Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) CC Docket No. 99-273 Telegate’s Proposal for Presubscription to ) CC Docket No. 98-67 “411” Directory Assistance Services ) COMMENTS OF LOW TECH DESIGNS ON TELEGATE’S PROPOSAL FOR PRESUBSCRIPTION TO “411” DIRECTORY ASSISTANCE SERVICES SUMMARY Low Tech Designs, Inc. (“LTD”) has filed extensive comments and reply comments in various Commission proceedings concerning similar implementations of Telegate’s currently proposed combined use of abbreviated dialing arrangements, or “ADA’s” and the Advanced Intelligent Network, or “AIN”. 1 As such, LTD supports Telegate’s proposal and is grateful to the Commission for it’s formal consideration. As shown herein, the Commission should adopt the proposal made by Telegate, with certain key modifications, in order to bring competition in the provisioning of AIN, directory assistance and ADA based services to telecommunications consumers. In these previous filings, LTD has urged the Commission to order the competitive use of abbreviated dialing arrangements, currently in the form of N11, *XX, *2XX and *3XX, as dialable telephone numbers without the requirement of presubscription. Because existing incumbent local exchange carriers (“ILEC’s”) offer *XX based services without requiring presubscription, in the form of pay-per-use *66 and *69 offerings, LTD has urged 1 See LTD’s Comments and Reply Comments filed in the Abbreviated Dialing Docket (92-105) and UNE Remand the Commission to allow similar competitive provisioning of *XX type services on a non-presubscribed basis using AIN-based officewide triggers. The current proposal could alleviate the need to provide access to other ADA’s while still providing service providers, such as LTD, with a meaningful opportunity to compete in the provisioning of ADA and AIN based services. LTD has argued that by allowing competitive local exchange carriers (“CLEC’s”) to be assigned *XX type telephone numbers, in combination with the power of the Advanced Intelligent Network, consumers could be offered innovative telecommunications services not envisioned by ILEC’s, or consumer friendly services not considered to be in their own self interest. If the Commission decides to designate “411” or other N11 codes as presubscribed special purpose telephone number associated with the power of the Advanced Intelligent Network, this telephone number could also provide the vehicle for the type of innovative telecommunications services LTD has envisioned, in addition to the introduction of greater competition in the provisioning of directory assistance services. Also, as show below, the “411” telephone number could also be used to provide voice access to the Internet. This promises to bridge the “digital divide” in our society, bringing the millions of computer “have nots” into the Internet economy. BACKGROUND The telephone number “411” has it’s roots in telephone “information”, a service that was originally provided by local telephone operators familiar with and located in the caller’s geographic area. “Directory assistance” became the name of the service after telephone companies discovered that Proceeding (96-98). Also see LTD’s ex parte filings in the Intelligent Network Docket (91-346). 2 the name “information” spurred requests for other types of “information”, requests that were not specifically related to telephone number provisioning. Current directory assistance providers are generally not located in the same geographic area of the caller and are not familiar with the local businesses and characteristics of the area. 2 LTD would like to utilize the power of the Advanced Intelligent Network to bring back the old “local information” aspect of directory assistance to telephone consumers. While Telegate has proposed the use of the AIN Release 0.1 “N11 Trigger” in order to implement their presubscription proposal, LTD strongly suggests that this would be a halfway and shortsighted measure. It cannot be denied that the latest AIN Release 0.2 “N11 Trigger” offers much greater flexibility in the range and consumer friendliness of the directory assistance and information services that could be offered by competitive providers using the “411” code. LTD’s PROPOSED SERVICES 1. Local and Long Distance Directory Assistance LTD would like to bring a real and local human voice, with local knowledge, back to directory assistance (“DA”), as described in the Wall Street Journal article in Attachment “A”. This can be most efficiently done by implementing the AIN Release 0.2 N11 Trigger and not the AIN Release 0.1 N11 Trigger, as proposed by Telegate. 2 See Attachment “A”, You Can Call Directory Assistance 'Information' in a Small Ohio Town, THE WALL STREET JOURNAL August 25, 1999., and Attachment “B”, Long Distance Blues: Operators Often Can't Find The Number ... Or The Listing That's Given Is Wrong, CBS Evening News, from http://cbsnews.cbs.com/now/story/0,1597,192005-412,00.shtml. The actual video news report is also available at this web address. 3 Release 0.2 of the N11 Trigger would allow for the implementation of AIN Intelligent Peripherals using the “send to resource, return to source” AIN functionality only available in this latest release 0.2 of the N11 Trigger. In this configuration, the Intelligent Peripheral (“IP”) resource would use directly interfaced, central office collocated voice recognition capabilities to differentiate between local and long distance DA calls. Local DA calls would be routed via the IP to live local DA operators, which could potentially be working out of home based business locations. After DA information was provided, the desired telephone number would, at the callers option, be provided by the IP to the AIN Service Control Point for completion using the “return to source” function. Long distance DA calls would be routed via the IP to remote DA operators serving the desired geographic area. This capability to route long distance DA calls to operators actually living in the targeted area will bring back the human element lacking in the current inferior centralized DA implementations described in the CBS Evening News program detailed in Attachment “B”. Once this long distance DA call was completed, the IP would once again become the interface to the caller, offering to automatically complete the call, if desired, using the caller’s normal long distance carrier. 2. “Digital Divide” Services Because of the flexibility provided by the AIN Release 0.2 N11 Trigger, additional services beyond directory assistance could also be provided by service providers using the “411” telephone number. 4 For example, “411” could be used to access a voice based Internet Service Provider (“Voice ISP”), providing the estimated 58 percent of people who own a telephone but don't own or have access to a computer with a uniform access number to dial on a nationwide basis. With the advent of the Voice Extensible Markup Language (“VXML”), bridging the “digital divide” for families without computers is now possible. See Attachment “C”. The use of an AIN Intelligent Peripheral, made possible by the use of the AIN Release 0.2 N11 Trigger, provides voice recognition services capable of providing access to the Internet using a simple voice telephone. RESPONSES TO SPECIFIC COMMISSION QUESTIONS LTD believes, just as Telegate has asserted, that “411” presubscription is technically feasible using AIN features already deployed by LECs. If AIN Release 0.2 N11 Triggers were required to be implemented, as has been proposed by LTD, additional modest upgrade costs might be incurred by LECs. Based on the potential to bridge the “digital divide” using “411” and VXML based Voice ISP services, this additional cost is fully justified on public interest grounds. LTD agrees that a new “411” Service Control Point (“SCP”) would be necessary to determine which “411” service provider had been selected by telephone consumers and to provide additional AIN query/response functions. This SCP would ideally be administered by a neutral third party. Because all existing and future service providers would query this database to determine subsequent call processing steps, all parties would be incented to keep these query charges as low as possible consistent with the required initial system establishment and maintenance costs. In this scenario, the new “411” service providers would contract with the neutral third party database administrator for SCP query execution at cost based rates. If these same providers wished to 5 provide the Intelligent Peripheral based services outlined above, these interconnected service elements would be provided by individual “411” suppliers on an as needed basis using standard industry interconnection protocols and interfaces to the LEC switches. Changes in subscriber presubscription choices could and should be done via a variety of mechanisms. Subscribers should have the choices of calling their serving LEC for changes, calling a toll-free number from the affected line using touch-tone input for selection of new providers, or by using a combination of web-based selection of service providers with email-based change confirmation. LTD believes that the costs of establishing a new “411” system proposed by Telegate should be shared by all existing, new and future participants in such a system. Consumers should not be forced to pay for the initial implementation of this new capability, although subsequent change charges would be acceptable. The system establishment costs should be spread over as wide a base of service providers as possible based on the number of subscribers acquired using the proposed presubscription balloting process. Each time a new customer is acquired by a service provider from a provider that has already paid for the incremental cost of providing service to an end user, the acquiring service provider would be responsible for compensating the prior service provider for the costs previously expended to serve that user. As the total telephone subscribers serviced by the new system increases, incremental costs will decrease and be reflected in these per user costs.