Date: 1985-04-03
Speaker: MARK FOWLER (democrat)
Chamber: S

Chairman. Federal Communications Comnission. Washington. DC. DEAR MR. CHAIRMAN: I am writing to ask the Commission to consider extending the comment period on the above captioned tariffs which would completely restructure AT&T Communications private line service. While I understand that a 3day extension has been made due to the impact of a threeday holiday weekend. I believe a further extension is needed. The tariffs and supporting materials are voluminous and complex analyses are necessary to determine their impact. Libraries do not have the data available to perform these analyses. which must be done on a network by network basis. and require AT&T assistance. AT&T has indicated the overall impact on libraries will be significant. but has not yet provided specific data. and will not be able to provide all this data until February 8th. With the currently scheduled deadline of February 7th. the Commission will not have the benefit of a full analysis by library customers. I am particularly concerned. as you know. about the impact of access and divestiture related tariffs upon the nations libraries. The private line tariff proposed by AT&T in October of 1983 would have had a devastating effect on the ability of libraries to connect to a system of nationwide bibliographic databases laboriously developed over the last fifteen years. The largest of these "bibliographic utilities" is OCLC (Online Computer Library Center) which uses a system of 260 dedicated. multipoint lines leased from AT&T to serve 5.600 terminals in libraries across the U.S. Each circuit in this system must be analyzed manually (since computer models for analyzing the new tariff structure are not available) in light of the tariff proposals and AT&Tprovided data in order to determine the impact on libraries in each regional or state library network. I wrote you in May of last year. along with 26 of my Senate colleagues. to urge the Commissions consideration of a library private line service. In your response. you .ssured me that the Commission was aware of the concerns of the nations libraries. that you shared my concern over the substantial rate level and rate structure changes proposed by AT&T. and that the Commission would address these concerns before the effective date of the tariff. That earlier tariff was subsequently found unlawful by the Commission. However. AT&T has given broad indications that this new tariff will cause Increases at least as high as the previous tariff had proposed for library users of AT&Ts private line services. Therefore. I urge you to extend the February 7 deadline so that affected entities with limited resources such as libraries can analyze the impact of the tariff and respond. Although the tariff would have a major impact on the publics access to information through libraries and would keep many small libraries from participating in coinputerized systems. the added revenues sought from libraries would mean little in the overall private line picture. In 1983 libraries accounted for $6.8 million or 0.3 percent of AT&T private line revenues. Thus movement on the library private line service proceeding proposed in my May 1984 letter to you is in order. In the interim. libraries should be provided the opportunity to comment fully on these tariffs. Once impact data are available within the library community. and have been communicated to the Commission. I urge you to give careful consideration to the impact of these private line tariffs on libraries. Since October 1983 libraries have been planning technological adjustments to minimize the impact of new tariffs. but such developments cannot be implemented quickly. Technological change in libraries. while significant. is gradual due to their limited capital. and inability to pass cost along to their users. Of course. libraries are unique among users of private line services in that the basic access to information they provide is done without remuneration from fixed annual budgets.