Dear FCC
by Susanna Opper

[editor's note: Susanna Opper was among the many networkers who sent letters to the FCC last October to protest the proposed change in rate structers for packet networks. The outcome of the proposal is still in doubt. We asked Susanna for permission to reprint her letter as an excellent example of how networkers articulated the issue.]

October 16, 1987

The Honorable Dennis R. Patrick
Federal Communications Commission
1919 M Street,
N.W. Washington, DC 20554

Re: CC Docket 87-215
Amendments of Part 69 of the
Commission's Rules Relating to
Enhanced Service Providers

Dear Chairman Patrick:

I am writing to urge you NOT to adopt this rate increase. It's
apparent to me that you and your commission have no direct
experience of the valuable activities that will be
jeopardized--and may even be terminated--by your actions should
you adopt this ruling.

My expertise is introducing business people to online
communications. So I will attempt in this letter to give you
some sense of the online world-- where I have "lived" and made
my living for more than four years. I hope to create a picture
for you of a group of pioneers as American as the Colonists or
Homesteaders who settled this country's physical space. My
colleagues and I are opening up America's electronic space.

My plea will be impassioned because your actions potentially
can destroy my business, the activities of many of my clients
and fellow pioneers and ultimately, I believe, America's place
of leadership in the next era of mankind's history--the
Information Age.

Who am I?

My background is as a writer and corporate communicator. In
1981 I was working for Exxon when I discovered the existence of
electronic mail and -- more significantly -- computer
conferencing. Both at Exxon and in previous internal
communications positions with major companies, I had endeavored
to help people get the information they need to do their jobs
and that they want as members of the corporate community. The
first time I saw the technology of electronic communications, I
saw the possibilities. Imagine workgroups at multinational
companies being in constant communication. Imagine a plant
manager in remote Wyoming being able to confer with other
colleagues about how to prevent a major plant disaster,
or how to handle a personnel issue, or how to implement a new
corporate policy. I was inspired--here at last was a
technology that could help me do my lifeswork.

So I began to spend time online. It's actually like being in a
place--only you're not really there and neither is anyone
else. I got to "meet" my fellow pioneers while sitting at my
computer. Many of my online acquaintances have, over the
years, become colleagues and friends.

In 1983 the Exxon Minerals Company moved to Houston, TX. and I
left to become an independent consultant in computer
conferencing and computer communications.

With hindsight it was a bold move. The industry was barely
embryonic; the demand for my services was nil. But I was
lucky--I found an enlightened Exxon manager who shared my
dream. We launched the first Exxon network in January 1984.

After that successful experiment, I set up several other
networks designed to link geographically dispersed workgroups
in industries as diverse as public accounting, consulting, and
manufacturing.

I continue to use public online systems for my clients, and
it's still an uphill battle. I can't make a living solely from
consulting in this field. My business is improving and I
continue to write and speak on the subject and am well-known in
the industry, but I've still had to expand my services to other
computer-related activities just to make a living.

But electronic networking is my passion. In April 1985 I
co-sponsored the first Electronic Networking meeting. From it
was forged the Electronic Networking Association (ENA)--of
which I am the first President. If you pass this ruling, ENA
and most of its members will be forced offline. Currently they
struggle to pay their $6 or $7 per hour nighttime line fees.
Nearly double those rates in one move and they will go
offline. Many of the companies that service them will go out
of business--those that remain (if any do) will have to
increase their rates to cover costs with a reduced user base.
Others will leave--it will mean a downward spiral to extinction.

The arguments

* Rate Shock

This argument has been made over and over again, I know. Let
me give you a different slant on the issue.

Many of my clients and other corporate department mangers are
under pressure from MIS departments to bring services in
house. In most instances, the in-house systems will be
inferior. If this rate increase goes into effect, my clients
will lose their battle--users will get dimin ished service,
in-house developers and other providers will have reduced
competition, and system development will suffer.

* Striking the meek

Actually, my large corporate clients will survive this increase
if it is, indeed, imposed. They will simply bring their
electronic services inhouse, thus ducking the increased costs.

The losers will be those LEAST able to pay--individual users,
small and medium-sized corporations, nonprofits, educational
institutions, and research facilities.

* Keep America First

This is the most powerful argument of all, I believe. Here is
an industry America leads in, just because the US government
has stayed out when other governments have meddled and taken
their tithe. Impose this rate increase and Japan and France,
already strong, will forge ahead.

* Stifle Democracy

Online communications are potentially the best possible forum
EVER for true democracy and free speech. For example, my
fellow pioneer Mike Greenly has created the field of online
journalism, where online readers can direct questions to
candidates and others at political conventions. Debates too
numerous to mention have already taken place online. In time,
political candidates and special interest groups will use this
medium to do what America is all about--express themselves and
fight for their causes.

In a way, this rate increase is actually a violation of the
First Amend ment--a sort of economic violation. Suppose, for
example, the government were to impose a fee that made daily
newspapers sell for $10 a copy. There would still be free
speech--but who could afford it? This ruling would do that to
the online world. Please don't.

In closing

I want to reiterate that I don't think you really understand
the impact of this increase. For example, paragraph 8 of your
proposal says the ESPs have had time to plan for this. But the
users have not. And ESPs must pass this cost to their users.
No business could absorb such an increase-- certainly not one
that is marginal to begin with.

I think there may well be some inequities in the existing
system. However, I urge you to defer this decision until you
have gained a greater understand ing of the industry and the
issues. I hope you will postpone action for at least two
years--by which time the industry will have had some time to
mature and to recover from the threat of this increase. In the
next two years, major technical advances--in hardware and
software--will be im plemented that will allow users to spend
much less time online while doing the same amount of work.
These advances will mitigate the impact of future rate
increases.

I struggled to be brief in this document because I know you
have much to read. But I have more to say than I can write
here. I shall seek to meet with you and members of your
committee and of Congress in person. As an independent
consultant who is barely making ends meet, I will not be paid
for these efforts. But this issue is so critical to the
survival of a whole industry and to my personal future than I
cannot but make this effort. I hope you will be able to meet
with me.

Sincerely,



Susanna Opper
encl.
cc: The Honorable James H. Quello
The Honorable Mimi Weyworth Dawson
The Honorable Patricia Diaz Dennis
Gerald Brock, Chief, Common Carrier Bureau
Thomas Sugrue, Chief, Policy Division, Common Carrier Bureau
William H. Tricarico, Secretary, Federal Communications Commission