The Curious World Of Telecommunications Tariffs (Spring, 2009)

Hello, and welcome to the Central Office! I don’t have a cold but I’m sneezing, which signals spring—my least favorite time of the year here in the Great Northwest. It’s barely discernible from winter, except that everything starts blooming, the roots start attacking my sewer line, and a handkerchief becomes a nearly permanent fixture on my nose.

So, in keeping with my least favorite springtime things, I could write a long rant about the pack of thieving raccoons that lives behind the fence and knocks over my garbage cans. Or about the gopher who pushes up little dirt mountains all over my lawn. I could write a rant about the teenage heavy breathing I barely ever hear anymore during my “service monitoring” because the kids are skipping the talk and just sending compromising picture messages to just the two of them and the whole Internet. Instead, though, I’ll take you through the dank, dripping hallways of any regulated utility’s nemesis: the state public utility commission.

Washington Utilities and Transportation Commission logo

Nearly every aspect of telephone service was once regulated, ranging from directory assistance to the placement of telephone poles to the format of your bill. Actually, all of those things are still regulated, but many other services (such as long distance, Internet, and voicemail) are effectively not. In fact, cell phones, long distance, Internet service, VoIP and most other ways of communicating are all but unregulated. However, traditional telephone service remains a regulated utility, like electric or gas utilities. Services from your telephone company are largely regulated by tariffs, both at the federal and state level. Republicans generally oppose federal regulations, and as they have exerted political control over the past 8 years, there has been a deliberate and substantial dismantling of nearly a century’s worth of federal regulations on telephone service (apart from surveillance requirements, which have increased substantially). In effect, most federal agencies have only token, toothless enforcement mechanisms and commissioners are lap dogs of the industry.

Ostensibly the FCC regulates long distance telephone service, but tariffs are no longer reviewed or approved and are self-reported by the carriers on their own Web sites. There’s a really tough enforcement mechanism for any failures, though; long distance carriers are accountable to themselves to self-report any lapses. If your phone company has accepted certain government funds, it might also be regulated by the Department of Agriculture’s Rural Utilities Service (formerly known as the Rural Electrification Administration) which provides funding for network development in rural areas. As I’ve written previously, the FBI has been granted de-facto regulatory power over the telephone system’s surveillance capability, known as CALEA. The NSA has also (presumably) been granted secret powers to do secret things in secret facilities constructed at tandems across the US, but whether or not they have been granted this authority is in itself a secret.

Room 641A

Room 641A, widely believed to be a NSA facility at AT&T’s San Francisco tandem

Most states have not been as easily convinced as the federal government to give up regulatory authority within their jurisdictions, and unlike the federal government, they generally do not conduct their business in secret. Telephone service—at least the ever-dwindling parts of it under state jurisdiction—is strictly regulated by the PUC’s regulatory tariffs. Here in my Central Office, services are divided and catalogued as regulated and deregulated. Trouble tickets on deregulated services almost never result in overtime, and I can work them more or less at my leisure (strictly within union work rules of course). Telephone companies love deregulated services. They can charge whatever rates they like, change the rates as often as they like, offer whatever promotions and marketing bundles they like, and they’re not accountable to the PUC for delivering any particular level of service quality. After all, if you aren’t satisfied with the service, your only meaningful recourse is generally not to subscribe.

Regulated services are an entirely different matter. Everything from the number of blocked circuits to outside plant demarcation points to billing practices—and most importantly rates—are regulated by the state Public Utilities Commission. The telephone company publishes a service catalog for both regulated and unregulated services, and for regulated services, publishes tariffs. It is accountable for delivering services exactly as advertised in the service catalog, and precisely according to the rates and conditions outlined in the tariff. Deviations are not permitted in any way. Only the services described in the tariff can be offered, at the prices they are advertised, or heavy fines can result.

For the curious phreak, browsing tariffs can result in some fairly interesting discoveries. For example, despite party lines having been obsolete for decades, there still exist tariffs for them in many states that grandfather existing users. I recently disconnected the final remaining party line in my wire center, which belonged to a subscriber who was 92 years old and had maintained the same service since 1946. In effect, she didn’t really have a two-party line anymore; the other party on her line moved away in the early 1980s after party line service was discontinued for new subscribers. However, her rate was grandfathered in under the old tariff, which was last revised in 1971. Other tariffs provide geographical exceptions. When a new Central Office is constructed (an incredibly rare event these days, but not uncommon in the rapidly growing Western US as little as 25 years ago), the serving boundaries are strictly defined by tariff. Accordingly, people living in the area with existing telephone service have to be explicitly allowed to maintain service from their existing wire center. Qwest, in fact, has an entire section of their tariff library in each state dedicated to obsolete tariffs detailing the rates and terms of services that are no longer offered, but are still maintained for existing subscribers.

On a more practical level, browsing tariffs is a good way to learn exactly how much you can squeeze out of your phone company in promotions or retention offers. In general, all of these offers have to be filed with the Public Utility Commission. For example, in Washington, Qwest can offer you a promotional credit in a value equal to three months of the service to which you’re subscribed. They can only do this once every two years, either to win a new subscription or to stave off a cancellation. And that’s all they can offer, but they don’t have to offer you the maximum (and usually won’t as a starting point for negotiations).  Of course, if you read the tariff, you’d settle for nothing less than the maximum.

Finally, understanding which services are in the catalog, their brand name, and the applicable Universal Service Order Code (USOC) can help you save money (sometimes a lot of money) on features. For instance, there is more than one way to skin a cat, and there’s more than one way to have a phone number in a different wire center ring your line in my Central Office.  Most people needing this capability order a foreign exchange circuit, which bills a hefty setup fee and an even heftier monthly fee (including a mileage charge). The bill can easily run to over $100 per month or more. Alternatively, you could order a cheap, obscure and rarely used service called “Market Expansion Line” for business lines, or an even cheaper and more obscure service called “Number Forwarding” that is the exact same thing minus a Yellow Pages listing. These services set up a “ghost number” in the remote office, with permanent call forwarding to your regular number. The business office will sell these services to you, but only if you ask for them specifically; otherwise they’ll sell you a foreign exchange circuit. The only thing you give up is a dialtone from the distant Central Office, which can help you avoid intraLATA toll charges in limited circumstances. These days, long distance is—in almost any usage pattern—less expensive than a foreign exchange circuit. Nonetheless, even though foreign exchange circuits almost never make financial sense, busy Central Offices still do a brisk business in them. One local plumbing company has over a half-dozen foreign exchange circuits, all of which are—in my estimation—completely unnecessary. Unfortunately, I can’t advise them that they’re wasting money because the tariff strictly regulates subscriber privacy, and I’m not allowed to use subscriber information to suggest products or services without the subscriber’s explicit consent. And considering the subscriber has to contact me before I can request that consent, I’ll probably retire before I can save these folks a dime.

And with that, it’s time to bring this issue of the Telecom Informer to a close. Drive carefully while sneezing from all the pollen. And remember that if you wrap your car around a telephone pole despite it all, you can blame the Public Utilities Commission for its placement!

References 

http://tariffs.qwest.com:8000/Q_Tariffs/index.htm – Qwest tariff library

http://serviceguide.att.com/servicelibrary/consumer/ext/index.cfm – AT&T tariff library

http://www22.verizon.com/tariffs/ – Verizon tariff library

http://tariffs.net/hawaiiantel/ – Hawaiian Telecom tariff library

http://www.tariffnet.com/ – Pay site that tracks tariffs across substantially all telecommunications providers

http://www.puc.state.or.us/ – Oregon PUC

http://www.utc.wa.gov/ – Washington Utilities and Transportation Commission

 

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