 authorizations issued to MCI contain

no limits or restrictions to private line.

These events mark the beginning of a controversy which is now requiring

the FCC to reexamine past decisions on policy, basic interpretation of the

Communications Act, and the market structure of an important and fast-growing

segment of the telecommunications industry. The effects of the Execunet issue

are reaching far beyond the question of simply whether or not to allow marketing

of Execunet or similar services such as MCI's service 12 or Southern Pacific

Communication Corporation's (SPC) Sprint service. The following chronology

describes the issues, people, and organizations involved as well as the specific

events occurring from July 1975 to June 1978 and was compiled from information

abstracted from Telecommunications Reports .
B-2

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date

July 2, 1975

July 2, 1975 to

November 19, 1976

April 1977

April 28, 1977

May 1977

June 1977

July 1977

August 1977

August 15, 1977

August 19, 1977

Event

FCC's initial order bars Execunet service by MCI

Original stay allowing Execunet marketing by MCI is in

effect

Execunet is put under court stay preventing its expansion

to new customers or service points.

Oral argument on FCC's decision that MCI Execunet

service is not a proper offering.

Customer writes letter to FCC questioning legality of

MCI's service 12 (an interstate, any-telephone to anytelephone service, with local exchange termination).

AT&T asks FCC to order MCI to stop marketing and

providing service 12; charges offering is public

message—not private line.

MCI opposes AT&T's request for FCC order. MCI states

service 12 is "hard-wired variety of Execunet" (lesserincluded Execunet) and protected under court stay.

MCI concedes service 12 is unauthorized, AT&T says in

further plea for cease and desist order; charges MCI with

misapplying stay order.

Court of Appeals reverses, remands FCC ruling. As a result, stay on MCI Execunet marketing to be lifted.

[Case Decision 75-1635] Mandate to be issued August 18.

Logic: Commission has not so far determined that public

interest would be served by a monopoly in the interstate

message telephone service field.

FCC asks court to stay its mandate for 30 days, during

which time the agency will ask Supreme Court for a writ

of certiorari (review). AT&T and U.S. Independent

Telephone Association also request stay of Execunet I decision mandate.

Order not to issue mandate prior to September 19, 1977

U.S. Court of Appeals vacates an order it reissued

earlier in week which would have granted three motions

for stay of Execunet decision mandate.
B-3

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

August 22, 1977

August 25, 1977

U.S. Court of Appeals reissues stay of mandate in Execunet

case pending ruling by Supreme Court.

Court denies MCI's motion to restore the original stay of

July 1975 which allowed Execunet marketing by MCI.

Week of

September 19, 1977 Following a petition for FCC review of Bureau action

rescinding Chicago-Omaha 214 authorization grants to

N-Triple-C Inc. (an MCI subsidiary), MCI asks the agency

to deny a 1978 blanket construction application filed

by AT&T, eight Bell-associated companies and three

independents.

"Sept. 19 [FCC] asked the U.S. Supreme Court to review

and reverse the ruling of the Court of Appeals for the

District of Columbia remanding the FCC's decisions that

Execunet is not an authorized private line service to

the agency ....

"[According to the FCC brief] the question for the

(Supreme Court) is: whether the Court of Appeals erred

in holding that specialized common carriers such as MCI

have authority to provide ordinary long distance telephone service, despite the fact that the FCC, with the

express approval of the Ninth and Third Circuits, had

consistently regarded its specialized common carrier

policy as limited to private line services and had not

made the requisite statutory finding that competition

in ordinary long distance service would serve the public

convenience and necessity. . . .

"The decision leaves in doubt the scope of authority

under certificates and licenses granted to domestic

satellite carriers, 'value added' carriers, and a number

of categories of miscellaneous carriers with similarly

limited grants. The decision also imposes on the Commission a new interpretation of the certification

process under section 214 which will require scrutiny

of applications beyond the proposed services and which

may bring into question the validity of numerous grants

made under the agency's own interpretation of that

statute. il

1. Telecommunications Reports , Volume 43, No. 38, September 26, 1977.
B-4

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

Week of

September 19, 1977 "MCI and SPC [opposed] the requests of the FCC, American

Telephone and Telegraph Co., and U.S. Independent

Telephone Association for Supreme Court review of the

lower court's decision. . . .

"SPC declared that 'This case presents (1) a narrow

question of statutory interpretation, i.e., whether section 214 of the Communications Act permits the Commission

to impose restrictions by implication on a carrier's cer- tificate of public convenience and necessity without an affirmative finding that the restrictions are required,

and (2) a narrow question of fact, i.e., whether the

Commission has done so by restricting specialized car- riers to private line services. . . . [the court] has

made no ruling on the lawfulness of Execunet, or of the

AT&T monopoly in (message toll) services [MTS] , or on the

proper dividing line, if any, which may be drawn between

MTS and private line services, or between authorized and

non-authorized services. All these matters are left to

the Commission to decide.'"*-

Justice Department indicates that no decision will be made

on the department's position unless the Supreme Court decides to review Execunet.

October 1977 AT&T sees "substantial evidence" that MCI is violating

FCC and court orders on Execunet. Asks Commission for

cease and desist order; cites MCI advertising, orders

for "unusual quantities" of local service for use in

connection with Execunet and service 12.

Week of

November 7, 1977 MCI replies to FCC's request stating it is an excuse to

carry on propaganda campaign; MCI asks equal time on telephone news; denied marketing Execunet service, in response

to charges, MCI states it would welcome FCC review of its

order and installation files.

December 1977 Solicitor General, Justice Department, agrees that high

court should review Execunet.

January 16, 1978 Supreme Court denies writ of certiorari petitions.

FCC reaction : will not issue further facilities

authorizations to specialized common carriers unless

they provide specifically and solely for private line

services.

1. Telecommunications Report , Volume 43, No. 38, September 26, 1977.
B-5

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

January 19, 1978 FCC formally reports AT&T filing of petition for a declaratory ruling and expedited relief "affirming

that petitioners have no present obligation to provide

additional connections to local exchange service to

other common carriers for their use in provision of

service offerings which are not private line services.'

[File docket 19896]

Logic: Specialized common carrier decision. The

opponents of AT&T's petition parry with the antitrust

issue.

Last week of

January 1978 FCC Chairman Ferris says, contrary to "some speculation,"

decision does not automatically open entire long-distance

market to competition. Specialized carrers free to use established facilities to introduce new services, but

Commission must have proceeding of some kind before additional facilities can be authorized. Looks toward broad

inquiry in the future.

First week of

February 1978 AT&T maintains its position, and notes that petition is

"not directed to the connections petitioners provide to international record carriers and value-added carriers in their

provision of existing services"—which are not functionally

equivalent to MTS.

Continental Telephone Corporation petitions FCC to bar

Execunet-type services.

In responding to Continental's position, Southern Pacific

declares FCC, to grant the petition, must make the following assumptions: (1) Execunet-type service will

divert revenues from interstate MTS rather than merely

capturing a portion of growth segments of the market

(10%) not currently served by any carrier; (2) present

results of the separations procedure must be protected

from any potential impact from authorized services of

specialized common carriers; (3) that public interest is

served by the Commission's taking an affirmative action

protecting the monopoly of existing carriers solely on

the basis of unsubstantiated and unquantified allegations

of potential impact upon that monopoly by specialized

common carriers; and (4) that the status quo Continental

seeks to preserve involves a lawful rate structure for

interstate MTS.
B-6

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

February 2, 1978 U.S. Court of Appeals for D.C Circuit issues its order

vacating Commission rulings regarding Southern Pacific

Sprint issue (Execunet-like service) . Southern Pacific

maintains that court's order "makes it clear that the ex- ceedingly narrow interpretation of the Court's mandate in

the Execunet case urged by Bell will not be countenanced."

February 3, 1978 Southern Pacific files new Sprint tariff.

February 22 to

23, 1978 National Association of Regulatory Utility Commissions

(NARUC) Executive and Communication Committees meets in

Washington. At suggestion of New York Commissioner Larkin,

initiates project to develop interest findings in connection with current competitive environment in telecommunications. Responsibilities of project include:

analyzing impact of competition on consumers; defining

role of NARUC; developing ways to improve states' input

into FCC deliberations.

February 23, 1978 FCC grants AT&T request for declaratory ruling that it

is not obligated to connect for Execunet; rejects Southern

Pacific's Sprint V tariff; and launches market study into

MTS, WATS to determine if public interest necessitates

monopoly or competitive environment.

"The FCC observed that 'A principal question we intend to

explore has to do with the industry's division of revenues

and settlements. While the Commission has approved jurisdictional separations— the procedures for allocating plant

operating and investment costs between state and federal

jurisdictions—and there is presently pending a federalstate joint board proceeding, docket 20981, looking toward

possible revisions in the current jurisdictional separations, the division of revenues and settlements have traditionally been industry devised.

"'It may be timely to exercise our jurisdiction under

section 201(a) of the [Act] to establish the division of

charges.' The FCC added the belief that it is 'necessary

to formulate policy' in the area of interstate MTS and

WATS [Wide Area Telephone Service] subsidy to local

exchange service.
B-7

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

"It continued, 'We therefore propose to determine what

reimbursement interstate services should make to local

operating companies for the use of local plant, on a cost causational basis; what additional charges, if

any, should be levied on interstate services to support

local exchange services; and whether and how these

charges can be equitably imposed on all interstate

services.

"'For the purposes of this issue, we will be examining

all interstate services of all carriers, not just MTS

and WATS. With these questions satisfactorily resolved,

we will be able to examine the industry structure question

for MTS and WATS on its intrinsic merits, unbeclouded

by an issue that can be independently resolved.'

"The FCC went on, 'Another area that warrants attention

is the industry practice of rate averaging for MTS so that

uniform rates prevail nationwide. The Commission has

never approved or prescribed any particular rate structure

for MTS. It appears essential to reach a public interest

determination on this rate averaging practice here, since

a finding in favor of a uniform rate structure nationwide—

at least for some kind of basic MTS service available to

all persons—would seem to imply a single integrated

offering and possibly foreclose competitive offerings of

the same kind of MTS service.'

"It declared, 'a further important area concerns the

extent to which the MTS facilities and service may be

severable. . . The sole question in this proceeding goes

to the possible duplication of intercity facilities and

the feasibility of competition in the provision of the

intercity portion of interstate services. Within the

latter framework, questions arise as to whether the

MTS and WATS services are a monolithic whole or whether

WATS could feasibly be provided on a competitive basis

even if the public interest should decree that MTS, or

at least basic MTS, must be a single, integrated offering.

"'If we should decide that the public interest requires

a single, integrated offering of basic MTS service, a question would remain as to whether competition should

be permitted in the fringe areas of MTS. To the extent
B-8

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

that WATS and fringe MTS services may now siphon off

traffic from the basic MTS service, is such siphoning in

the public interest, and should this determination vary

depending on whether the WATS and fringe MTS services

are open or closed to competition?'

"Further, the Commission reported, 'We will, of course,

be exploring such factors as the best means of achieving

low costs and charges to the public, technical and operating efficiency, network planning and management, innovation, and how best to satisfy the service needs and

desires of the public. ... In the event of a determination that some measure of competition would be in the

public interest, the associated question of interconnection under section 201 of the Act would also be

determined . '"1

February 24, 1978

February 27, 1978

March 1978

Chairman Ferris issues 11-page statement on MTS, WATS

inquiryfirst policy declaration in this area .

Southern Pacific files petitions for review by the D.C

Court of Appeals of two FCC actions: grant of AT&T

declaratory ruling and rejection of its Sprint tariff.

FCC announces that MCI letter stating it is unlawful for

FCC to delay authorizations of specialized common carriers

while granting them to telephone companies will be con- sidered a comment on Continental Telephone Company's

request to bar expansion of Execunet services.

Regarding MCI's request for mandate enforcement, FCC says

that there is nothing in the court's mandate which would

require action different from ones it took.

MCI, Southern Pacific reply to opponents in Execunet mandate. MCI again expresses belief that "Execunet should be

classified as shared FX service, and hence a legitimate

private line service." Southern Pacific submits FCC must

vacate Sprint V opinion as directly in conflict with the

Court's Execunet decision.

1. Telecommunications Reports, Volume 44, No. 9, March 6, 1978.
B-9

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

March 1978

continued

March 22, 1978

Continental asks FCC to defer action on its petition

at least until the U.S. Court of Appeals for the District

of Columbia rules on MCI's pending appeal of two FCC

orders which serve to moot the need for an order prohibiting Execunet service's future growth.

Commenting on MCI's letter, Continental says MCI did not

"effectively challenge the Commission's basic authority

to grant section 214 applications for new facilities on

the condition that they not be used to provide specified

services until and the unless the Commission determines

that the public convenience and necessity requires such

services." The Execunet decision does not obviate the

need to make a public interest determination under sec- tion 214(a) of the Act before granting MCI's applications

for new facilities.

Commission turns down an associated petition of MCI to

enforce the Court of Appeals' mandate and require AT&T

to provide local connection facilities to Execunet.

Logic: There is "no valid public interest basis for

granting the instant petition." The Commission also

reminds MCI that, when it rejected SPC's Sprint V

tariff, it pointed to the carrier's opportunity to

seek a specific interconnection proceeding under sec- tion 201(a) of the Act.

April 1978 For the first time in history, NARUC names officials

of a non-member governmental entity—specifically,

three Rural Electrification Administration (REA)

telephone officials—as observers on its prinicipal

communications committees. Appointments: Ballard

named to the NARUC Communications Committee; Norris

to the staff subcommittee on communications; and

Rose to the staff subcommittee on separations and

toll rate disparity.

REA expresses concern about impact of competition

on small and rural telephone companies and plans to

makes information on their operations developed over

28 years by REA available to policy makers. Central

issue: Can small telephone companies continue to

serve the public under the emerging common carrier

policies of the FCC?
B-10

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

April 1978

continued REA will provide information as called for by the FCC,

Congressional committees, the new NTIA at Commerce and

associations with similar concerns such as the National

Telephone Cooperative Association, Organization for the

Protection and Advancement of Small Telephone Companies,

and the REA Borrowers Association. REA officials point

out that, systemwide (930 small companies), the borrowers

obtain about 55 percent of their total revenues from

toll. They have calculated that the loss of 50 percent

of toll revenues (not inconceivable in time without some

mitigation) would result in local services rates on the

average two and a half times as high. Lower percentage

losses, of course, would have proportionate impact on local exchange rates. And, an REA official emphasizes

that "The REA borrower bleeds as much whether his

throat is cut by Bell or MCI. And this is not a theory."

April 7, 1978 AT&T files motion to dismiss MCI antitrust complaint

in its entirety.

Logic: Complaint involves matters already considered

and mostly settled by FCC; for example, "the extent to

which the general service carriers were obligated to

interconnect with the specialized common carriers and

to provide joint services that would permit the specialized common carrier to provide a greater range of ser- vices over a greater geographical area than they were

prepared to provide on their own," "the prices, terms

and conditions under which the Bell System would provide

local facilities to the specialized common carriers,"

and "the appropriateness of the responses of the Bell

system to the creation of the specialized common carriers, particularly the question of the nature and

extent of any adjustments in the Bell System's rates

for interstate telecommunications services." AT&T also

says, "A long line of cases has firmly established the

principle that antitrust jurisdiction cannot properly

be asserted over matters that are subject to pervasive

regulatory jurisdiction."

April 1978 U.S. Court of Apeals for the District grants MCI's

motion for an "order directing compliance of the

[Execunet] mandate of this court."
B-ll

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

April 1978

continued

April 1978

Logic: MCI's facilities authorizations encompassed

Execunet service precisely because the specialized

carrier (policy decision) did not explicitly and affirmatively exclude this type of service from consideration. The court ruled that AT&T has an obligation to

provide interconnections for Execunet.

Mandate under stay; FCC awaits decision on whether U.S.

Court of Appeals for District will rehear the ruling.

MCI petitions FCC to deny AT&T 1979 blanket construction

applications.

Logic: The instant application [of AT&T] cannot be

granted—unless the applications of all carriers are granted under the same terms as such applications are granted to Bell—until the MTS/WATS inquiry is terminated

and the Commission is able to make a decision—based on substantial evidence in the record—that it is in the

public interest to authorize competition in the provision

of public voice services, or that the public interest

requires the granting of exclusive authorizations to

Bell rather than to any other carriers.

AT&T response: The continued provision of adequate

and efficient MTS and WATS is required pending the outcome of the MTS and WATS proceedings. It would indeed

be a perversion of the Commission's processes—and the

purpose of the MTS and WATS proceeding—if the Bell

companies were denied the temporary authority granted

here.

April 1978 MCI, in petition for reconsideration, against asks

Commission to reject AT&T multischedule private line

(MPL) voice grade tariff and reinstate voice private

line rates.

Logic: MCI states the Commission has refused to reject

the MPL tariff primarily because of the desire to maintain order in the voice grade private line market and

asserts that, since the specialized common carrier policy

case was decided, the Bell series 2000/3000 private line

voice grade rates against which the other common carriers

must struggle to survive have been patently unlawful,

lacking in adequate cost support and predatory in their

effect on competition.
B-12

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

May 1978 While awaiting word on rehearing the U.S. Court of

Appeals Execunet ruling, FCC takes position, "en banc

court should take the case because Execunet II effectively writes section 201(a) out of the Act, because

the Commission has not yet made the important policy

determinations this decision presupposes, and because

the decision ignores the established principle that

carriers have no obligation under common law to interconnect their services or facilities .... [court]

panel's action also conflicts with settled Supreme

Court precedent establishing limitations on the power

of reviewing courts in relation to administrative

agencies."

Appellate tribunal turns down requests for rehearing;

FCC seeks U.S. Supreme Court review of most recent

decision. Denial appears to put telephone companies'

applications into hearing process, if plan is to ex- pand MTS/WATS over competitive routes; FCC says clear

all carriers' applications over competitive routes are involved. As a result, FCC passes over projected ex- tension of Dataphone digital service (DDS) to 96 cities.

Unofficial notice outlining policy was given to affected

common carriers by FCC:

"Below are listed three categories of facilities:

(1) those not used for MTS/WATS /Execunet-type services;

(2) (a) those used for MTS/WATS /Execunet services between

non-competitive service points; and (2)(b) those used

for MTS/WATS /Execunet services between competitive

service points. Pending completion of the MTS/WATS

and PMS [public message service] market structure

investigations (and absent a reversal of the court's

interconnection order) , the bureau proposes to deal

with each of these categories as follows:

"(1) Facilities required to expand competitive service

offerings (other than MTS, WATS, PMS or their equivalents), either quantitively or geographically, will be

authorized. Grant will be subject to other conditions

or considerations, as appropriate. However, in order

to have a particular application included in this

category, applicants will be required to demonstrate

with specificity that these facilities will not be
B-13

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

used to expand existing MTS. WATS, PMS or equivalent

service offerings, either in quantity or geographic scope

.

In addition, applicants must show that the requested

facilities will not be used to offload any existing ser- vices in order to allow diversion of previously granted

facilities for expansion of public message-type services.

"(2) (a) Facilities required to maintain acceptable

quality standards for public service offerings, i.e.

MTS, WATS, PMS, between points not currently served

by competitive offerings will be authorized subject to

whatever other conditions and considerations exist.

In order to have an application considered in this

category, applicants must demonstrate with specificity:

(a) the potential impairment of service quality posed

by failure to authorize; (b) the absence of directly

competing alternatives offered by other carriers; and

(c) the measures which will be taken to ensure that

the facilities will not be used to offload traffic

from competitive routes in such manner as to provide

the applicant a competitive advantage in serving those

routes during the pendency of the investigation. This

would recognize, however, the hierarchical nature of some services.

"(2)(b) Facilities required to extend or to expand MTS,

WATS, PMS, or their equivalents, where competition

currently exists in the public message market, or where

a potentially competitive service is offered, will not

be authorized until it has been determined, through an appropriate hearing, whether the public interest will

best be served through the introduction or expansion

of such competitive public message service offerings,

or through some allocation of the public message

services on this route among one or more carriers.

This hearing generally will be undertaken as part of

the MTS/WATS and PMS investigations. However, individual hearings may be instituted where the applicant

shows good cause in the public interest for such

actions."^-

1. Telecommunications Report, Volume 44, No. 19, May 15, 1978.
B-14

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

May 1978 FCC receives preliminary comments on MTS/WATS market

structure inquiry which suggest three alternatives

facing Commission: (1) present natural monopoly

approach "possibly with some regulated competition";

(2) free and open competition; or (3) creation of a separate entity to own all long-distance transmission

facilities employed for any purpose. Lessees of

facilities from this separate entity would be free

to operate in an openly competitive and unregulated

marketplace, offering packages of services and prices

which they determine to be advantageous from a com- petitive business standpoint.

May 1978 The Office of Consumer Affairs urges the Commission to

take all necessary steps to promote public participation in the decision-making process since the basic

issues involve social choices regarding the nature of

the future telecommunications systems. It said,

"Participation in the process of deciding these issues

should not be limited to those parties with recognized

technical expertise in the area, especially since most

of those parties have an economic interest in the outcome of the proceeding."

May 1978 In its first action of a tariff administration-type

relation to Execunet, in response to MCI tariff revisions

to add 16 cities to Execunet service, FCC tells MCI that

under section 61.38 of the FCC's rules, tariff revisions

require 70 days notice instead of 15, and more support

data.

May 12, 1978 Oral argument in Justice Department's antitrust suit

against AT&T.

May 18, 1978 In major policy change, International Communications

Association (ICA) members authorize regulatory liaison

committee to take more active role in regulatory and

legislative matters; Vennum, Deakin, Isaacs, Fallat,

and Heide in top positions. President Carter sends

letter referring to creation of NTIA and suggesting

close cooperation between ICA and NTIA.

Commenting on Execunet decision at May 15 to 19

annual ICA conference, FCC Chairman Ferris says,

"some services whose impact on the public interest

is yet unknown may be implemented; and some of the

Commission's established procedures are in disarray;
B-15

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Date Event

and some portions of the Communications Act, after 44 years of

interpretation, are unrecognizable." Hinchman declares that

the public is presently vulnerable in two areas: potential deaveraging of nationwide MTS/WATS rates and potential loss of

MTS/WATS revenues which now defray part of the cost of local

exchange facilities. He says that if the telephone industry

chose to file deaveraged rates, it would be very difficult for

the Commission or anyone else to challenge such a rate structure, whatever it might be, given the paucity of relevant

cost and related information presently available.

Late May 1978 FCC CCB directs MCI to subject its tariff revision adding

ten cities to Execunet to be effective August 2 on full

90 days statutory notice. AT&T files a petition to reject

both ten-city extension and a prior six-city extension.

Stay on Execunet decision still in effect pending petitions

for review. Opponents of stay contend issue disposed of

when Supreme Court refused to review Execunet I; petitioners

declare whole new set of reviewable issues raised by Execunet

II —most notably, interconnection issue. AT&T and MCI offer widely divergent forecasts of what revenue effect will

be if specialized common carriers go ahead with full-fledged

offerings.

ECC again passes over DDS 96-city extension, which is tied

to FCC reexamination of its 214 authorization policies and

passes over MCI's petition for reconsideration of the FCC's

latest order in multischedule private line docket 20814.

Series of recommended legislative changes offered by the

organization representing specialized common carriers to

the House Commerce Group—the Ad Hoc Committee for Competitive Telecommunications (ACCT). ACCT urges Congress

to make clear FCC has primary jurisdiction over anything

to do with interstate service. Calls for time limits on

FCC of 12 months to decide rate cases and six months for

facilities authorizations. Says FCC should be empowered

to exempt competitive activities from tariff filing re- quirements of the Act. ACCT proposes that Congress ask

FCC to move ahead and recommend legislative changes in

the following areas: (1) questions as to the proper
Date

June 1978

June 7, 1978

B-16

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

Event

procedures for determining toll settlements and jurisdictional separations; (2) criteria for carrier accounting,

depreciation and other costing practices; (3) questions

about the impact of competition on rates and the availability of service, and methods of mitigating any desirable effects; (4) questions of monopoly and competitive

roles in the interstate communications industry; and

(5) questions about the need to require the separation

of monopoly and competitive services.

Supreme Court refuses writ of certiorari on Execunet II.

Court of Appeals stay is terminated.

"Communications Act of 1978" (HR 13015) introduced in

the House. Would rely mostly on competition to make

available diverse, efficient services at affordable

rates. Proposes end to separations process, with new

"universal service compensation fund" to comprise

network access payments from intercity carriers set

and distributed by new Communications Regulatory

Commission. FCC would be abolished and NTIA would

be moved to the Executive Branch. Would virtually

eliminate role of state commissions in regulating

inter-state-connected services. Proposes end to

tariff suspensions, and refund provisions for competitive services. Recommends sweeping changes in administration of international services and facilities.

Permits any common carrier to provide any telecommunications

service through a separate subsidiary. Only exception would

be that carriers providing services found to be noncompetitive

could not engage in communications manufacturing.

JUNE 1978 FCC lifts freeze on processing of all carriers' 214

applications. Interim policy proposed will not be

followed. In essence, providing for wide open grants

of authority for all types of services, pending outcome

of MTS/WATS market inquiry.

Chairmen of the Senate and House communications . subcommittees write the FCC endorsing the concept of the AT&T

exchange network facilities for interstate access (ENFIA)

tariffs and the Commission indicates it will take up the

next moves of the MTS/WATS inquiry in July, quite possibly

including establishment of a federal/state joint board to

consider separations changes and interim establishment of

a network access charge applicable to all interstate car- riers and services connected to the public switched

telephone network. The interim network access charge

is considered by some a possible alternative to the ENFIA

approach in supporting local service to which all intercity carriers have access under recent developments

.
B-17

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

June 1978 In view of related events of past year leading to several

continued court orders addressing ex parte contacts (including Execunet)

,

FCC adopts interim procedures for recording of public ex parte

contacts in rulemaking procedures.

Requests for rejection or suspention of MCI's tariff filings

extending availability of its Execunet services to 16 more

cities moves closer to decision at FCC, as MCI opposes the

AT&T's suspension request and AT&T replies to MCI's answers

to its earlier rejection petition.

MCI opposes request to FCC by Lincoln, Nebraska Telephone & Telegraph Company that MCI's tariff extending Execunet to

additional cities (including Lincoln) be suspended. MCI says

that diversion of revenues by Execunet service from Lincoln

Telephone (with the facilities in question) would actually be

less than 10.8 percent of Lincoln Telephone's "study" results.

Further, MCI expresses the view that the independents are as bound as Bell Co. by the FCC's 1974 ruling, later affirmed in

court, that non-discriminatory local connections must be furnished.

In response to request for more information from FCC, AT&T

official announces that in addition to segregating costs now

included in the "other" categories of FDC-7 (fully distributed

cost) studies, such as those for facilities now provided by

the AT&T long lines department to other common carriers and to

WU under contract, the new categories will include "the costs

for facilities presently provided by Bell System operating

companies to other common carriers and IRCs under the Bell

System operating companies' tariffs and to Western Union under

contract.

The Justice Department says that development of local exchange

and intercity long distance services under regulation, as well

as manufacturing activities, show pattern of antitrust violations by AT&T.

FCC denies MCI's petition for rejection of the AT&T MPL tariff

and a return to previous rates

.

NARUC/REA subcommittee on study of competition holds its first

meeting with outside organizations to define the public interest

in communications. Outside groups: Citizens Communications Center 3 Common Cause, Consumers' Union, Consumer Federation of America,

and the United Church of Christ's Office of Telecommunications.

The Institute of Electrical & Electronics Engineers forms U.S.

Activities Board Committee on Telecommunications Policy.
B-18

CHRONOLOGY: THE MCI EXECUNET CONTROVERSY

June 1978 At the Pennsylvania Independent Telephone Association convention,

Continued Chairman Theodore F. Brophy warned that the telephone industry

is in danger of repeating ; the basic mistakes of the French high

command at the outset of World War II, when it was defeated by

an approximately equal force in 35 days. "France fell because

of bad leadership. A similar kind of bad leadership, among

ourselves and others in our position, could bring about the

destruction of the American telephone industry. . . . First,

I'm afraid some of us still believe that traditional telephone

companies can survive, and even grow, through a policy of static

defense—through an entrenched reliance on the past . . . Second,

we must learn completely the lesson we've only begun to glimpse:

that our competitors will not observe the rules of the game.

There's no better illustration of that than Execunet."
APPENDIX C: SPACE INDUSTRIALIZATION CONCEPT AND IMPLICATIONS

FOR TELECOMMUNICATIONS

by

Copper Wilson

Roland Weiss

C-l

SPACE INDUSTRIALIZATION

I. THE CONCEPT AND THE LINK

One example of a formal technology transfer program is the Space Industrialization program conducted by NASA. The concept of Space Industrialization

was defined by a director of NASA's Advanced Programs Office as follows:

Space Industrialization is the use of space flight for commercial

or utilitarian purposes; that is, the use of space to produce a salable/profitable product or a service which companies as a business

expense or citizens through their taxes are willing to pay for.

Other basic uses of space, of course, include Scientific Research

and Exploration, typified by the Voyager and Apollo programs and

National Security. But .... I believe the prospects [for space

industrialization] are bright enough to say that they may form the

nucleus for a third industrial revolution.

The main attributes of space include:

• overview of the earth (essential to communications); and

• high space orbits which give extended lifetime to space systems.

Other attributes of the space environment which may also be relevant are:

• zero-gravity;

• a near-perfect vacuum which makes manufacture of certain

products in space more cost-effective and efficient than manufacture on earth (particularly in the electronics and pharmaceuticals industries);

• the presence of an unlimited reservoir for disposal of waste heat

or storage or disposal of waste products; and

• uninterrupted solar energy.

1. Disher, John H. , Advanced Programs, Office of Space Flight, NASA,

Washington, D.C., "Plans and Projections for Space Industrialization,"

a talk for the Near Earth Space Utilization Special Seminar Series of the

MIT Department of Aeronautics and Astronautics, December 8, 1976, (unnumbered).
C-2

NASA's five-year plan delineates the steps it believes are important

in their Space Industrialization plan. One aspect of the five-year plan

calls for bringing new "communications systems into operational use which

will make available to the American people a variety of new communications

services. It will create opportunities for new service businesses. ..."

In October 1977, Robert Cooper, Director of NASA/Goddard Space Flight

Center, stated:

The research and development for future systems will include

studies by NASA of large space antennas with multiple beam

capabilities, propagation characteristics, spacecraft transponders, low-cost ground terminals, satellite switching

techniques and multiple access arrangements.

NASA indicates that, at this stage, the main utilization of space satellites is in the area of communications (other uses are weather satellites,

navigation, mapping, and earth resources surveying). Commercial communications

firms such as Ford Aerospace & Communications Corporation and Western Union's

Space Communications, Inc., are using satellites to perform various services.

John H. Disher, Director of Advanced Programs, Office of Space Flight, believes

3

that "Communications by itself constitutes a multibillion dollar Space Industry.

NASA's long range plan for communications via satellite includes a public

service platform which in NASA's belief is an important step to the industrialization of space. This proposed communications platform would have three

antenna groupings covering a wide range of possible services such as personal

4

communications, advanced television, electronic mail, teleconferencing, etc.

1. NASA. "Report on NASA Five-Year Planning, Fiscal Years 1978 through

1982," Washington, D.C., October 12, 1976, p. 52 (draft).

2. Cooper, Robert. Director, NASA/Goddard Space Flight Center, "Remarks,"

for the PSSC Second Annual Conference on Satellite Communications for Public

Service, Washington, D.C, October 5, 1977.

3. Disher, John H. , oip_. cit . , p. 2.

4. Kline, Richard L. "The Space Station and Space Industrialization," a paper presented at the Bicentennial Space Symposium, Washington, D.C, October

6-8, 1976, p. 4.
C-3

Inherent in NASA's concept of Space Industrialization is a relationship

between government and private enterprise:

Space Industrialization, by developing the permanent and productive

use of environments beyond Earth, must be based on the economic

principles of cost effectiveness and commercial competition * This

in itself presupposes the introduction of "stepping stones" to the

overarching concept of Space Industrialization in order to facilitate the transfer of the investment capitalization from the public

(Federal Government) sector to private industry. Since capital

costs and interest rates are significantly affected, as is inflation, by the length of time and the extent to which investment

capital is tied down unproductively in development (requiring

discounting) , return (pay-back) times on investment and the time

until breakeven must be minimized. In addition, the higher the

confidence level that influential features of the future Space

Industrialization systems /programs can be maintained within ac- ceptable tolerances, the lower the risk to the investor.

[Emphasis added.]

This "transfer of investment capitalization" could be of interest to

investors, those in various industries, and to proponents of space exploration.

Figure 1 shows NASA's description of a four-stage process for transfer

of a space industrialization "product" from the public to the private sector.

In the first stage the concept is developed with government funding. Government subsidized process evaluation occurs in the second stage with industry

participation. In the last two stages, industry—without government subsidization—utilizes the process and carries out production of the product.

Candidate activities for such process may include: information transmission for public services (which would encompass, among other services, data

transmission, person-to-person communications, and electronic mail); manufacturing in low-earth orbit; lunar and solar industrialization; space light

illumination; and space microwave power (long-distance relay of power from

source to user center).

1. von Puttkamer, Jesco. "The Next 25 Years: Industrialization

of Space: Rationale for Planning," British Interplanatory Society , Vol. 30,

No. 7, July 1977, p. 259.
C-4

SPACE PROCESSING PRODUCT EVALUTION

I 'CONCEPT FEASIBILITY

ZERO -G- EXITS TO

VEST! FY THEORETICAL

PREDICTIONS

GOVEHNaE.NT FUNDED )

II PHOCES5 EVALUATION

TESTS 1EXPTS TO

DETERMINE ENVIRONMENTAL

LIMITS. PROMISING METHODS & PROCEOURES

(

MARKET ANALYSIS ANO RETURN ON

INVESTMENT

INDUSTRY PARTICIPATION GOVERNMENT SU8S10IZEO

III PROCESS OPTIMIZATION

EXPERIMENTAL PROTOTYPE FOR OPTIMIZING PROCESSIV PILOT PIANTS/PROOUC710S

PROOUCTION IN QUANTITIES TO MEET A GROWING MARKET IN TIME

INDUSTRY SUPPORTED >

SPACE SYSTEM ACCOMMQOATIOH

SOUNOING ROCKET -

SHUTTLE SORTIE-SPACE -IA8

SPACE STATION

FREE FLYERS -SHUTTLE OR

' STATION TENOEOS

FIGURE 1: NASA PLANS FOR STEPS IN TRANSITION OF FINANCIAL SUPPORT

FROM GOVERNMENT TO INDUSTRY

Source: Disher, John H. , op_. cit »
C-5

Over the past years, many aerospace-derived innovations have been transferred to private and public sectors. Many of these innovations and improvements, carried out under NASA contract and within NASA itself, have been

announced in a NASA Technology Utilization Office publication called Tech

Briefs. Many technological transfers may be possible in the future, including

manufacturing.

B. SUMMARY

NASA's Space Industrialization concept is just one formal technology

transfer program. Others may exist. Technological transfer may occur between

industries with little or no obvious connection. For example, Allen and

Company, a high-risk investment firm, is an underwriter of specialized common

carriers in the communications industry. Allen and Company is also involved

in the drug industry: they introduced oral contraceptives on the market

several years ago. Technological transfer may also occur between more obviously

connected industries such as between industries that use microwave transmissions

Government subsidization of initial or later steps may be the primary factor

for transfer to occur or even for the innovation to occur. Or private industry,

such as high-risk research and development firms, may be the connecting link.

Since the influence of government R&D spending on the telecommunications

industry over the next fifty years might be important, three aspects would

116 pp.

1. Haggerty, James. Spinoff 1977, An Annual Report , NASA, January 1977,
C-6

seem to demand attention: (1) how innovation is transferred from the public

to the private sector, (2) the actual amount of impact on innovation across

industries of high-risk research and development efforts funded by the government, and (3) what implications do factors such as these have for the role

of the regulator in fulfilling its responsibilities.
APPENDIX D: FINDINGS ABOUT INFORMATION SOURCES AVAILABLE AT THE

FEDERAL COMMUNICATIONS COMMISSION AND ELSEWHERE

by

Sharon Kirby

James Bell

| This appendix Is a draft report which describes the preliminary

| tasks undertaken by ETIP, its contractor, Commission staff, and

| a few telecommunications industry-related organizations in order

| to identify sources of measurement information (especially with-

|in the Commission), and to gather material used to prepare the

levaluability assessment report.
TABLE OF CONTENTS

A. INTRODUCTION

B. EVALUATOR OBSERVATION OF CCB OPERATIONS

1. FACILITIES

2. TARIFF REVIEW

a. THE RULES REGARDING TARIFF

b. TARIFF REVIEW OPERATIONS

c. INFORMATION ABOUT REVIEWER'S TIME

d. INFORMATION ABOUT THE CARRIERS FOUND IN TARIFF REVIEW

e. ANALYSIS OF OFFICIAL TARIFFS

3. OTHER SOURCES BESIDES TARIFF AND FACILITIES

C. INFORMATION SOURCES OUTSIDE OF CCB •

D. SUMMARY

D- 1

D- 4

D- 4

D- 7 D- 7 D- 7 D- 9

D-13

D-19

D-23

D-23

D-25

FIGURES, TABLES AND EXHIBITS

FIGURE D-l:

FIGURE D-2:

TABLE D-l:

TABLE D-2:

EXHIBIT D-l;

EXHIBIT D-2:

EXHIBIT D-3:

TABLE D-3:

TABLE D-4:

FIGURE D-3:

FIGURE D-4:

FIGURE D-5:

FIGURE D-6

FIGURE D-7

FIGURE D-8

FIGURE D-9:

FCC OPERATIONAL ACTIVITY D- 2

ACTIVITY INTERFACES AMONG ENTITIES IDENTIFIED IN EARLY PHASE

OF EVALUATOR CONTACT—BASED ON INTERVIEWS WITH FCC STAFF D- 3

SAMPLING OF 214 APPLICATIONS BY SPECIALIZED COMMON

CARRIERS CONDUCTED MAY 1978 BY UI STAFF D- 5

NOTICE/PETITION PERIOD GUIDELINES AS SPECIFIED IN

SEC. 61.38 OF 47 CFR D- 8

SAMPLE OF TARIFF CHECKLIST FORMAT D-10

SAMPLE OF COST SUPPORT MATERIAL CHECKLIST D-ll

EXPLANATION OF 61.38 D-12

DISTRIBUTION OF TARIFF ACTIVITY BY TYPE OF CARRIER D-14

WESTERN UNION TARIFF ACTIVITY FROM SEPTEMBER 1976

THROUGH APRIL 1978 D-14

TOTAL NUMBER OF FILINGS MONTHLY D-15

PERCENTAGE OF TOTAL FILINGS FOR EACH CARRIER TYPE (BASED

ON APPROXIMATELY 82% OF OFFICIAL FILINGS) D-16

TARIFF FILINGS BY TYPE CARRIER—SEPTEMBER 1976 THROUGH

APRIL 1978 D-17 and D-18

WESTERN UNION TARIFF FILINGS BY TYPE D-18

COUNT OF COMMON CARRIERS—AS OF AUGUST 1978 D-20

COMPARISION BETWEEN MCI FAXNET AND SOUTHERN PACIFIC

FAX DATA SERVICES D-2

2

CONTENTS OF STATISTICS OF COMMON CARRIERS D-2

4
D-l

APPENDIX D

A. INTRODUCTION

In early 1978, Urban Institute staff conducted interviews with FCC

Common Carrier Bureau staff. Urban Institute Working Paper 1198-70-01,

which resulted from those interviews, contains descriptions of FCC Common

Carrier Bureau (CCB) organization including roles played by the different

groups and some specific activities of the Domestic Branch of the Facilities

and Services Division; the Tariff Review and Tariff Proceedings Branch;

Complaints and Service Standards Branch; and the Hearings Division. The

working paper is written in terms of PMS regulatory situations; however,

these same operations and procedures apply to all types of services regulated.

The CCB administration and support groups (e.g., Policy and Rules, Economics

Division, etc.) were described as

playing a less direct role in producing most line regulation

outcomes. They provide analytic, strategic and staff support.

A very important filing will prompt greater administrative

interest, and analytic and tactical support. In such cases, it

is not uncommon for staff from many CCB branches and divisions

to be assigned partial responsibility for processing the filing.

The managers of the FCC-CCB branches and divisions are the staff's communications links with the administration and support groups. The Chief of the

CCB is their link with the commissioners and policymakers.

The following displays depict information gained from these earlier

interviews in terms of activities and participants:

• Figure D-l: FCC Operational Activity

• Figure D-2: Main Activity Interfaces of Entities Identified

1. Bell, James. The FCC/ETIP Regulatory Experiment , (Draft) The Urban

Institute, Working Paper Number 1198-70-01, May 3, 1978, p. 19.
D-2

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D-3
D-4

As you will note from Figure D-2, the early discussions concentrated almost

entirely on FCC operations ; Agency interactions with carriers (as relates

to the carriers getting into business, doing business with emphasis on performance, and getting out of business); and the traditional legal process

which has been the linchpin of the regulatory operations.

B. EVALUATOR OBSERVATION OF CCB OPERATIONS

Figure D-2, the interface activities, shows that the two main areas of

interaction among entities is in the Tariff Review and Facilities sections.

These two divisions were selected for further investigation.

1. FACILITIES

A sampling of 183 specialized carrier applications required under Section

214 was taken. Requirements for Section 214 authority are described in Part 63

of the Code of Federal Regulations (47 CFR). These regulations are concerned

with extensions and supplements of facilities (actual transmission systems,

plants, equipment, etc.), and discontinuances, impairments and reductions in

service (either voluntary or involuntary). The findings of the sampling mentioned above are shown in Table D-l.

An additional 51 applications were studied in greater detail. Of these,

40 applications were specifically in compliance with Section 63.03 of Part

63, which concerns supplementing existing facilities and which is considered a

minor action. The types of companies filing were Bell, independent telephone

companies, or joint filings by Bell and independent telephone companies.

The average FCC processing time was 17.5 calendar days. Filings were based

on geographic networks; in other words, although permission for one huge

expansion may be sought by a company, separate filings must be processed
D-5

TABLE D -1 : SAMPLING OF 214 APPLICATIONS BY SPECIALIZED

COMMON CARRIERS CONDUCTED MAY 1978 BY UI STAFF

Name of Applicant Number of

Applications

% of Total

(N-183)

Locations Number of Cities

Cited

MCI Telecommunications Corp.

Western Union

Telegraph Co.

Data Transmission

Corporation

Southern Pacific

Communications

Corp.

Telenet

Communications

Graphnet Inc.

USTS

Microwave Comm.

Inc.

71

21

11

44

17

7

4o;;o%

11,5

6.0

5.0

24.0

.5

9.0

4.0

OH,NY,IL,

0K,NJ,MI,

CT,CA, CO,

M0,DE,GA,

AZ,IN,MD

IN, OH, AK, DC

GA,TX,NY,CA

LA,IL,0R,WA

141

66

0H,IL,GA,M0

DE, PA, MA, MI

Not Shown

MD,DE,0H,CA,

CT, MA, NY, PA,

GA,

Not Shown

MA,NY,NJ,CA,IL, Not Shown

VA,DC,TX,ME,VT,

MN,0H,M0,MA,C0

I Canada, Mexico Various U.S.

and locations in cities

U.S.

NJ,MD,VA,PA,GA, 82

NC,DC,NY

IL,M0

TOTAL lo J 100.0% ~

Source: UI Staff Sampling of Facilities Filings, Summer 1978

Not Shown
D-6

for each point-to-point geographic area. A simple count of filings might be

misleading as far as actual number of projects—depending on how "project"

is defined.

Another type of information which can be gleaned from these filings is

which carriers are leasing, renting or purchasing facilities from other carriers rather than constructing their own. All requests (new constructions,

purchases, etc.) gave probable costs; for example, maximum yearly rental

which would be paid. Two requests were for special temporary authority;

for example, satellite transmission of Madison Square Garden events to cable

television. These requests took 20 and 21 days to process—slightly longer

than the average. Of these 40 filings, all had been approved.

The remaining 11 filings concerned 63.01 of Part 63 which concerns

the following types of changes: installation/extension of cable and carrier

systems or rerouting of interstate channels. This is considered a major

action—perhaps because environmental impact is a factor in approving these

requests. Each file contained a "Telephone Wire Application" form and copies

of the requests were sent to the Secretary of Defense and Governor of the

state affected by the proposed change. The average processing time was

42.5 days —twice as long as for the other type of application.

The Western Union Telegraph Company applications were not studied in

detail. However, a review of Part 63 indicates that in addition to requests

for facilities extensions and supplements, Western Union must also submit an

application to Facilities if it wishes to close or reduce hours at any its

agencies or offices. Most of these sections of Part 63 will probably be

deleted and/or simplified in some way by the deregulation. The changed procedures for this type of Facilities application could be used as a measurement

of change in the amount of paperwork for both Western Union and the FCC.
D-7

In summary, direct observation gave the following information:

1. The basic responsibilities of Facilities was as described in the

early phase;

2. Operational aspects of Facilities were not verified or observed;

3. Types of information which could be developed from the files were:

carrier's name; type of carrier; amount of activity; type of activity,

being undertaken; type of transmission facilities; name of underlying

carrier, if any; service locations by state; FCC processing time; and

number of filings approved/disapproved;

4. Several new entities were added to the environment: the Defense

Department, State Governments, and environmentalists.

2. TARIFF REVIEW

In April/May 1978, several interviews were conducted with Tariff Review

staff. The basic operation of the Tariff Division was described in the early

phase; however, these later interviews filled in a great deal of detail.

a. THE RULES REGARDING TARIFF

Part 61 of 47 CFR are the rules governing tariff. Many of the specific

rules have to do with definitions and format. Section 61.38 concerns economic

support data. Section 61.58 concerns notice requirements. Table D-2 shows

the relationship of notice and petition periods.

b. TARIFF REVIEW OPERATIONS

In September 1976, to offset the time lag that developed as a filing

was routed from the Secretary's Office (or the Mailroom) to the Tariff Review

Section, the carriers were requested to provide courtesy copies to the Tariff

Review Section at the same time they sent the original filing to the Secretary's

office. Another reason for this request was that today, especially with the
D-8

TABLE D-2: NOTICE/PETITION PERIOD GUIDELINES AS

SPECIFIED IN SEC. 61.38 OF 47 CFR

NOTICE PERIOD* PETITION PERIOD TYPE APPLICATION

(Unofficial Designation)

15 days

70 days

90 days

petitions must be received

within 7 days

petitions must be received

within 15 days

petitions must be received

within 25 days

minor; unimportant

as far as rates

medium; e.g., new

equipment

major; e.g., rate

change activity;

controversial

* Tariff automatically becomes effective on the scheduled effective date if no action taken by the Commission to either suspend or reject the tariff

filing. If a party does file a petition or objection, or if FCC staff has

questions, FCC can order extension to 90 days. FCC not really locked into

these time periods since Congress passed law, that it could use its own discretion regarding 90-day notice period.

Source: 47 CFR, Section 61.58; interview with CCB staff, August 1978.

emergence of the specialized carriers (which will be discussed later in this

paper) and existence of greater competition in the marketplace, the FCC-CCB

Tariff Review Section receives many requests for information about who has

submitted filings, what the filings apply for, etc., from the public.

A daily log of tariff courtesy copies received is kept. This log records

which carriers filed and also a brief summary about each application. The

courtesy copies, however, are not mandatory. Another official count is

compiled in tabular form showing only the total number of tariffs received

monthly. An analysis was done of all courtesy copy logs as of April 1978

almost 2,000. This was compared with the total official court. This showed
D-9

that approximately 82 percent of carriers submit courtesy copies of filings.

One FCC staff person suggested that the other 18 percent were probably minor

filings by radio common carriers; but a later study of all official tariffs

did not seem to bear this out. If the courtesy logs were used as a proxy

of tariff activity, a greater effort would be needed to examine which types

of carriers are not submitting courtesy copies. Or, the Agency could simply

make courtesy copies mandatory. They are considering this anyway for the

sake of efficiency.

Two checklist forms are used by the tariff review staff: one is for

the tariff itself and the other is for the cost support material. (See

Exhibits D-l and D-2 below.)

The tariff checklist assists the reviewer in examining the tariff for

format; the cost support checklist also assists in a review of format.

Exhibit D-3 is a Commission description regarding background information

about Section 61.38 on cost support requirements.

Each reviewer has the option to make recommendations about whether or not

to consult the supervisor on a possible problem filing; e.g., a filing which

may prompt a petition. The last section on the tariff review checklist asks

about supervisory action. If there is a complaint or possible problem area,

it may take one or two weeks for the tariff to be finally checked out by

"higher-ups" in the Tariff Branch. As far as cost support sections of filings,

analysis of cost support data are not written unless a problem exists. And

even if a petition is received, usually the cost support analysis is verbally

described to the attorney.

c INFORMATION ABOUT REVIEWER'S TIME

Staff effort expended in the tariff review process is difficult to measure

in "time." A staff member interviewed said that, even for an established
D-10 CARRIER:

TRANS. DATE: /$/3C/'7'&

TARIFF: tr

P

NO: cT5

CONTACT:^^^^

r.

2a.

Purpose: 10Mjl£U2jul/cJ'&D &V J&M/U&A/. OU^^O' &U<.

Mew ./nzttCicfcti focd Jfc-c/. zdkccttc/i/sfc^xf /&'cs.

Associated Special Permission No: — 2b. Conformance: ."" (61.151-61.153)

3. Items Reviewed:

a. Correct filing fee submitted? - H'Mfy*k PdCjCA

b. Issue and Effective Date (61. 54, 61.58, 61.59)

Authority for less than statutory notice shown? (61.60-61.64,

61.66, 61.67)

c. Notice to customers required?

Provision made?

d. Transmittal Letter (61.33)

e. Cost support data required?

Received?

f. Check Sheet (61.113)

g. No. of copies (61.34)

h. Copy supplied to duplicating contractor?

i. Tariff format (61.37, 61.52-61.55, 61.112-61.115)

j. Use of symbols (61.55, 61.71, 61.118)

k. Supplements (61.56, 61.116, 61.191 thru 61.193)

1. Adoption Notice and Supplements (61.171 thru 61.174)

m. Other (list)

lr. Is the tariff reasonable, non-discriminatory?

5. Is the tariff clear, legible, understandable?

5. Is the tariff consistent with other service offerings - of this carrier?

of other carriers?

7. Are there any known possible complications?

(If explanation required for 4, 5, 6 or 7, use reverse side)

3. Should an inter-office memo be prepared for information purposes?

9. Should a public notice be issued'

10. Recommendations of reviewer: CLCCJLfM.

*j3on SBpr

fffff^A?

^4

m<h

j^L

YL

j/C_

s

•:

.k^_

/

if

/hr

Ml

J)2£l

Supervisory action: Reviewer

:

Dste: • 1 ? . /->. Ifel 7*7

EXHIBIT D-l: SAMPLE OF TARIFF CHECKLIST FORMAT
D-ll

CARRIER:

TRANSMITTAL NO. 7346

TARIFF NO: 240/258

TWX/Telex DATE RECEIVED: 12-2-77

TARIFF: NEW RECEIVED X

DATE TARIFF BECOME EFFECTIVE: March 1, 1978

Explanation and Data Supporting Changes

and/or New Tariff Offering

| |Para. 61. 38 | Cost Data|

Item | Reference |Reference|

|1. An explanation of the changed or new matter |p. 1-2

|2. The reason for the filing I (a) (i) |p. 2-8 |

|3. The basis of ratemaking employed |p. 8-17

|4. A cost of service study for all elements of cost

for the most recent 12-month period (changed

matter only) I (a) (2) (i) |p. 49-68 | |5. A study containing a projection of cost for a 3-year period beginning at the date of the filing

|

of the tariff matter (changed and new matter)

|6. 3-year estimates of the effect of the new or

changed matter upon:

| a) traffic and revenues from the service to |

| which changed matter applies |p. 18-39

b) traffic and revenue from other services | (a) (2) (ii)

| classification of the carrier I |Att. D

c) upon the overall traffic and revenue of the

| carrier I |Att. D | |7« Complete explanation of the basis for the

estimates |0K

|8. Four sets of working papers which support the

information in items 4 through 6 (b)(i) |0K

|9. Statistical Studies I

I (if provided) (b)(2) |0K

|10. Form and content of material submitted with

rate increase (d) |0K

Recommendation of Reviewer: Accept [Reviewer:

|Date:

EXHIBIT D-2: SAMPLE OF COST SUPPORT MATERIAL CHECKLIST
D-12

61.38 of the Commission's Rules

Backeround:

61.38 was adopted by the Commission effective October

20, 1970 under Docket No. 18703.

The need for an amendment to Part 61 in terms of requiring

more comprehensive material to be filed with tariffs had been recognized

for some time. The above proceeding was instituted by the Commission

on- its own motion by a Notice of Proposed Rule Making released on

October 17, 1969. The main purposes of this notice were:

l) to give greater notice to the public of tariff changes

and 2) increase the efficiency of the Commission and its staff through the

submission of more detailed data by the carriers whenever tariff change;?

were submitted to the Commission for filing. Many of the carriers had been

providing only the minimum amount of information necessary to comply with

the existing requirements of Section 61.33 and the staff was unable to

make an resolution of the tariff filings without requiring extension

additional information and data to support the filing.

It is the intent of the 61.38 rule reduce_the._cumber_of

_

tariff filings ordered for hearing. with better information available to

the staff it is believed that many hearings might be avoided and the public

interest better served. Even in cases when a hearing were ordered the

availability of this information would shorten the time necessary for

determining the lawfulness of a filing.

EXHIBIT D-3: EXPLANATION OF 61.38
D-13

carrier, to check the format of a new tariff may take half an hour or 45

minutes depending on the length of the tariff, in order to make sure they

have all the pieces, proper notations, symbology, etc. Western Union's format

is standardized and might take only five minutes to check. However, total

review time of Western Union tariffs may run into hours because of the monopoly

situation at present. A revised tariff on the other hand might take only

5 minutes. Parts which must be clear and which are checked carefully are:

what service the carrier is offering and what are the obligations and liability

of both carrier and customer. Time required for a reviewer to analyze cost

data also varied. A detailed analysis of AT&T can take half a day—or a year.

Others can be done in half an hour. Mathematics is usually not checked.

Another part of a reviewer's time is devoted to contact with the carriers

themselves. Exact amount of time varies. With smaller carriers there may be

a great deal of contact because the format of the tariff is checked before

actual filing so that the filing does not have to be rejected and resubmitted

because of a simple error. One tariff reviewer said that sometimes an entire

day is spent assisting carriers and answering questions. A reviewer also

engages in meetings with other FCC staff to discuss problem or disputed cases.

As the above description indicates, no records are kept of how reviewers'

time is spent. Unless some mechanism for measurement of this is built into

the evaluation design, the evaluators will be unable to determine changes in

this area except through staff interviews. There is also no formal system

for tracking the tariffs and cost support sections through the review process.

d. INFORMATION ABOUT THE CARRIERS FOUND IN TARIFF REVIEW

Following are several tables and plots which show the types of information which can be gathered from an analysis of tariffs.
D-14

CARRIER TYPE PERCENTAGE OF TOTAL

(N=1876)

Specialized Common Carriers

International Record Carriers

Domestic Satellite Carriers

Western Union

AT&T

Other (includes, multipoint

distribution, radio common

carriers, maritime, microwave, RCA Alascom, Comsat,

and independent telephone

companies)

9%

30

7 10

26

18

100%

Source: FCC:CBB Tariff Review Courtesy Logs: September 1976 through

April 1978 (based on approximately 82% of total filings) r— i TABLE D-3: DISTRIBUTION OF TARIFF ACTIVITY BY TYPE OF CARRIER

DATE TARIFF TYPE

Private Line PMTS Telex/TWX Satellite Other

iSept. 76 1 1 3 2

i Oct. 2 1 2 1 3

Nov. 1

1 2 2 1

Dec. 1

2 2 1

Jan. 77 1

1 1 1

Feb. 1 3 1

Mar. 1 1 1 1 5

April 2 2 2 2 2

May 5 1 4 2 2

June 4 1 1 1 2

July 2 2 2 1 4

Aug. 2 6 1 4 3

Sept, 3 1 1 1 1

Oct. 2 1 1 2

Nov. 2 1 2 4 3

Dec. 3 5 2 1

Jan. 78 3 2 3 1 4

Feb. 2 2 3 1 2

3

3 Mar. 1 2 2

Apr. 3 1 2

Source; Tariff: Courtesy Logs (Approximat ely 82% of Total Tarii: f Filings

TABLE D-4: WESTERN UNION TARIFF ACTIVITY FROM SEPTEMBER 1976 THROUGH

APRIL 1978
D-15

#-

1*6-

looH

hJH

ftO

S 6$

^-

2*--

-I \- H 1 \—t ! > 1 !

' 1- i o 5 C /^)D r A\ <A

FIGURE D-3: TOTAL NUMBER OF FILINGS MONTHLY
D-16

% 1976

100

% of ToLal

9%

30%

18°/

7%

10%

26%

D

B

Carrier Types

Specialized

Common

Carriers

International

Record

Carriers

Other : Multipoint

Distribution Cos. Comsat RCA Alascc

Ind . Phone

RCC Maritime

Microwave

Domestic

Satellite

Companies

Western Union : Private Line

PMTS Telex/TWX

Satellite

Other

AT&T: Long Lines

Bell Cos. AT&T Co.

*Based on approx. 82% of official

filings

to

mos

FIGURE D-4: PERCENTAGE OF TOTAL FILINGS FOR EACH CARRIER TYPE

(BASED ON APPROXIMATELY 82% OF OFFICIAL FILINGS)
D-17

5*1

00

cr. 8

"5/2*

t/i

V -i V) -I O C

v5 c

fcr-s

tobOO

a,o

>,

CO

a) u

!-i OUO

CO

WH

P-. W

COwMIw

Ph

>hH

PQ

COO

55M

hJHI QOH
D-18

So—

<b

J

it

14- 5

Source: Courtesy

Copy Logs

Ar-tT

' v)e.5-rETP-N> un>\ok>

/»--

-

1 »

1

1 H I H > H i ' I I ]

< i * hi I i 1<R71 1 17 SI> M I « I I M U I H I **»\ y-w^^aJfltoMD prvft

FIGURE D-5 CONTINUED

5PT6UUI t6

Pm.s

FIGURE D-6: WESTERN UNION TARIFF FILINGS BY TYPE
D-19

e. ANALYSIS OF OFFICIAL TARIFFS

Next, a review was made of all tariffs on file and all cost support

material for the specialized common carriers. Figure D-7 shows the number and

types of common carriers regulated by the Agency. The established carriers,

such as Western Union, usually have a separate tariff for each type of service

category. The tariffs are numbered sequentially for each carrier. So, in

locating a tariff, one must know the carrier, the tariff number, and title

of the tariff. We have compiled indexes of the tariffs by carrier type.

We divided the specific information that we wanted into two categories:

service and financial. Carriers selected for further investigation were:

Western Union and the specialized common carriers (SCCs). The reason for

this was that initially the Tariff staff had made the statement that the

specialized carriers were the most likely entrants into the PMS markets.

And, the review of all tariffs supported their theory. The specialized carriers were the only types—besides Western Union and AT&T—which offered a

range of services which could be generally described as intercity communications channels of various bandwidths, types and data speeds designed to provide transmission of voice, data, and/or facsimile and other special/type,

dedicated services.

Types of information found in the tariffs include: carriers' names;

other carriers participating in the tariff; types of services—classes and

subclasses of service when appropriate; rates; and points of service. The

detail and comprehensibility of this information varies from tariff to tariff.

In short, service and operation and rate information can be found in the

tariffs, but it is difficult to work with. As long as a carrier conforms to

certain basic requirements in format, it can use its own methods and terminology in writing the tariff. They don't all provide the same services

and the range of services is almost unlimited since the specialized carriers
D-20

Monopoly/Established Carriers: 3

(AT&T, Western Union and Comsat)

Competitive Carriers:

Domestic Satellite 9

Multiple Distribution Service 12

Microwave 70

Mobile Radio Common Carriers 383*

Maritime or Coastal Harbor Services 90

Telephone Companies:

Miscellaneous 4

(All American Cable & Radio; Cuban

American Telephone & Telegraph; ITT

Virgin Island; United States Liberia)

CATV Independents 12

Wide Spectrum 34

Independent Telephone Companies 58

Bell Associated Companies 25

CATV Bell Associated 3

Hawaiian: 2

(Western Union of Hawaii and Hawaiian

Telephone)

Alaskan

:

1

(RCA Alascom)

International Record Carriers: 5

Specialized Microwave Carriers: 7 (MCI, ITT-CCS, Transportation Microwave,

U.S. Transmission Systems, Goeken, Southern Pacific, and Western Telecommunications)

Specialized Domestic Satellite: 4

(RCA Americom, Southern Satellite Systems,

Satellite Business Systems, and American

Satellite)

Other Specialized Carriers: 3

(Graphnet, Telenet, and Tymnet)

TOTAL 725

*N0TE: Although there are 383 tariffs on file, most of these radio carriers

are NOT interstate and according to current law do not have to have a tariff on file. I assume that only approximately 20 or 30 of these tariffs

are required and have had actual tariff activity during the last couple

of years. So, this would drastically change the count to something like:

725 - (353) = 372 Common Carriers who are required to file Tariffs with the FCC.

Source: Review of ALL CCB Tariff Filings as of August 1978 Conducted by UI Staff,

FIGURE D-7: COUNT OF COMMON CARRIERS—AS OF AUGUST 1978
D-21

offer custom private line services which include services from unique customeroriented combinations of voice/data/facsimile transmission to special construction of transmission systems to providing telephone equipment.

Tariff sections describing "same" services, however, are somewhat more

standardized. For example, Figure D-8 shows tables comparing MCI Communications Corporation rates for its Faxnet Service and Southern Pacific Communications Corporation FAX Data rates. Both are facsimile services. Now, other

common carriers offer it on a subscriber basis to their customers. This

information on rates, however, was not in tabular form in the tariffs. The

terminal types were in one section; the class/delivery types in another

section; and the actual rates in another. In other words, the tariffs are

not easily worked with. And, for now at least, there is no guarantee that all

information sought will be found in them in every case. Before describing

other sources of information that we investigated after reviewing the tariffs,

we will mention findings regarding a review of the tariff of Graphnet Systems,

Inc., a specialized common carrier.

Graphnet only offers one service—facsimile. Graphnet's network configuration, service classifications, refund and liability policy, billing methods

and rates were covered in an Urban Institute draft memorandum which detailed

the information found in Graphnet's tariff.

With FCC permission, Graphnet's Washington representative was contacted

and copies of the memorandum were submitted to him for verification. Subsequently, a meeting was held attended by Urban Institute, ETIP and Graphnet staff

On the whole, the tariff information was accurate, but it did not seem to give

a complete picture of Graphnet. For example, missing information included

financial information, customer types, the fact that Graphnet manufactures

specialized hardware devices and advertises itself as a universal service
D-22

FAXNKT—MCI RATES (entry or exit)

Class

:

Delivery:

Terminal*

A

B

CD

1 15 min.

$.40

.40

.30

.20

Daytime

Charge Per Page

2

2 hours

$.32

• 32 .24

.16

1 Overnight 15 min.

Nightime

Charge Per Page

$.24

.24

.18 .12

$.28

.28

.21 .14

2 2 hours

$.22

• 22 .17

.11

Overnight

$.17

• 17 .13

.07

Monthly acces charge $10 Rental for Fax Terminal: $42/month

*Authorized Fax Terminal Types:

A carrier-provided analog fax terminal 1 page/ 4 minutes

B customer-provided analog fax terminal 1 page/4 minutes

C customer-provided analog fax terminal 1 page/3 minutes

D customer-provided analog fax terminal 1 page/2 minutes

FAXNET FORWARDING SERVICE

Class 4: U.S. Mail (regular or special delivery); postage/$1.00/$. 10 per page

surcharge where permissible

Class 5: Pickup by subscriber, addressee or agen4; $1.00/$. 10 per page surcharge

where permissible

FAXNET FORWARDING FACILITIES LOCATED IN:

Los Angeles, Chicago, New York, Cleveland, Philadelphia, Dallas and Houston

SPCC FAX DATA RATES (entry or exit)

Daytime Nightime

Charge Per Page Charge Per Page

Class

:

1 2 3 1 2 3 Delivery

:

15 min. 2 hours Overnight 15 min 2 hours Overnight

Terminal : **

I $.50 $.40 $.30 $.32 $.24 $.20

II .50 .40 .30 -32 .24 .20 III .375 • 30 .225 .24 .18 .15 IV .25 .20 .15 .16 .12 .10 V .125 .10 .075 .08 .06 .05 VI*** .125 .10 .075 .08 .06 .05

Monthly charges: Analog $49/Digital $600

**Authorized Fax Terminal Types:

I carrier-provided analog 1 page/4 minutes

II customer-provided analog 1 page/4 minutes

III customer-provided analog 1 page/3 minutes

IV customer-provided analog 1 page/ 2 minutes

V customer-provided digital 1 page/1 minute

VI carrier-provided digital 1 page/1 minute

***First 6000 pages per terminal FAX DATA FORWARDING SERVICE:

Class D: United States Post Office (regular or special delivery);

postage/$1.00/$- 10 per page surcharge where permissible

Class E: pickup by customer, address, or agent; $1.00/$. 10 per page surcharge where permissible

Surcharge for delivery to incompatible terminal - $.50 per page

FAX DATA FORWARDING FACILITY. LOCATED IN: Chicago, Illinoi

FIGURE D-8: COMPARISON BETWEEN MCI FAXNET AND SOUTHERN

PACIFIC FAX DATA SERVICES
D-23

capable of interface with any equipment by means of equipment interface

packages it develops.

3. OTHER SOURCES BESIDES TARIFF AND FACILITIES

Within the FCC, the Economic Studies Branch of the Commission was contacted

to establish the types of information they might have available. The information on the established carriers such as Western Union is very complete; however, the SCC information is sketchy. "The Statistics of Common Carriers" is a

publication of the Economics Group. It has a great deal of valuable financial

information; however, the lastest published data is two years old. The UI has

recently obtained copies of the FCC's computer print-out sheets with compilations of unpublished 1977 financial information. Figure D-9 shows the types

of information shown in these reports. UI staff have begun compiling a notebook of information on each specialized common carrier.

C. INFORMATION SOURCES OUTSIDE OF CCB

It seemed obvious that a major source of information about the carriers

were the carriers themselves. In early September 1978, a mailing was sent

to approximately 10 of the remaining 14 specialized carriers besides Graphnet.

As of November 1978, approximately half had responded, expressed interest in

our study, and sent information including public relations material, network

descriptions, rate information, and press releases.

Another source of information about the specialized common carriers

was discovered by reading a newsletter known as Telecommunications Reports .

This publication reports on all events in the common carriers industry,

including contracts, mergers, investments, financial reports, court cases,

and Congressional/Federal/State and Agency activity as well as conventions,
D-24

PART 1. GENERAL TABLES — TELEPHONE AND TELEGRAPH

1. Selected Data of Telephone and Telegraphy Carriers Reporting to the Commission for the Year Ended December 31, 1977

2. Tax Accruals and Excise Taxes Collected From Users of Comrnf cation Service as Reported by Telephone and Telegraph Carriers

PART 2. TELEPHONE CARRIERS

3. List of Telephone Carriers Reporting to the Commission for the Year Ended December 31, 1977, whose reports were used in the Statistical Tabulations

4. Averages and Ratios Computed from Selected Data Submitted by Telephone Carriers

5. Number of Telephones in the United States as of the Close of the Year, 1882-1977

6. Telephone Development by States •

7. Telephone Development in Large Exchange Areas in the United States

8. Selected Data Shown by States or other Areas, of Telephone Carriers Reporting Annually to the Commission

9. Selected Data Showing Development Through the Years 1944-1977, Inclusive, of Telephone Carriers Filing Annual Reports with the Commission

10. Employees of Telephone Carriers Reporting Annually to the Commission Classified by Occupational Groups, and Their Average Basic Hourly

Rates of Pay as of December 31, 1977 Local Service Revenues, Toll Service Revenues and Total Operating Revenues from January 1968 to December 1977, Inclusive, of Telephone Carriers Reporting Monthly

12. Communication Plant of Telephone Carriers Reporting Annually To The Commission

13. Overseas and Marine Communications Services Furnished by Telephone Carriers Reporting Annually to the Commission

14. Revenues from Overseas Communications Services Reported by Telephone Carriers for the Year6 1951 to 1977, Inclusive

15. Analysis of Overseas Telephone Traffic by Country or Point — AT&T

16. Statistics of Telephone Carriers Reporting Annually to the Commission, as of December 31, 1977, and for the Year Then Ended

17. Statistics of Selected Large Telephone Carriers Not Subject to the Reporting Requirements of the Commission, as of December 31, 1977, and fot the Year Then Ended

18. Capitalization Ratios for Reporting Telephone Carriers

19. Interest Coverage Ratios for Reporting Telephone Carriers

20. Rate of Return on Utility Rate Base for Reporting Telephone Carriers

PART 3. DOMESTIC AND OVERSEAS TELEGRAPH CARRIERS

21. List of Domestic and Overseas Telegraph Carriers Reporting to the Commission for the Year Ended December 31, 1977, Whose Reports Were Used in the Statistical Tabulations

22. Averages and Ratios Computed from Selected Data Submitted by Domestic and Overseas Telegraph Carriers

23. Selected Data Showing Development Through the Years 1942-1977, Inclusive, of Principal Domestic and Overseas Telegraph Carriers Filing Annual Reports with the Commission

24. Message Revenues of Domestic and Overseas Telegraph Carriers Shown According to Class of Message

25. Revenues from Overseas Communications Services Reported by Telegraph Carriers for the Years 1958 to 1977, Inclusive

26. Analysis of Overseas Message Telegraph Traffic by Country or Point

27. Analysis of Overseas Telex Traffic by Country or Point

28. Employees of Western Union Telegraph Company Classified by Occupational Groups, and Their Average Basic Hourly Rates of Pay as of October 31, 1977

29. Employees of Principal Overseas Telegraph Carriers Classified by Occupational Groups, and Their Average Basic Hourly Rates of Pay

as of October 31, 1977

30. Monthly Revenues from January 1963 to December 1977, Inclusive, of Overseas Telegraph Carriers

31. Indexes of Various Classes of Domestic Record Communications

32. Communication Plant of Uestern Union Telegraph Company

33. Communication Plant of Overseas Telegraph Carriers

34. Statistics of Domestic and Overseas Telegraph Carriers Reporting Annually to the Commission, as of December 31, 1977, and for the Year Then Ended

35. Rates for Interstate Long Distance Telecommunications Service — United States Mainland

36. Rates for Long Distance Message Telecommunications Service — United States Mainland - Alaska

37. Rates for Long Distance Message Telecommunications Service — United States Mainland - Hawaii

38. Rates for Long Distance Message Telecommunications Service — United States Mainland - Canada

39. Rates for Long Distance Message Telecommunications Service — United States Mainland - Mexico

40. Rates for Long Distance Message Telecommunications Service — United States - Overseas

41. Rates for Public Message Telegram Service for United States Mainland and United States Mainland - Alaska, Canada, Saint Pierre - Miquelon Islands, and Mexico

42. Usage Rates for Intra - United States Telex Service

43. Usage Pates for United States - Alaska Telex service

44. Usage Rates for United STates - Mexico Telex Service

45. Rates for International Overseas Telex Service from the United States

46. Rates for Overseas Message Telegraph Service from the United States

47. Rates for Intra - United States Teletypewriter Exchange Service

48. Rates for Money Order Service for Intra - United States, United States - Alaska and United States - Hawaii

19. Rates for Intra - United States, United States - Alaska and United States - Hawaii Mailgram Service Filed by Telephone,

by Tie Line or Over the Counter

PART 5. COMMUNICATIONS SATELLITE CORPORATION

50. Balance Sheets of Communications Satellite Corporation on December 31, 1977 and 1976

51. Income Statements of Communications Satellite Corporation for the Years Ended December 31, 1977 and 1976

52. Selected Facility and Usage Data of Communications Satellite Corporation

PART 6. HOLDING COMPANIES AND INTERCORPORATE RELATIONS

53. Intercorporate Relations of CommurJcptions Carriers and Controlling Companies, December 31, 1977

54. Changes Affecting Coverage of Table 53

Source: FCC Statistics of Common Carriers: computer print out sheets of unpublished data for 1977 obtained by UT Staff 9/78.

FIGURE D-9: CONTENTS OF STATISTICS OF COMMON CARRIERS
D-25

educational courses, research reports, and new publications. One new publication mentioned in the Reports specifically concerned the specialized common

carriers and is published by a group known as the Ad Hoc Committee on Competitive Telecommunications. A telephone call to that group confirmed that

they were lobbyists representing the specialized carriers and the newsletter

was specifically geared to equipment manufacturers to give them economic

information about the specialized common carriers.

Another source of information is the Securities Exchange Commission.

A few of the carriers, like Telenet, have prospectuses on file which are

very complete and contain information in a very readable and usable form.

Information that is sometimes found in a prospectus includes history of

services, competitors, equipment manufacturers and computer companies dealt

with by the company, and future plans. Many of the specialized carriers

are subsidiaries of other companies and, sometimes the controlling company

will have information on file. The carrier in this case, however, is only

described as a part of the whole.

D. SUMMARY

In summary, direct observation gave the following information:

1. The responsibilities of Tariff were described in the early phase.

2. The basic operation of Tariff was as described in the early phase.

3. Hard measurement data on changes in FCC staff time and time to

process tariffs might be difficult to obtain. Information

requirements about new companies entering the PMS market (and

any control group used) could be met —most easily by establishing

contact with the carriers themselves.

4. The types of carriers in the environment, by type and name, have

been identified. New entries in the environment include:

employees (unions), equipment manufacturers, computer companies,

lobbyists, investors, and the Securities Exchange Commission (SEC)

APPENDIX E: POTENTIAL USES OF INFORMATION AND POTENTIAL MEASURABLE ISSUES

Developed by

Steven Watson

James Bell

Sharon Kirby

Paul Nalley

Roland Weiss

E-l

Page

CONTENTS E-l

HOW TO USE THE TABLES E-l

1. Sponsors' s Issues E-2

2. Participants' Issues E-8

3. Gateway Inquiry Issues E-ll

4. Telex/TWX Rate Case Issues E-12

5. WATS/MTS Inquiry Issues E-13

6. Computer Inquiry E-14

7. Graphnet and Telenet - Domestic Carriers Applying for

Authorization to Enter International Market E-16

8. Testimony of Witnesses at HR 13015 Hearings, August 1978 E-18

HOW TO USE THE TABLES

Specific questions that concern sponsors, participants and onlookers have

been identified, and are listed on the following tables. The far right column

contains our best current understanding of potential use of measurement data.

Moving across the table, the middle columns include notations about where to

pursue measurement data. Potential measurable issues related to possible uses

of data are on the left. The far right columns identify the source documents

used to gather this information. See Chapter VT of the report for an example

of how these tables illustrate the way information gained from the evaluation

might be used. These tables and the numerous possibilities for measurement

they represent also point out the need for decisions about what to measure.

There are more possible measurements than can be tracked within the resources

of the evaluation. It should be noted, however, that these decisions are also

dependent on actual effects of the deregulation.

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F-2

I. PARTICIPANTS IN OTHER

SPECIAL FCC INQUIRIES

a. Computer Inquiry

Docket 16979 and

Docket 20828

o FCC STAFF 1 . James Smith

Policy and Rules

INVOLVEMENT IN

PMTS DEREGULATION

Possible issue links

between other FCC

special inquiries

and the Western Union

Monopoly Inquiry

INDIVIDUALS EXPRESSING CONCERNS TO FCC RE COMPUTER INQUIRY

2. Jim Buckley and Associates

3. Ad Hoc Telecommunications Committee

Jeremiah Courtney, Esq.

4. Aeronautical Radio, Inc.

Charles R. Cutler, Esq.

Kirkland, Ellis and Rowe

5. American Bankers Association

Gerald M. Lowrie

6. American Newspaper Publishers Association; Associated Press; Commodity

News Services, Inc.

Aloysius B. McCabe, Esq.

Kirkland, Ellis and Rowe

7. American Satellite Corporation

Michael D. Campbell, Esq.

8. American Telephone & Telegraph Co.

Alfred A- Green, Esq.

9. Applied Data Research, Inc.

Carol A. Cohen, Esq.

10. Remote Processing Services Section

(RPSS) Of the Association of Data

Processing Service Organizations;

Indepenent Data Communications

Manufacturers Association, Inc.

Herbert E. Marks, Esq.

Wilkinson, Cragun & Barker

11. Boeing Computer Services, Inc.

Ben Harty, Esq., Vice President

12. Citicorp; Bunker Ramo Corporation

Tedson J. Meyers, Esq.

13. Computer and Business Equipment

Manufacturers Association (CBEMA)

;

McDonnell Douglas Corporation

Joseph M. Kittner, Esq.

14. GTE Domestic Telephone Operating

Companies

Ruth L. Prokop, Esq.

15. Incoterm Corporation

Andrew M. Wolfe, Esq.

16. International Business Machines (I3M)

David R. Anderson, Esq.

17. ITT Domestic Transmission Systems, Inc

Agatha M. Modugno, Esq.

18. ITT World Communications, Inc.

Joseph J. Jacobs, Esq.

19. MCI Telecommunications Corporation;

Microwave Communications, Inc.; and

N-Triple-C, Inc.

Michael H. Bader, Esq.

20. National Burglar and Fire Alarm

Association

21. National Communications Services

Eugene Strange, President

22. National Data Corporation

William B. Moriarty, II
F-3

INDIVIDUALS EXPRESSING CONCERNS TO FCC RE COMPUTER INQUIRY

23. Bowne and Company, Inc.

Paul S. Hoffman, Vice President

24. NCR Corporation, Industry

Standards and Relations

Thomas W. Kerns, Systems Standards

25. Executive Office of the President

Office of Telecommunications Policy

General Counsel

26. Computer Law and Tax Report

Robert P. Bigelow, Editor

27. Communications Satellite Corp.

William K. Coulter, Esq.

28. COMSAT General Corporation

James T. Roche, Esq.

29. Computer and Communications

Industry Association

Terry G. Mahn, Esq.

30. Continental Telephone Corporation

Thomas L. Jones, Esq.

31. Control Data Corporation

Philip C Onstad, Management

Telecommunications Policies

32. Electronic Industries Association

John Sodolski, Staff Vice

President

33. French Telegraph Cable Company

Henry Goldberg, Esq.

34. General Electric Company

David Sherman, Esq.

35. General Services Administration

Spence W. Perry,. Esq.

36. GTE Data Services, Inc.; GTE

Automatic Electric Inc.

Allen R. Frischkom, Jr., Esq.

37. RCA American Communications, Inc.

David R. Ellis, .Esq.

38. RCA Global Communications, Inc.

Donald J. Elardo, Esq.

39. Rochester Telephone Corporation

David J. Cook, Esq.

40. Rutgers Journal of Computers

and the Law

John R. 3onica

41. Sander Associates, Inc.

F. Sherwood Lewis, Esq.

42. Satellite Business Systems

F. Thomas Tuttle, Esq.

Counsel, Regulatory Matters

43. Scientific Time Sharing Corp.

Philip S. Abrams, Vice President

44. Seattle First National Bank

David B Goldstein, Esq.

45. Securities Industry Automation

Corporation

46. Southern Pacific Communications

Company

John V. Kenney, Esq.

47. Sperry Rand Corporation, Sperry

Univac Division

Frank M. Lesher, Esq.

48. Stanford Research Institute

Lloyd I. Krause

49. Telenet Communications Corporation

Philip M. Walker, Esq.

50. Tele-Sciences Corporation

Fred W. Morris, President

51. Thrift Transfer Services, Inc.

Merrikay S. Hall, Esq.

52. TRT Telecommunications Corporation

Roderick A. Mette, Esq.
F-4

INDIVIDUALS EXPRESSING CONCERNS TO FCC RE COMPUTER INQUIRY

53. Tymnet, Inc.

William M. Combs, President

54. United Computer Systems, Inc.

John 0. Somers, Esq.

55. United States Independent

Telephone Association

Thomas J. O'Reilly, Esq.

56. United Systems Service, Inc., on behalf of the member companies

of the United Telephone System

57. Utilities Telecommunications

Council

Charles M. Meehan, Esq.

58. David McCable

618 A Street, S.E., Apt. 4

Washington, D.C 20003

59. Western Union International, Inc.

Stephen C Weingarten, Esq.

60. Western Union Telegraph Company

Joel Yohalem, Esq.

61. The Annenberg School of Communications

University of Southern California

James H. Carlisle

62. U.S. Department of Justice

Kenneth Robinson, Esq.

63- Xerox Corporation

John L. Wheeler

64. Raymond Panko

808 Coleman Avenue, Apt. 12

Menlo Park, California 94025

b. Gateway Investigation

Docket 19660

o FCC STAFF 65. Helene Bauman

(Facilities)

66. Kent Nakamura

(Tariff)

67. John Copes

( International

Division)

INDIVIDUALS EXPRESSING CONCERNS TO FCC RE GATEWAY INQUIRY

68. ITT World Communications, Inc. 72. Western Union International, Inc.

69. RCA Global Communications, Inc. 73. Western Union Telegraph Company

70. TRT Telecommunications, Inc. 74. American Satellite Corporation

71. COMSAT 75. Mobile Marine Radio, Inc.

c MTS/WATS Inquiry

Docket 21402 (78-72)

o FCC STAFF 76. Dan Harrold

(Tariff)
t-5

INDIVIDUALS EXPRESSING CONCERNS TO

77. ABC Broadcasting

78. CBS Broadcasting

79. NBC Broadcasting

80. American Petroleum Institute

81. American Trucking Association, Inc.

82. Telenet Communications Corp.

83. Ad Hoc Telecommunications Users

Committee

84. Southern Pacific Communications Co.

85. Western Union Telegraph Co.

86. National Data Corporation

87. Committee of Corporate

Telephone Users

88. American Bankers Association

89. Aeronautical Radio Inc. and

Air Transport Association of

America

90. National Retail Merchants Assoc.

91. Aerospace Industries Association

of American

92. MCI Telecommunications Corporation

93. American Telephone & Telegram Co.

94. Administrator of General Services on behalf of Executive Agencies of

the United States

95. 3M Corporation

96. American Motel and Hotel Association

97. Republic Distributors Inc.

98. Computerized Automotive Reporting

Services Inc., Realtron Corporation,

Roberts Advertising

99.

100.

101.

102.

103.

104.

105.

106.

107.

108.

109.

110.

111.

112.

113.

114.

115.

116.

117.

118.

119.

120.

121.

122.

FCC RE MTS/WATS INQUIRY

Tele-communications Association

Pitney Bowes

Record Shack of Cleveland, Inc.

Campaign Communications Institute

of America, Inc.

Congress of the United States, on behalf of House of Representatives

Army Times Publishing Company

Tri-Clover Division, Ladish Company

The Loading Service Company, Inc.

Poly-Tech

EMC Corporation

Peterbilc-Timpte of Wisconson, Inc.

Minneapolis Auto Equipment, Inc.

Ultimate Numbering Machine Service, Inc.

Our Own Hardware Company, Minnesota

Ramada Inn

Data 100 Corporation

Midwest/Northern, Inc., Minnesota

"The Fun Food People"

Budget Motels and Hotels of America

Echo Communications, Inc.

Inventory Data Systems

Littrell Parts

Mountain Co., Inc.

Mt. Rushmore Concession

Hanco, Bloomington, Minnesota

Associated School Supply Corporation

Los Angeles, California
F-6

INDIVIDUALS EXPRESSING CONCERNS TO FCC RE MTS/WATS INQUIRY

123. Century Communications Corp.

124. Jockey International

125. Steven Fabrics

126. Business and Institutional

Furniture Company

127. Board of Commissioners

Josephine County, Oregon

128. Chicago Cutlery Company

129. Imported Auto Parts

130. Palm Beach Beauty Products

131. National Communications Service

Vienna, Virginia

132. M. Lowenstein & Sons, Inc.

Rock Hill, South Carolina

133. Timoa Inns, Inc.

Peoria, Illinois

134. Ohio Rural Electric Cooperatives

Columbus, Ohio

135. Meredith Corporation

Des Moines, Iowa

136. Seattle First National Bank

137. International Communication

Management, Inc.

138. Supra Products, Inc.

Salem, Oregon

139. Ellerbe

Bloomington, Minnesota

140. American Family Insurance Group

Madison, Wisconsin

141. Marquette Electronics, Inc.

Milwaukee, Wisconsin

142. Lyon Brokerage Company, Inc.

Minneapolis , Minnesota

143. Wiedemann Industries, Inc.

Muscatine, Iowa

144. Oregon Shakespearean Festival

Association

145. Broan Manufacturing Co., Inc.

Hartford, Wisconsin

146. Parker Automotive

Minneapolis, Minnesota

147. Ashland Oil, Inc.

Telecommunications & Radio/

Electronics Division

Ashland, Kentucky

148. Interstate Manufacturing and

Supply Company

Minneapolis, Minnesota

149. Quint Cities Ford Truck Sales

Davenport, Iowa

150. Gary Van Zeeland Talent Inc.

151. Federal Financial Corporation

152. Grain Terminal Association

153. Harry and David Fine Food and

Gifts, Oregon

154. Holms ten Ice Rinks, Inc.

155. Federal Financial Corporation

156. Elixir Industries

157. Amert Construction

158. The Travelers Insurance Companies

159. Mast Keystone

160. Bradley Automotive

161. The Service Auto Glass Company

162. Taylor Music

163. Omega Securities, Inc., Oregon
F-7

d. TELEX/TWX Rate Inquiry

Docket 78-97

o FCC STAFF

INVOLVEMENT IN

PMTS DEREGULATION

164. Ken Levy

Tariff Proceedings

INDIVIDUALS /ORGANIZATIONS EXPRESSING CONCERN IN

TELEX/TTJX INQUIRY

169. ITT World Communi cat ions Inc.

170. RCA Global Communications, Inc.

171. FTC Communications, Inc.

165. American Telephone & Telegraph

166. Western Union International Inc.

167. American Facsimile Systems

168. TRT Telecommunications Corp.

e. Issue re domestic carriers

(Graphnet and Telenet) competing in international marketplace

INDIVIDUALS /ORGANIZATIONS EXPRESSING CONCERN IN DOMESTIC/INTERNATIONAL

MARKETPLACE COMPETITION

172. RCA Global Communications, Inc.

173. TRT Telecommunications Corp.

174. Graphnet Corporation

II. THE CONGRESS OF THE

UNITED STATES

Subcommittee on Communications of the Committee on Interstate and Foreign

Commerce

o FCC Staff

General Rule Rewrite

175. Telenet Corporation

176. Western Union International

177

178.

179.

180.

181.

182.

183.

184.

185.

186.

187.

188.

189.

190,

191.

192.

Lionel Van Deerlin,

Calif., Chairman

Members

John M. Murphy, N.Y.

Charles Carney, Ohio

Timothy Wirth, Colo.

Marty Russo, 111.

Edward Markey, Mass.

Thomas Luken, Ohio

Albert Gore, Jr., Tenn.

Barbara Mikulski, Mo.

Henry A. Waxman, Calif.

Louis Frey, Jr., Fla.

W. Henson Moore, La.

Carlos Moorhead, Calif.

Marc L. Marks, Pa.

Samuel Devine, Ohio

Harley Staggers, W. Va.

INVOLVEMENT IN

PMTS DEREGULATION

Rewrite of the Communications Act, HR 13015

Titles I, III on Common Carrier Regulation

193. Ruth Reel

(Division)
F-8

INDIVIDUALS /ORGANIZATIONS WHICH HAVE TESTIFIED BEFORE SUBCOMMITTEE

RE REWRITE OF TITLE I, III OF THE COMMUNICATIONS ACT

~

194. State of Alaska

Robert M. Walp, Governor's

Office of Telecommunications

195. GTE Automatic Electric, Inc.

Theodore Brophy, Chairman

196. State of New York

Charles Zielinski, Chairman

Public Service Commission

197. Central Telephone & Utilities

Corporation

Robert P. Reuss, Chairman

198. American Telephone & Telegraph

Richard R. Hough, Executive

Vice President

William M. Ellinghaus

Vice Chairman

199. Communications Workers of

America

Glenn E. Watts, President

200. International Business Machines

Wallace Doud, Vice President

201. Continental Telephone Corporation

Charles Wohls tetter, Chairman

206. MCI Communications Corporation

William G. McGowan, Chairman

207. National Telephone Cooperative

Association

David C. Fullarton, Executive

Vice President

208. Telecommunications Policy Task

Force

209. Graphnet Systems, Inc.

Edward Taptich, Esquire

210. North American Telephone Association

James Lovell, President, Fisk

Telephone Systems, Inc.

211. Computer and Business Equipment

Manufacturers Association (CBEMA)

Vico E. Henriques, President

212. Association of Data Processing Service Organizations, Inc. (ADAPSO)

Fred 3. Lafer, Vice President,

Automatic Data Processing, Inc.

213. American Electronics Association

Kenneth Oshman, President,

Rolm Corporation

202. United Telecommunications, Inc.

Paul H. Henson, Chairman

214. American Satellite Corporation

Michael D- Campbell, Vice President

202. Satellite Business Systems

Philip N. Whittaker, President

203. Telenet Communications Corporation

Philip M. Walker, Vice President

204. U.S. Independent Telephone

Association

J. Philip Bigley, President

205. Organization for the Protection and

Advancement of Small Telephone

Companies (0PASTC0)

Glen Bergland, Member, Board of

Directors

215. Independent Data Communications

Manufacturers Association, Inc.

(IDCMA)

Arthur Carr, Member, Board of

Directors

216. Scott Buttner Communications, Inc.

Joel Effron, President

217. Teleprompter Corporation

Cable Television Division
F-9

INDIVIDUALS /ORGANIZATIONS WHICH HAVE TESTIFIED BEFORE SUBCOMMITTEE

RE REWRITE OF TITLE I, III OF THE COMMUNICATIONS ACT

218. University of Chicago

Department of Economics

Professor Dennis Carlton

219. Computer & Communications Industry

Association (CCIA)

Philip S. Nyborg, V.P.

220. International Telephone and

Telegraph Corporation (ITT)

Frank P. Barnes, Senior V.P.

221. General Telephone and Electronics

Corporation

Dr. Lee L. Davenport

V.P. and Chief Scientist

222. New Jersey Bell Telephone Co.

Morris Tanenbaum, President

223. Bell Telephone Laboratory

Ian Ross, Executive V.P.

224. Illinois Bell Telephone Company

Charles Marshall, President

232. National Burglar and Fire Alarm

Association

Joseph F. Duncan,. President

233. Central Station Electrical Protection Association

Richard Clark, President

234. Ad Hoc Committee on Competitive

Telecommunications

Herbert N. Jasper

235. National Data Corporation

L. C Whitney, President

236. National Federation of Local

Cable Programmers

David Hoke, Advocacy Committee

Chairperson

FEDERAL GOVERNMENT STAFF TESTIFYING:

237. DEPARTMENT OF STATE

Lee R. Marks, Deputy Legal

Adviser

225. National Cable Television Assoc.

Robert L. Schmidt, President

226. Tele-Communications Association

Daniel L. Grove, President

238. U.S. DEPARTMENT OF JUSTICE

John H. Shenefield, Assistant

Attorney General, Antitrust Div.

FCC STAFF TESTIFYING:

227. International Communications Assoc.

Westinghouse Electric Corporation

Robert E. Bennis, Chairman

228. New York State Commission on Cable Television

Thomas E. Ryan, Exec Director

229. Community Antenna Television Assoc

Stephen R. Effros, Exec Dir.

239. The Honorable Charles D. Ferris

240. Commissioner Lee

241. Commissioner Quello

242. Commissioner Washburn

243. Commissioner Fogarty

244. Commissioner White

245. Commissioner Brown

EXECUTIVE 3RANCH STAFF TESTIFYING:

230. Securities Industry Automation

Corporation (SIAC)

Vincent Moore, Jr., Sr. V.P.

231. United Telephone Company

Paul Brewer

246. National Telecommunications and

Information Administration

The Honorable Henry Geller

Assistant Secretary for

Communications

APPENDIX G: FCC NEWS RELEASE ANNOUNCING END OF WESTERN UNION MONOPOLY

AND CONDITIONAL APPROVAL OF GRAPHNET'S APPLICATION FOR

DOMESTIC SERVICE (CC Docket Nos. 78-95-96)

G-l

1919 N StrestNW.

WashlBgtM, D.C. 20554

>r recorded listing of releases and texts call 632-0002 For general information

call 632-7260

Report No. 14735 ACTION IN DOCKET CASE January 25, 1979 - CC

FCC ENDS WESTERN UNION TELEGRAM MONOPOLY;

CONDITIONALLY APPROVES GRAPHNET' S APPLICATION FOR DOMESTIC SERVICE

(CC DOCKET NOS. 78-95-96)

The Commission has determined that the public interest would

be served by adoption of a policy of multiple entry into the domestic

public message telegraph service field, historically the monopoly domain

of the Western Union Telegraph Company.

The result of this decision is that the Western Union Telegraph Company (WU) will no longer have an FCC-granted monopoly in the

provision of domestic telegraph service and that other carriers may

apply to offer services similar to WU's. (In 1943 the Commission made

a public interest finding and approved a merger between WU and the

Postal Telegraph Company, which in effect gave WU a monopoly in the

domestic public message service field.)

The Commission also granted the application of Graphnet

Systems, Inc. to interconnect with International Record Carriers (IRCs)

and deliver inbound international messages from the IRCs to locations

within the United States on condition that Graphnet accepts the

responsibility for delivery of the messages and that the IRCs do not

bear the costs of the hinterland haul. A division of revenues arrangement

and other like bona fide compensation for the hinterland haul are permissible.

(There are five authorized gateways within the United

States — Miami, New York, New Orleans, San Francisco

and Washington, D. C. — where an IRC may pick up or deliver international telegraph messages. The hinterland

is any domestic location other than the five authorized

gateways.

)

(over)
G-2

On March 9, 1978, the Commission began its inquiry to determine

whether WU should retain its monopoly on telegraph services.

The action was the result of Graphnet's application to

interconnect with any IRC and to deliver international public message

domestically.

In setting the investigation, the Commission said Graphnet's

application raised a number of policy issues in view of the fact that

the FCC had never endorsed an open entry policy for domestic public

message telegraph services. The issues included in the investigation

were: — Should domestic public telegraph service be provided

on a sole source basis, free from competition? — Assuming the market were to be opened to competition,

should different regulatory standards and procedures

be established than those that were designed to regulate

WU's monopoly?

Would the potential economic impact of competition

on WU be contrary to the public interest?

At that time, the Commission held that until the inquiry was completed, it could not make the necessary findings to grant Graphnet's

application. In its decision today, the Commission said it must first

address the threshold question of whether Congress has given the FCC

discretion to permit an end to WU's monopoly in the delivery of public

message telegrams. It noted that Section 222 of the Communications Act

is permissive and not mandatory, and the FCC was not required to approve

the WU-Postal merger but was given discretionary authority to exempt it

from the operation of the antitrust laws as follows:

It shall be lawful, upon application to and approval

by the Commission as hereinafter provided,- for any

two or more domestic telegraph carriers to effect a consolidation or merger.

Thus, it said, Section 222 's focus was the antitrust laws

and not limitation of entry in the future by others. Moreover, the

Commission said the legislative history clearly manifested Congress's

understanding that it was bestowing authority to take the WU-Postal

merger out of the operation of the antitrust laws, and no more.
G-3

It said Section 222 left telegraph carriers the option of

merging or not merging; and its decision over the WU-Postal merger

lest the same option for other carriers. Thus, the FCC found that

neither Section 222 nor its decision approving the merger represented

a policy determination that future entry or participation in domestic

telegraphy would be foreclosed.

The Commission said telegram service has declined in importance

both as a source of revenue to WU and a means of public communications.

It said telegram service has evolved away from the traditional messengerdelivered yellow telegram, toward a system highly reliant on the telephone

and other services outside the corporate control of WU.

WU's reliance on telephone acceptance is increasing, the FCC

said, pointing out that the percentage of messages originated by

telephone in 1971 was 44 percent. It said that currently some 64 percent

of telegrams and cablegrams are originated at WU's three Centralized

Telephone Bureaus. 14 percent at WU's public offices and agencies and

22 percent via WU's Telex and TWX terminals located on the customer's

premises.

Telegraph revenues also are a decreasing portion of WU's

total revenues, it said, noting that telegram revenues have fall

from about 80 percent of WU's total revenues in 1947 to less than 10

percent in 1976. This has occurred, the FCC said, despite the growth

of total operating revenues for WU from $199.7 million to $527.5 million

during the same period.

It said the changes in the character of telegram usage and

declining volume were intertwined with the increasing price of telegrams

and the development of substitutes. It said some usage has shifted to

telephone and the relative prices of the two services changed over time

telephone becoming cheaper while telegrams become more expensive. Also,

other record services have grown, taking portions of traffic which are

not best handled on the telephone, the Commission said.

The Commission noted that there are many services to which

public message telegraph traffic has been diverted, i.e., Telex, Mailgram,

telephone company services such as private line telegraph and WATS,

dataphone terminals, facsimile machines, nontariffed information

processing and forwarding services, etc.

(over)
G-4

The FCC emphasized that nearly every new record service that

has been developed since the merger has been oriented toward high-volume

business users, adding that WU's monopoly has been a barrier to making

these services available to the general public.

It noted that WU's argument for retention and expansion of

its monopoly is premised on the belief that public message telegraph

service cannot be profitable. However, the Commission said that

technological innovation can make a previously unprofitable enterprise

profitable by lowering the costs of the enterprise, or alternatively

by increasing efficiency.

The Commission said in light of its previous decisions

allowing competition in private line and domestic satellite services

and allowing the resale of other services by a common carrier to a second entity for eventual service to the public, efficient low-cost

substitute services have become available.

Taking all of this into consideration, the question was

whether there was a vital public need for WU's telegraph service today

that cannot be met by alternative sources of supply.

Because of the limited effect on WU's revenues and service,

the fact that low-cost alternatives to WU's service can be developed,

the fact that WU's service is in many ways limited, and because of the

FCC's belief that there is an untapped demand for low-cost public record

services, the Commission concluded that a public record or message

service could be viable under conditions of competitive supply.

In spite of Its confidence that the public would be served

by allowing multiple entry in the public message telegraph market,

the Commission said it would carefully and continuously monitor changes

in the service and would focus on the entire record service field to

determine changes (if any) in overall service available to the public.

It said its primary concern would be the level of aggregate

service that is available to the public, adding that the effect on service rendered by any particular company was of concern only insofar

as it has an impact on the overall level of service that is available to

the public from all sources.
G-5

The Commission noted that it would soon be proposing new

rules to govern the public message service, including removing some

of the restrictions on WU to make it easier for the company to adapt

to competition.

The conditioned grant to Graphnet represents the first

application of the Commission's policy of multiple entry in the PMS

market. The public interest finding by the FCC concerning Western

Union's monopoly removed a substantial legal barrier to Graphnet 's

entry — the 1943 Merger Decision.

Equally important to Graphnet 's application was the question

whether the Commission's "Free Direct Access" policies governed

Graphnet' s proposed service. "Free Direct Access" refers to situations

where the International Record Carriers (IRCs) absorb the cost of

hinterland delivery from their authorized gateway cities. The Commission

has banned such activity because it constituted an expansion of

gateways without proper authorization. The Commission is reexamining

its "Free Direct Access" policy in another proceeding, Docket 19660).

The Commission found that the "Free Direct Access" policies are not

applicable to hinterland delivery of telegraph messages by domestic

PMTS carriers so long as these carriers accept responsibility for the

telegraph messages involved and it is clear that the IRC is not bearing

the cost of hinterland delivery. Now that multiple entry's authorized

in domestic FMTS, Graphnet can operate in the same manner as Western

Union. Since WU's delivery to the hinterland of IRC's messages is not

an extension of their gateways, neither is service by Graphnet if

similarly offered.

The Commission noted that it will review any tariffs filed by

Graphnet to assure that there is no violation of its Free Direct Access

policies.

Graphnet 's application is also conditioned on the outcome of

the Commission's inquiry concerning the monopoly provision of the

Message Telecommunications Service (MTS) and Wide Area Telecommunications

Service (WATS) by AT&T.

Action by the Commission January 25, 1979 by Memorandum Opinion

and Order (FCC 79-42). Commissioner Ferris (Chairman), Lee, Quello,

Washburn, Fogarty, White, and Brown, with Chairman Ferris issuing a separate statement.

This is an unofficial announcement of the Commission's

action. Release of the full text of the Commission's

order constitutes official action. See MCI v. FCC, 515

F. 2d 385 (D. C. Circ. 1975).

- FCC -
G-6

January 25, 1979

IN RE: Separate Statement of Chairman Charles D. Ferris

Public Message Telegraph Inquiry

(CC Docket Nos. 78-95 and 78-96)

I strongly endorse the Commission's decision today adopting a policy of open

entry into the public message service market. I expect this competitive policy

to lead to lower prices, innovative service offerings, and more rapid implementation of new technology in this area.

Public use of domestic telegrams has fallen dramatically since the end of

World War II. The number of messages and the number of Western Union offices

have exhibited parallel declines. The nature of the telegram has changed ds

well, with Western Union increasingly using the telephone network to accept

telegrams and using unaffiliated messenger services to physically deliver them.

During the past 30 years, a number of substitutes of varying degree for telegram

have also been developed and marketed. In fact, Western Union--with its Telex

and Mailgram offerings—appears to have been its own most formidable competitor

for telegram business.

We will soon initiate another proceedinq concerning proposed rule changes for

public message telegraph service carriers. My initial belief is that we

should minimize government regulation of this market. I also look forward to the

opportunity this proceeding will give us to examine to what degree--if at allregulation is necessary or appropriate in this kind of competitive market. In

addition, I currently believe that whatever the rules, they must apply equally

to Western Union and the new entrants to insure that the resulting competition

is fair. I will, of course, base my ultimate decision on the comments and

evidence filed in that proceeding.

Finally, I intend to insure that the Commission monitors the effects of this

policy change. This evaluation will be undertaken by staff of the Common Carrier

Bureau in cooperation with the Experimental Technology Incentives Program (ETIP)

of the National Bureau of Standards. This will enable the Commission to check

its expectation of public benefits, based on today's reasoned judgment, against

subsequent events in the marketplace.
NBS-114A (REV. 9-78)

U.S. DEPT. OF COMM. BIBLIOGRAPHIC DATA

SHEET

1. PUBLICATION OR REPORT NO. NBS TN 1104 Vol. 2

2. Gov't Accession No* 3. Recipient's Accession No.

4. TITLE AND SUBTITLE

The FCC Public Message Services Policy Change:

An ETIP Evaluability Assessment Report

5. Publication Date September 1979

5. Performing Organization Code

7. AUTHOR(S) James Bell, Sharon Kirby, The Urban Institute;

Roland G. Weiss, NBS; Steve Watson, The Urban Institute

8. Performing Organ. Report No.

9. PERFORMING ORGANIZATION NAME AND ADDRESS 1% Project/Task/Work Unit No.

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, DC 20234

The Urban Institute

2100 M St., NW

Washington, DC 20037

11. Contract/Grant No. 7-35822

12. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, state, zip)

Same as above

13. Type of Report & Period Covered Interim

14. Sponsoring Agency Code

15. SUPPLEMENTARY NOTES

| | Document describes a computer program; SF-185, FIPS Software Summary, is attached.

16. ABSTRACT (A 200-word or leas tactual summary of most significant infonrtation. If document includes a significant bibliography or

literature survey, mention it here.) This document is a report of work in progress toward evaluating effects of the

recent decision of the Federal Communications Commission to open public message

services to competition. It is one product of the Regulatory Processes and

Effects Project of the Center for Field Methods (ETIP). The broader project,

described elsewhere, is attempting to analyze the effects of changes in regulatory

processes on industrial innovation. The joint ETIP/FCC project will involve

measuring whether the FCC policy change leads to increases in competition,

technological innovation, and public benefit.

The first two chapters provide an introduction and synopsis. Chapter III examines

the setting in which the decision occurs in terms of historical developments,

industry trends, and views held by various observers. Chapter IV describes the:

Commission's mandate for regulation, process for implementing this mandate in

terms of regulations and operations, and current industry status. The fifth

chapter describes the evaluation logic. The last chapter is an assessment which

shows that there are many choices to be made to target the evaluation. A

glossary of terms and bibliography are included. Seven appendices are bound

separately

.

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only the first letter of the first key word unless a proper name;

separated by aemicoionsj Administrative experimentation; economic deregulation; evaluability

assessment; evaluation; Experimental Technology Incentives Program; Federal

Communications Commission; regulatory experimentation; regulatory policy;

technology innovation; telecommunications.

18. AVAILABILITY Unlimited

I | For Official Distribution. Do Not Release to NTIS

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