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THE OPEN PLATFORM PROPOSAL:
A Proposal by the Electronic Frontier Foundation for a National
Telecommunications Infrastructure



Until now, the nation’s telecommunications policy debate has largely been
perceived as a struggle among entrenched commercial interests over who will
control and dominate markets such as information services, manufacturing,
and long distance service. It is time to refocus the debate by seeking near-term
technological, economic, legislative, and regulatory solutions that will
encourage the rapid development of a diverse information services market
and help realize the democratic potential of new information media.
In the fall of 1991, the Electronic Frontier Foundation was invited by
Representative Edward Markey to testify before the House Subcommittee on
Telecommunications and Finance on the subject of Bell company entry into
the information services market. To address concerns that Bell entry into this
market would reduce the diversity of information through anti-competitive
behavior, the EFF proposed the deployment of a digital information platform,
using existing technology and facilities, which could be made available on a
ubiquitous, affordable, equitable basis. Our testimony suggested that the
Integrated Services Digital Network (ISDN) could be such a platform.
Narrowband ISDN, if offered nationwide and tariffed at affordable, mass-
market rates, can offer end-to-end digital service without major infrastructure
investments. This narrowband technology can also serve as a transitional
telecommunications platform until national switched broadband access
options become available early in the 21st century. With an ISDN platform in
place, information entrepreneurs will soon be able to reach an expanded
market in which to offer text, video, and interactive multimedia services.
Public agencies; private communications, computer, and publishing firms;
and even individuals will be able to access an inexpensive, widely available
medium in which to publish and communicate electronically. Other
technologies from outside the public telephone network may also come to
play an important role in providing digital access, but because of the
importance of the public switched telephone network, ISDN has a key role to
play.
The EFF believes that ISDN deployment and other developments in the
public telecommunications infrastructure should proceed with the following
goals in mind:
• make end-to-end digital service widely available at affordable rates;
• promote First Amendment free expression by reaffirming the principles
   of common carriage;
• ensure competition in local exchange services;
• foster innovations that make networks and information services easy to
   use;
• protect personal privacy; and
• preserve and enhance equitable access to communications media for all
   segments of society.
A robust, open telecommunications infrastructure is important for the
international competitiveness and economic health of our nation. But also, as
people become more dependent on telecommunications services in their
daily lives, the character of the evolving infrastructure and the laws that
govern its operation will come to have a profound impact on politics,
culture, education, and entertainment. Therefore, the steps that we take at this
critical moment in the development of telecommunications technologies
must be carefully considered.
ISDN is a platform that could stimulate innovation in information services
in a way that will benefit much of the American public that currently has no
access to electronic information services. Lessons from the personal computer
industry can help guide telecommunications policy makers in the
development of an information infrastructure. The desktop personal
computer represented a revolutionary platform for innovation in the 1980s
because it was affordable and was designed according to the principle of
open architecture, allowing numerous hardware and software entrepreneurs
to enter the computer industry.
To bring the benefits of the Information Age to the American public in the
1990s, we need to build an open, ubiquitous digital communications platform
for information services. Just as the personal computer brought access to
computing power beyond large organizations, widely available ISDN can
enable the citizen’s access into the Information Age.
.c.
.c.What is ISDN?
ISDN (Integrated Services Digital Network) is a technology designed for
the public switched telephone network that allows low-cost communication
in data, voice, video, and graphic media over the existing copper telephone
network. ISDN is not an information service, but a transmission medium — a
platform — for delivering and receiving information in a variety of formats.
Crude data communication is possible over standard analog telephone lines
now, but the fact that the existing transmission system was designed for voice,
not for data, means that transmission rates are very slow, error rates are high,
and equipment (modems) is difficult to use. Basic Rate ISDN offers
transmission speeds fifteen to sixty times faster than most data transmission
schemes now used on voice lines. More than just increased speed, what is
important about ISDN is that it offers the minimum capacity to carry full
multimedia — voice, text, image, and video — transmissions.
ISDN is not a “field of dreams” technology. It is a fully developed
international standard that has been extensively tested in the United States
and has already been implemented in the public switched telephone
networks of other countries. Real applications have been demonstrated over
ISDN lines. Major communications carriers have field-tested distance
learning applications that allow students in classrooms all across a city to
participate in multimedia presentations run by a teacher in a remote location.
Inexpensive desktop and home video conferencing systems are now being
introduced that run over ISDN lines. These applications have real value, but
are only a small sample of what entrepreneurs will inevitably produce if
ISDN becomes widely available. Yet, the promise of this service can be
realized only if the local phone companies tariff and deploy the service.

.c.Prospects for Near Term ISDN Deployment
The EFF’s Open Platform Proposal for ISDN is a work-in-progress. We
have received valuable comments and support from key players among the
Regional Bell Operating Companies (RBOCs), interexchange carriers,
information providers, and state public service commissions, all of whom
believe that ISDN can play a crucial role in developing the information arena
for the benefit of all today. To date, we have reached the following
conclusions:
1. ISDN deserves a second look because it can meet many of the
information needs of residential and commercial users long before a
public, switched broadband network will be available.
2. ISDN can be made widely available within the next three to five years,
without massive infrastructure investment or new technology
development.
3. ISDN must be priced as a basic service at affordable rates.
4. ISDN is a critical and even necessary transitional technology on the path
toward the future broadband national public network.
5. The benefits of other networks that are already important information
distribution media can be enhanced by interconnection with ISDN.
More investigation of many issues is required, especially the regulatory
economics of deployment. Still, we are optimistic that ISDN is an important
step along the path to a telecommunications infrastructure that meets the
diverse needs of the nation.

Second Look at ISDN
ISDN can meet many of the critical information needs of both residential
and commercial users even without broadband capacity. ISDN is the only
switched, digital technology available today in the public switched network
that can be deployed widely in the near term. For text-based data users and
publishers, ISDN offers a dramatic advantage over data transmission
technology currently used by individuals and small organizations. One of the
two 64kbits/sec data channels available in the ISDN Basic Rate Interface can
fax thirty typewritten pages of text in one minute, and send a 1,000-word
newspaper article in less than one second. Dramatic advances in video
compression make transmission of videoconference images possible today,
and all indications are that new compression algorithms will allow real-time
transmission of VCR-quality video images in the near future. The
Massachusetts Department of Public Utilities found, in the course of its recent
investigation of ISDN, that “residential customers will benefit from the
availability of significant enhancements to services such as home banking,
library access, work at home, home health care monitoring, home shopping,
and information access.”1
Some telecommunications cogniscenti view the promise of narrowband
ISDN as limited. They are aware that ISDN has languished unimplemented
for over ten years, and because they know that other copper-based
transmission technologies offering much higher bandwidth are available. We
are fully supportive of implementing higher capacity narrowband and
broadband networks in the future, when technology and user demand make it
possible.
The personal computer industry shows that raw power is not all that
matters in a new technology. By about 1980, corporations already had good
access to massive computational facilities at the institutional level through
their mainframes and minicomputers. But individual workers had no
effective direct access to those facilities. In practice, all the computing power
didn’t directly help the office worker get her job done. Personal computers
made a difference in the office and the home because they were directly
under the control of the individual, despite the fact that they were anemically
under-powered. Similarly, there may be high data capacity at the institutional
data network level already, but if individuals and small organizations can’t
connect with it, its value is limited. We must make tapping into the digital
switched network as easy as ordering a phone line for a fax. Just as PCs
enhanced individual productivity, ISDN can enhance individual
connectivity.
In this regard, we are encouraged by the fact that the computer industry
has recently joined the debate on the telecommunications infrastructure. With
the growing recognition that the hardware and software they design will be
severely limited by the lack of a nationwide switched, digital
communications infrastructure, key players in the industry have lent their
support to the EFF’s Open Platform Proposal as a transitional infrastructure
strategy.

ISDN Means An Available Infrastructure Soon
In sharp contrast to fiber optic-based broadband technologies, only modest
infrastructure investment is required. Digital central office switches are
required for ISDN2, but with the Bell companies’ aggressive deployment of a
fully digital switching and signalling system (Signaling System Seven), the
bulk of the infrastructure necessary to support ISDN is already installed or
planned.3 Some Bell companies, such as Bell Atlantic and Ameritech, plan to
have over 70% of their subscriber lines ISDN-ready by the end of 1994. Other
companies, however, project deployment rates as low as 21%. On a national
level, 56% of all lines are expected to be capable of carrying ISDN calls by
1994.4 (See Appendix A)
Many segments of the telecommunications industry are engaged in a
concerted effort to make nationwide ISDN deployment a reality. Problems
that haunted ISDN in the past, such as lack of standard hardware and software
protocols and corresponding gaps in interoperability, are being addressed by
National ISDN-1. This is a joint effort by the Bell companies, interexchange
carriers, switch manufacturers, and Bellcore to solve major outstanding
standards problems. By the end of 1992, a single hardware standard will make
ISDN central office switches and customer premises equipment
interoperable, regardless of which vendor made the equipment. Following
National ISDN-1, National ISDN-2 will address standards problems
associated with ISDN Primary Rate Interface (PRI), a switched 1.5Mbit/sec
service with 23 separate 64kbit/sec data channels and one 64kbit/sec
signalling channel.
Led by Bellcore, the communications industry has a nationwide
demonstration of real, off-the-shelf, ISDN services planned for November
1992, called TRIP’92. A variety of local and national ISDN services will be
demonstrated on a working ISDN network covering twenty cities around the
country. TRIP’92 will show that Bell companies, long distance carriers, and
information providers can work together to provide the kind of ubiquitous,
standards-based service that is critical to the overall success of ISDN.
Additional interconnection problems remain to be solved before ISDN is
truly ubiquitous. Among other things, business arrangements between local
Bell companies and interexchange carriers must be finalized before ISDN
calls can be passed seamlessly from the local exchange to long distance
networks.

ISDN Must Be Priced Affordably
If ISDN is to be a platform that spurs growth and innovation in the
information services market, it must be priced affordably for the average
home and small business user. Here, the telephone industry has a valuable
lesson to learn from the computer industry. The most valuable contribution
of the computer industry in the past generation is not a machine, but an
idea—the principle of open architecture. Typically, a hardware company
neither designs its own applications software nor requires licenses of its
application vendors. Both practices were the norm in the mainframe era of
computing. Instead, in the personal computer market, the hardware company
creates a “platform”—a common set of specifications, published openly so
that other, often smaller, independent firms can develop their own products
(like the spreadsheet program) to work with it. In this way, the host company
takes advantage of the smaller companies’ ingenuity and creativity.
Platform services, even if they are ubiquitous, are useless unless they are
also affordable to American consumers. Just as the voice telephone network
would be of little value if only a small fraction of the country could afford to
have a telephone in their home, a national information platform will achieve
its full potential only when a large majority of Americans can buy access to it.
Therefore, the tariffs adopted by state public utility commissions are critical
to the success or failure of ISDN.
Since few states have adopted single-line business and residential ISDN
tariffs, there is an opportunity to establish pricing principles for ISDN that
make it viable as a mass-market service. The Massachusetts Department of
Public Utilities’ (DPU) recently completed proceeding should serve as an
example to other states. The Massachusetts regulators found that ISDN is a
“monopoly, basic service that has a potentially far-reaching and significant
role in the telecommunications infrastructure of the Commonwealth.”5 The
DPU recognized that the “risks of pricing the service too high are of much
greater concern ... [because] high rates could discourage the development of
new ISDN-dependent technologies and their applications.”6 The final tariff
approved has a monthly access charge of $13.00 for single-line residential
service and usage fees of 2.6 cents for the first minute and 1.6 cents for each
additional minute. After much dispute, New England Telephone (NET)
based the usage-sensitive component of the tariff on measured voice rates
already in place in Massachusetts. We believe that NET’s decision to link
prices to existing basic voice rates is an important signal to other LECs and
other state commissions that low-priced ISDN service is indeed possible.
Studies by experts in the field of regulatory economics indicate that ISDN
can be priced affordably. Dr. Lee Selwyn found, based on data from the
Massachusetts proceeding, that the average monthly price for ISDN service
should be approximately $10.7 An analysis of ISDN deployment by a leading
consumer advocate also indicates that ISDN can be offered at a relatively low
cost to consumers. Dr. Mark Cooper, Research Director of the Consumer
Federation of America, found that average ISDN monthly costs are now
roughly $7.50, and can be expected to decline to $4.50 in the near future.8
To encourage widespread use of ISDN, it must be priced at or near the
price levels already in place for basic voice services. ISDN line charges will
be somewhat higher than analog voice services because there are additional
one-time capital costs associated with offering ISDN service, but basing prices
on voice telephone rates is possible and rational from a regulatory standpoint.
The digital switches that carry ISDN calls treat voice and data calls in
exactly the same manner. A five-minute data call uses no more or less
switching resources than a five-minute voice call, so their pricing should be
equivalent. Some states may choose to tariff ISDN only with measured rates,
while others may also want to adopt a flat rate scheme similar to that which
exists for residential voice services. The economics of this issue need more
study, but we believe that both options have arguments in their favor.9
Current prices for ISDN telephones, data links, and in-home network
terminators are high. An ISDN telephone with voice and data interfaces costs
roughly $1,000. If these price levels persist, many small-scale users will never
enter the market. However, with increased demand, ISDN terminal appliance
prices can be expected to follow the steep downward curve of VCR and PC
prices. When first introduced, VCRs cost well over $1,000, but now sell below
$200 for a basic unit.
Ill-considered pricing policy could, alone, cripple ISDN’s chances for
success. We hope that the Bell companies with more aggressive deployment
plans will file such residential tariffs and set a precedent for progressive,
mass-market pricing that will make ISDN affordable. In any event, legislative
or regulatory action may be necessary to guarantee affordable rates and
widespread availability of ISDN around the country.

.c.ISDN: A Critical Transitional Technololgy
ISDN is not a permanent substitute for a broadband network, but it is a
necessary transitional technology on the way to public switched broadband
networking. Though some might like to leap directly to a broadband
network, the entire telecommunications and information industry still has
much to learn about designing a broadband digital network before it can be
implemented.10 Though a first generation of broadband switches are now
being introduced, many basic questions still remain about the most
appropriate design for a broadband network that can replace or be built on
top of the analog telephone network. These questions are impossible to
answer without experience in the ways that people will use a public, digital
switched network.
Some are reluctant to make any investment in ISDN because it is perceived
as old technology. But this is not an either/or choice. If implemented at prices
that encourage diverse usage, ISDN will provide important new services to
all segments of society, and offer vital perspectives on how to design the next
generation of public, switched broadband networks.

.c.ISDN Enhances Extant Networks
The public switched telephone network is a critical, central part of the
nation’s telecommunications infrastructure, so ISDN has a vital role to play in
the overall information infrastructure. In addition to being an information
platform itself, ISDN can interconnect with other networks that offer a variety
of information resources. Cable television systems, which already provide
broadband connections to 60% of U.S. homes and pass by 90%, might provide
a new digital data service. Using ISDN, cable systems could develop
interactive video applications. The Internet, an international packet network
serving universities, government organizations, and an increasing number of
commercial enterprises, has over two million users and access to vast archives
of information. Wireless transmission systems such as PCS (Personal
Communications Systems) can also serve as open platforms for information
services.

.c.Guiding Principles
The public switched telephone network is just one part of what we call the
National Public Network, a vibrant web of information links that will come to
serve as the main channels for commerce learning, education, politics, social
welfare, and entertainment in the future. With or without ISDN, the telephone
network is undergoing dramatic changes in structure, in scope, and in its
growing interrelationship with other communications media. These changes
should be guided by a public policy vision based on the following
principles.
A. Create an Open Platform for Innovation in Information Services by
Speedily Deploying a Nation-wide, Affordable ISDN
To achieve the information diversity currently available in print and
broadcast media in the new digital forum, we must guarantee widespread
accessibility to a platform of basic services necessary for creating information
services of all kinds. Such a platform offers the dual benefit of helping to
create a level playing field for competition in the information services market,
and of stimulating the development of new services beneficial to consumers.
An open platform for information services will enable individuals and small
organizations, as well as established information distributors, to be electronic
publishers on a local, national, and international level.
B. Promote First Amendment Free Expression by Affirming the Principles of
Common Carriage
In a society that relies more and more on electronic communications media
as its primary conduit for expression, full support for First Amendment
values requires extension of the common carrier principle to all of these new
media. Common carriers are companies that provide conduit services for the
general public. The common carrier’s duties have evolved over hundreds of
years in the common law and later in statutory provisions.
The rules governing their conduct can be roughly distilled in a few basic
principles. Common carriers have a duty to:
•provide services in a non-discriminatory manner at a fair price,
•interconnect with other carriers, and
•provide adequate services.
The public must have access to digital data transport services, such as ISDN,
that are regulated by the principles of common carriage.
Unlike arrangements found in many countries, our communications
infrastructure is owned by private corporations instead of by the government.
Therefore, a legislatively imposed expanded duty of common carriage on
public switched telephone carriers is necessary to protect free expression
effectively. A telecommunications provider under a common carrier
obligation would have to carry any legal message regardless of its content,
whether it is voice, data, images, or sound. For example, if full common-
carrier protections were in place for all of the conduit services offered by the
phone company, the terminations of “controversial” 900 services, such as
political fundraising, would not be allowed, just as the phone company is
now prohibited by the Communications Act from discriminating in the
provision of basic voice telephone services. As a matter of law and policy, the
common-carriage protections should be extended from basic voice service to
cover basic data service as well.
C. Ensure Competition in Local Exchange Services
The divestiture of AT&T in the early 1980s brought with it various
restrictions on the kinds of markets in which the newly created local Bell
companies were allowed to compete. Many consumer and industry groups
are now concerned that as these judicially imposed restrictions are lifted
(know as the MFJ), the Bell companies will come to dominate the design of the
emerging National Public Network, shaping it more to accommodate their
business goals than the public interest. The bottleneck that the Bell companies
have on local exchange services critical to information providers can be
minimized by unbundling these services and allowing non-Bell company
providers to offer them in competition with Bell companies.
The post-divestiture pattern of providing long distance service offers us a
valuable lesson: A telecommunications network can be managed effectively
by separate companies — even including bitter opponents like AT&T and
MCI— as long as they can connect equitably and seamlessly from the user’s
standpoint. Together with the open platform offered by ISDN, unbundling
and expanded competition is a key to ensuring equitable access to Bell
company facilities needed for information service delivery.
D. Protect Personal Privacy
As the telecommunications infrastructure evolves, there are increasing
threats to both communications privacy and information privacy. Strong
government intervention will, at times, be necessary to protect people’s
constitutional right to privacy. Careful thought must also be given to the
appropriate use of search warrants and wiretap authorizations in the realm of
new electronic media. While new technologies may pose some difficult
challenges to law enforcement, we must protect people’s constitutionally
guaranteed right to be free from “unreasonable searches and seizures.”
Fundamental civil liberties tenets are at stake as long-standing constitutional
doctrine is applied to new technologies.
The privacy of telephone conversations and electronic mail is already
protected by the Electronic Communications Privacy Act. However,
communications in other media, such as cellular phone conversations, can be
intercepted using available technology by third parties without the
knowledge or consent of the conversants. In addition to this, we believe that
technological advances should be used to help people protect their own
privacy and exercise more control over information about themselves. In
general, citizens should be given greater control over information collected,
stored, and disseminated by telephone companies and information providers.
As the public outcry over Caller ID demonstrates, citizens want and deserve
to have adequate notice about what information is being collected and
disseminated by communications firms, and they must be able to exercise
informed consent before information collected for one purpose can be used
for any other purpose.
E. Make the Network Simple to Use
One of the great virtues of today’s public switched telephone network,
from a user’s perspective, is that it operates according to patterns and
principles that are now intuitively obvious to almost everyone. As this
network grows beyond just voice services, information services that become
part of this network should reflect this same ease-of-use and accessibility. The
development of such standards and patterns for information services is vital,
not just because it helps makes the network easier to use, but also because it
ensures an open platform for information providers. However, standards
development will be ad hoc and even chaotic at first. Numerous standards
may be tried and found inadequate by users before a mature set of standards
emerges. Congress and government regulatory bodies may need to set out the
ground rules for standards planning in order to ensure that all interested
parties have an equal voice, and the resulting standards should be closely
analyzed to make sure that they reflect public needs. But direct government
involvement in the process should be avoided if possible.
F. Preserve and Enhance Socially Equitable Access to Communications
Media
The principle of equitable access to basic services is an integral part of the
nation’s public switched telephone network. From the early history of the
telephone network, both government and commercial actors have taken steps
to ensure that access to basic voice telephone services is affordable and
accessible to all segments of society. Since the divestiture of AT&T, many of
the constituent parts of the “social contract” for universal service have fallen
away. Re-creation of old patterns of subsidy may no longer be possible nor
necessarily desirable, but serious thought must be given to sources of funds
that will guarantee that the economically disadvantaged will still have access
to basic communications services.
The universal service guaranty in the Communications Act of 193411 has,
until now, been interpreted to mean access to “plain old telephone service”
(POTS). In the Information Age, we must extend this guaranty to include
“plain old digital service.” Extending this guaranty means ensuring that new
basic digital services are affordable and available. Equity and the democratic
imperative also demand that these services meet the needs of people with
disabilities, the elderly, and other groups with special needs. Failure to do so
is sure to create a society of “information haves and havenots.”12
The path toward ISDN deployment requires the cooperation of numerous
public and private sector organizations and political constituencies. National
policy direction is needed to ensure that the necessary ubiquity and
interconnection of service providers are achieved. Federal policymakers in
Congress and the Federal Communications Commission will also have to
consider the appropriate regulatory role for guidance of a new national
resource: the information infrastructure. State public service commissions
will be at the forefront of establishing pricing policy for ISDN service. The
success of residential applications for ISDN will depend heavily on the PUCs’
approach to ISDN pricing.
The communications industry — including the Bell companies,
interexchange carriers, equipment manufacturers — all have cooperative
roles to play in making ubiquitous ISDN a reality. The computer industry is a
new but critical player in telecommunications policy. Many of the innovative
products and services to take advantage of ISDN will likely come from the
computer community.
In the policy arena and in relations with industry, many public interest
advocacy organizations have a vital role to play in ensuring that new
technologies are implemented and regulated in a way that promotes
widespread access to new media and preserves the fundamental guarantees of
affordable, universal service.
The Electronic Frontier Foundation is working to solicit comments,
support, and criticism from all of these constituencies. This version of the
Open Platform Proposal has been much improved with the help of thoughts
and reactions from many concerned parties. We welcome more comments
from all who are concerned about the development of the
telecommunications infrastructure.






NOTES

1 ISDN Basic Service, Mass. D.P.U. 91-63-B, p. 86-7 (February 7,
1992).
2 In central offices where digital switches have not yet been
installed, ISDN can still be provided at lower cost than by installation
of special “switch adjuncts.”
3 Though the Bell companies are not required to install Signalling
System
Seven, it is the only practical way that they can meet new FCC
requirements for 800 number portability. See Memorandum Opinion
and Order on Reconsideration and Second Supplemental Notice of
Proposed Rulemaking, FCC Docket 86-10, Released September 4,
1991.
4 See FCC Docket 89-624 and Bellcore Special Report SR_NWT-
002102, ISDN Deployment Data, Issue 2, June 1992.
5 Mass. D.P.U. 91-63-B, p. 34.  Prodigy Services Company was a
driving force behind securing affordable ISDN in Massachusetts.
6 Id. at 86.
7 L. Selwyn, A Migration Plan For Residential ISDN Deployment, April
20, 1992 (Prepared for the Communications Policy Forum and the
Electronic Frontier Foundation).
8 M. Cooper, Developing the Information Age in the 1990s: A
Pragmatic Consumer View, June 8, 1992. See p. 52.
9 Since the average length of a data call may be longer than the
average voice call, the flat rate for ISDN would have to be adjusted
upward to reflect added load on central office switching systems.
However, the mere fact that data lines may remain open longer does
not preclude a flat rate, non-usage-sensitive tariff.
10 The most optimistic BOC estimates on fiber deployment promise
ubiquitous fiber optic cable in roughly 20 years.
11 47 USC 151, et seq.
12 Modified Final Judgment: Hearings Before the Subcommittee on
Telecommunications and Finance of the House Committee on Energy
and Commerce, 101st Cong., 1st Sess. 2 (1989) (Opening Statement of
Chairman Markey). Chairman Markey set the following goal:
“to make [information services] available swiftly to the largest
number of Americans at costs which don’t divide the society into
information haves and have nots and in a manner which does not
compromise our adherence to the long-cherished principles of
diversity, competition and common carriage.”



For More Information Contact:

Daniel J. Weitzner, Senior Staff Counsel, [e-mail]
Jerry Berman, Executive Director, [e-mail]

EFF
1001 G Street, NW
Suite 950 East
Washington, DC  20001
[phone]  tel
[phone]  fax
[e-mail]  internet