Comments from Jeffrey Dukes on Docket No. UT-970325 Page 1 Comments from Jeffrey Dukes on Docket No. UT-970325 NOTICE: Opportunity to Comment Docket No. UT-970325 Page 1, end of paragraph 2 …. In addition to comments on the outlined issues, please feel free to comment on any additional aspect of an obligation to serve requirement. The issuance of this ‘NOTICE’ is an example of the criticality of telephone service to the infrastructure of life in America --- for responses, this NOTICE only contained ‘e-mail’ addresses and ‘Telephone’ numbers NOTICE: Opportunity to Comment Docket No. UT-970325 Page 3 1. How should the obligation to serve differ, if at all, between: c. The obligations of incumbents and new entrants with respect to customers outside any incumbent’s current exchange boundaries? Where there is an abutting exchange boundary, the service requirement should be voluntary. Where there is a non competing exchange boundary gap, that gap should be filled in by the local exchange. Where there is a competing exchange boundary gap, the gap should be filled in by moving one or both exchange boundaries. The adjustment should be based on such things as physical or governmental boundaries. Such adjustment should be at the desecration of a third party such as the Commission. e. …., and its obligation to serve new customers within existing exchange map boundaries? Existing exchange map boundaries where made up based on the then centers of population and commerce. They actually contained multiple packets with vacuums in between. As new packets appeared between existing packets, these new packets where served. But if a packet appeared that was only adjacent to an existing packet the ETC could choose to ignore it. (I am told by old timers that when GTE took over most of Snohomish County, there was then telephone service in Silverton but based on Density we where left out of the progress of life. You can still see some of the glass insulators in a few old trees NOTICE: Opportunity to Comment Docket No. UT-970325 Page 4 4. For purposes of fulfilling the obligation to serve requirement, are ILECs’ designated (tariffed) service areas appropriate, or could some other geographic area be considered? If a major ILECs’ tariffed area is the major viable portion of a larger government area such as a county or of a physical area such as an island, they should be required to serve all of that larger area. 5. Section 214(e)(3) requires state commissions to designate an ETC for unserved areas of the state. What process should the Commission use to designate provider(s) that will have an obligation to serve currently unserved areas of the state? If a case-by-case approach is recommended, what specific criteria should the Commission consider? The nearest current ETC should be required to provide service. In a case where more then one ETC wishes to be appointed, the nearest ETC should be given preference because they have ‘been there’ all along. The other ETC(s) are just being predatory. In any case the most important criteria the Commission should consider is who can and will provide the best overall service to the consumer. 6. What service(s) should be provided pursuant to the statutory obligation to provide service requirement? Should the service(s) provided differ depending upon whether the customer is located in an existing exchange area or in an unserved area? One would hope and expect that all customers are treated equal. But if that can not be then as a minimum there should be: One private line Access to 911 Access to the local seat of government i.e. the county seat. 9. Are there any legal, institutional, or market factors that the Commission should consider in altering the existing ILECs’ obligation to serve? Market factors should no longer be considered when defining obligations to serve. The telephone is so entwined into modern life that it is almost as important as air and water. You can collect your own water and generate your own electricity, but you can’t create your own dial tone. 10. Can the limits of an obligation to serve requirement be defined by technology?; by business plan?; by any other attribute or attributes other than a tariff? At this point, a company should only be required to provide a service or product that is currently in their field of business. That ‘field’ of business should include all of the United States. If a company provides a service or product in Florida, then the Commission should be able to require that service or product be provided in Washington. What other issues, not addressed here, should be addressed by a Commission rule concerning the obligation to serve requirement? The principle issue should be the Health, Safety and Well Being of ‘ALL’ the citizens of Washington State. The secondary issue is the greatest possible convenience for all citizens. 12. Do wireless providers have an obligation to provide service within their designated serving areas? Can the Commission designate wireless providers as ETCs? Wireless providers should be required to provide the widest possible service area. Currently there is competing infrastructure within high density areas. There should be a designated infrastructure provider renting service to all service providers. If that where so currently, the whole State could have been covered for a far lower cost. And so the consumer could have had a lower cost and a greater range. We all pay for public schools, emergency response teams, welfare…etc , irregardless of our usage of them. It is done for the greater public good. This was not always so, but as times change, things change. And so, the way telephone service requirements are made should change. Sincerely, Jeffrey Dukes 49419 Mountain Loop Hiway Silverton Granite Falls, WA 98252 Home phone (Service not available) Work phone 253-773-9294 FAX 253-773-9407 mailto:jeffrey.l.dukes@boeing.com mailto:dukesj@gte.net Used via a payphone, 12 miles from my home.