June 6, 1997
Office of the Secretary
Washington Utilities and Transportation Commission
Box 47250
Olympia, WA 98504-7250
To the Commission:
The Washington Association of Internet Service Providers (WAISP), is
opposing U.S. West's (USW) request to eliminate Local Area Data Service
(LADS), filed as UT-970822. WAISP represents dial-up and direct Internet
Service Providers all across Washington, serving nearly 50,000 Washington
Internet users.
WAISP is concerned with USW claims that LAD circuits are limited and
decreasing in demand. A survey of our membership indicates that a
significant number of our larger members are using or have LADS circuits on
order. In addition, later this year the next generation of xDSL devices
will be available, allowing for transmission distances of 24,000 to 30,000
feet rather than the current 18,000 feet, and the price of these devices is
expected to drop significantly. This means that ISPs can offer low cost
xDSL services over a dry copper wire pair. We believe that this is exactly
what USW is afraid of, and why they are seeking to eliminate this service.
USW claims that LAD circuits were not designed for xDSL service. This may
be true, as xDSL wasn't even known of when LADS circuits were first
implemented. However, LADS circuits can be used for xDSL -- and as the
equipment improves, we expect to have more and more LAD lines used for xDSL.
USW says that other services can be used to substitute for LAD, including
LSD and VG-36 analog private lines. However, unless USW can guarantee that
these lines are unloaded, and that they do not require equipment be
co-located in the central office, they proposed alternatives wont work for
xDSL and will be inappropriate substitutes.
In addition, USW has laid blame at the ISP doorstep regarding network
congestion. LAD lines actually reduce congestion because they bypass the
switching centers. All of the proposed substitute services do not, thus
adding traffic to the switched network. If ISPs are forced to switch from
LAD lines, will we also continue to be blamed for causing network
congestion?
Finally, USW is promoting a product that utilizes a similar circuit with
their own ISP business subsidiary. As more and more of our members began
using LADS lines, it appears that USW saw an opportunity to keep more of
this business in house. By eliminating LADS lines, and forcing ISPs to use
substandard lines that wont work for transmitting high-speed data, USW again
becomes a monopoly provider of xDSL services.
Such an arrangement is not good for Washington consumers. Just
as ISPs discovered a means to offer low-cost, high-speed connectivity to
schools, service agencies, businesses, and individuals, USW wants to revoke
the tariff that allows such services -- in effect, killing off this
technology in its infancy.
The WAISP asks that the WUTC not grant USWs request to eliminate LADS
service, and further that the WUTC order that LADS lines be used in any
manner that does not interfere with other circuits in the same trunk group.
At the least, we would ask the WUTC to delay acting on USWs request for 90
days to allow those entities effected by the elimination of LADS circuits
to gather data on the effectiveness of LADS vs other types of circuits for
offering xDSL service.
Thank you for your consideration.
Cordially,
Gary Robert Gardner
Executive Director
Letter
supplied by Alden Reust
Alden Reust is the NorthWest Regional
Representative for Web Design and Developers Association
Charter Member of
the newly formed WAISP
and President of TSC NET
