As a 66 year old member of AARP, I thought I'd look at their initial [comments] and reply comments. I am disappointed. My summary will be considered caustic and critical by many. That is intended. My perspective is warped as a father of five college graduates and trustee of an independent secondary school as well as by having previously served as a company president, bank director and hospital trustee. Here are very brief summaries of the AARP initial and reply comments. They joined with two other groups for comment.
This coalition of advocates declares a failure of Congressional intent "...if average Americans pay more for their telecommunications service, lose access to crucial services currently provided as part of basic service, or fail to receive access to new functionalities as they become available...". They desire definitions of affordability which don't create "serious inconvenience" but want individual state, not federal, determination of the affordability and comparability of rates. They want self-certification of 125% of poverty level income as eligibility requirement for basic service, long distance blocking, no-charge on phone company calls, lower installation costs and waiving of initial deposits. Those eligible should be allowed to buy higher grades of service and should not be vulnerable to disconnection for non-pay of long distance bills. Functionalities in the universal service should include "directory assistance, the provision of and listing in annual local directories, Call Trace, 900-number blocking service, equal access to interexchange carriers, interoffice digital facilities, equal access to SS7 functionalities, and interconnection among all carriers and modem facilities".
These advocates want expanded access to universal service as they declare "...AARP, CFA, AND CU are very concerned that the Notice does not address the important, underlying elements of this principle (universal service applies to all consumers) and, instead, limits its scope to only the beneficiaries of the targeted subsidies." They also want the Commission to address the cost allocation rules of Section 254(k).
Everything for everybody everywhere by Federal decree is my harsh summary of this plea. The bulk of the text is rhetoric (including absolute and relative definitions of affordability) in support of the plea. Throughout, there are presumptions of the producing economy's ability and willingness to support the largess, the power of the government to direct the transfers of values without limit, and the self-discipline of consumers to make good use of the system. As a senior citizen, I am not proud of the AARP's posture.
In the reply comments the advocates:
- Challenge all cost data & economic impact estimates of the providers,
- Refuse to offer an economic model of their vision,
- Challenge the authority of the commission to act on rates,
- Promote disagreement between local exchange and long distance companies,
- Encourage introduction of new providers,
- Deny anyone's ability to predict new rates,
- Urge retention of rates until some new competition stabilizes conditions, and
- Urge refusal of recovery of some prior investments.
In short, give their constituents all the benefits without risk and let someone else suffer any pain and uncertainty. It is a curious blend of expectation of effectiveness through competition, condemnation of previously regulated suppliers and reliance on future regulation for a result which they claim can be determined only by actual implementation, not prediction.
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