Since September of 1998, NNI has filed five comments with the FCC (as well as one complaint with the Criminal Justice Division of the IRS) and all pertaining to Baby Bells business practices. And ALL of the information for these filings have been taken directly from "The Unauthorized Biography of the Baby Bells & Info-Scandal". Read 'em and weep . . .

Let's go through our filings and what they mean to average phone customers.

1. CC Docket 98-146 NOI (text)

CC Docket 98-146 NOI (.pdf)(33K)

2. FCC 98-188 Order/NPRM

FCC 98-188 Order/NPRM (.pdf)(33K)

http://www.fcc.gov/ccb/706/

FCC LAUNCHES INQUIRY, PROPOSES ACTIONS TO PROMOTE THE DEPLOYMENT OF ADVANCED TELECOMMUNICATIONS SERVICES BY ALL PROVIDERS (CC Docket Nos. 98-146, 98-11, 98-26, 98-32, 98-15, 98-78, 98-91, 98-147)

Public Notice: Common Carrier Bureau Establishes Revised Pleading Cycle for Comments in Section 706 Notice of Inquiry, FCC 98-187, and Deployment of Advanced Telecommunications Notice of Proposed Rulemaking, FCC 98-188

The Commission today initiated two proceedings intended to create marketplace conditions conducive to the nationwide deployment of advanced telecommunications services, such as high-speed Internet access and video telephony, by all providers. First, the Commission commenced an inquiry into the current availability of advanced telecommunications services and what actions the Commission can take if it determines that these services are not being deployed to all Americans in a reasonable and timely manner.

Second, the Commission proposed actions to encourage all wireline providers, both incumbent local telephone companies and their competitors, to provide advanced telecommunications services.

NNI'S FINDINGS: The Bells promised to rewire half of America with the Fiber Optic, 500 channel, Ultra-high speed, Broadband, Info Highway services by the end of this year. However, the Bells received state and federal financial incentives to be used for new construction. We estimate that customers were overcharged $30 billion for services they never received.

Therefore, we requested the FCC to first investigate these claims and mandate refunds, before the Bells are granted any new incentives to deploy advanced networks.

IN THE BOOK: Info-Scandal is one of the primary themes of the book. Chapters 1, 2, 3, 4 and 5 details the Bells promises, Chapters 22 clearly outlines the incentives that were granted while Chapters 27, 28, and 29 explain our position on Bell overcharging, related to Info-Scandal. Chapters 46, 45, and 48 outline investigations the FCC should be undertaking.

Depreciation Issues ASD 98-91 (.pdf)

UNITED STATES TELEPHONE ASSOCIATION FILES PETITION FOR FORBEARANCE FROM DEPRECIATION REGULATION OF PRICE CAP LOCAL EXCHANGE CARRIERS, ASD 98-91, Reply Date: November 12, 1998

On September 21, 1998, the United States Telephone Association ("USTA") filed a petition requesting that the Federal Communications Commission forbear from regulating the depreciation and amortization practices of local exchange carriers subject to price caps regulation. USTA is filing this petition pursuant to Section 10(c) of the Communications Act of 1934, as amended, 47 U.S.C. Section 160(c). The Accounting Safeguards Division of the Federal Communications Commission will be considering this action.

(In English - the Primary Bell's lobbying group, the USTA, requests that the FCC no longer regulate or examine the Bell companies write-offs because they now use price-caps regulation.)

NNI Findings: The Bells also took an additional $21 billion dollars in massive write-offs of the old copper networks that were supposed to be replaced with Fiber optics. They were never replaced, so we believe these write-offs were improper. (This was also filed as a complaint with the Criminal Justice division of the IRS, may 1998.)

FROM THE BOOK: As we point out, USTA is a lobbying Group/association for the Bells. Chapter 18 discusses construction and depreciation issues, and highlights our complaint to the IRS. while Chapters 8, 9, 10, and 13 discusses the Bells lobbying and Campaign Financing issues and related business practices. Also, Chapters 19, 20, 21 and 22 supply discussions of the arcane issues and terms surrounding Bell company regulations.

PHONEBILL ISSUES CC Docket No. 98-170 (.pdf)

IN THE MATTER OF TRUTH-IN-BILLING AND BILLING FORMAT, CC Docket No. 98-170- NOTICE OF PROPOSED RULEMAKING, Adopted: September 17, 1998

http://www.fcc.gov/Bureaus/Common_Carrier/Notices/1998/fcc98232.txt
http://www.fcc.gov/Bureaus/Common_Carrier/News_Releases/1998/nrcc8063.txt

One of the primary goals of the Telecommunications Act of 1996 (1996 Act) is to make available to consumers new services and technologies by promoting the development of competition in all aspects of telecommunications services. In today's marketplace, increased competition has generated many new telephone-related services. While the nature of the charges appearing on consumers' telephone bills has changed dramatically due to the proliferation of services and service providers, the bills themselves do not seem to reflect this new era. Increasingly, consumers are concerned about telephone bills that do not provide sufficient information in a user-friendly format to enable them to understand the services being provided and the charges assessed therefore, and to identify the entities providing those services. In this Notice of Proposed Rulemaking (Notice), we seek comment on proposals to help provide consumers with the information they need to make informed choices in this competitive telecommunications marketplace.

NNI's Analysis of Phonebills: Approximately 0% of the population can answer basic questions about their telephone bill. From the number of charges to even the definitions used, the phonebill allows the Bells to make more money through customer confusion. We suggest a total simplification of the bill to stop slamming and cramming, two problems that are rampant through all of local service provision.

From The Book: In 1993 and 1995 NNI conducted Nationwide surveys of 1,000 consumers to see if they understood how to read their phonebill. Chapters 30 through 42 are dedicated to items on the bill., while Chapter 43 deals with customer confusion. Chapters 44-48 suggest remedies for these problems

ACCESS FEES FCC No. 98-222 Dkt No.: CC-98-166 (.pdf)

PRESCRIBING THE AUTHORIZED UNITARY RATE OF RETURN FOR INTERSTATE SERVICES OF LOCAL EXCHANGE CARRIERS. Initiated a proceeding to represcribe the authorized rate of return for interstate access services provided b ILECs. Action by the FCC. Adopted: September 8, 1998. by Notice & NPRM. (FCC No. 98-222). CCB

http://www.fcc.gov/Bureaus/Common_Carrier/News_Releases/1998/nrcc8068.html

FCC SEEKS COMMENT ON CHANGES TO LOCAL TELEPHONE COMPANIES' RATE OF RETURN TO REFLECT MARKETPLACE CONDITIONS. The Commission today asked for comment on changes to the rate of return, or profit, that local telephone companies receive for providing interstate access services, such as originating and terminating long distance calls, in light of other marketplace changes.
Report No: CC-98-33. by Notice & NPRM. Action by: the Commission. Adopted: September 8, 1998. Dkt No.: CC-98-166. (FCC No. 98-222)

NNI's FINDINGS: Almost 40% of all customer long distance charges goes back to the local phone companies, Known as access fees, we believe like others groups including MCI, Consumer Federation of America and Probe Research, that massive overcharging is occurring from access fees, and that we are calling on the FCC to use a "Total Bill Analysis", (described in the filing) to fix the problems.

IN THE BOOK: Chapter 6 gives the history of access charges and Chapter 15 highlights' access charge revenues. Meanwhile, Chapter 28 highlights MCI, Consumer Federation of America and Probe Research's prior finding on Access Fee overcharging. Chapter 45 and 46 explains how to fix the problem.

(a) IN GENERAL- The Commission and each State commission with regulatory jurisdiction over telecommunications services shall encourage the deployment on a reasonable and timely basis of advanced telecommunications capability to all Americans (including, in particular, elementary and secondary schools and classrooms) by utilizing, in a manner consistent with the public interest, convenience, and necessity, price cap regulation, regulatory forbearance, measures that promote competition in the local telecommunications market, or other regulating methods that remove barriers to infrastructure investment.

(b) INQUIRY- The Commission shall, within 30 months after the date of enactment of this Act, and regularly thereafter, initiate a notice of inquiry concerning the availability of advanced telecommunications capability to all Americans (including, in particular, elementary and secondary schools and classrooms) and shall complete the inquiry within 180 days after its initiation. In the inquiry, the Commission shall determine whether advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion. If the Commission's determination is negative, it shall take immediate action to accelerate deployment of such capability by removing barriers to infrastructure investment and by promoting competition in the telecommunications market.

(c) DEFINITIONS- For purposes of this subsection:

(1) ADVANCED TELECOMMUNICATIONS CAPABILITY- The term `advanced telecommunications capability' is defined, without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications using any technology.

(2) ELEMENTARY AND SECONDARY SCHOOLS- The term `elementary and secondary schools' means elementary and secondary schools,as defined in paragraphs (14) and (25), respectively, of section 14101 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 8801).