* Original Area: BLINDTLK
* Original From: John Souvestre (1:282/1045)
* Original To  : All (1:282/1045)
Originally appearing in a local New Orleans conference.
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AOP Alert                         Thursday, February 13, 1997
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The following is a legislative alert from the Association of
Online Professionals, the world's largest association of 
Internet Service Providers and other professionals who manage 
online services.
Please give it the widest possible distribution.
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Comments to FCC on ISP Access Fees
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Over the past week, message traffic across the Internet has
incorrectly characterized the procedures, deadlines and general
tone of an FCC request for comments on access fee reform as it
might apply to Internet Service Providers.
This is an important issue for the online community, and AOP
encourages ISPs and other interested parties to file comments.
The following information is intended to assist you in doing so.
On December 23, the FCC initiated a proceeding to reform the
present system of interstate access charges levied on long-
distance carriers to make that system more competitive and to
address questions of whether these fees reflect the actual cost
to the local telephone companies.  This proceeding, in a Notice
of Proposed Rulemaking (NPRM) is identified as CC Docket No.
96-262.  Formal comments were invited, with a deadline of
January 27 and a deadline for reply comments of February 13.
This is **not** where ISPs should focus their responses, 
unless they have valid input to these specific telephone
company issues.  However, many of the comments filed on this
issue do touch on ISP access fees, and you are encouraged to
read the comments that have been posted online at http://www.
fcc.gov/Bureaus/Common_Carrier/Comments/access_reform/.
Also on December 23, the FCC released a Notice of Inquiry 
(NOI) identified ad CC Docket No. 96-263.  In the NPRM (see
above), the FCC tentatively concluded that information
service providers should not be subject to the interstate
access charges as currently charged.  However, the Commission
also noted that the development of the Internet may raise 
issues beyond the scope of the access fee reform proposed in
the NPRM.  The NOI is designed to help the FCC decide whether
access fees may be needed to create incentives for the 
deployment of more efficient data services.
AOP encourages all of its members to file appropriate
comments with the FCC on this issue.  In doing so, please
be aware of the following:
1)  You may file formal comments in writing, as AOP will do.
2)  You may file informal comments by electronic mail by
    sending them to isp@fcc.gov.  However, please note that
    "informal comments" does not mean "casual."  It means
    "less formal than written comments," but there are still
    requirements for the format (e.g., putting the docket
    number in the subject line, providing a mailing address,
    etc.).  Before filing comments, please review the
    information at http://www.fcc.gov/isp.html.
3)  Deadline for these comments is March 24, 1997.  Reply
    comments to these comments must be filed by April 23,
    1997.  Note that these are **new** filing deadlines, 
    amended by FCC to provide more time for responses.
Before filing comments, you are strongly urged to review:
**  The general information on filing comments with the
    FCC, found at http://www.fcc.gov/isp.html.
**  The text of the NOI itself, which may be found at
    the same web address.
**  Comments previously filed by other parties as part
    of their response to the NPRM.
This is an important topic before the FCC, and we
encourage you to make thoughtful, informed comments.
AOP will post its comments shortly for the review of
our members.
--- Maximus/2 2.02
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