US/ND-4: Your Opinion Wanted...
Your Opinion Wanted...
Wong, WayJane (WAwong@smtp.cde.ca.gov)
20 Sep 96 14:57:26 PDT
Dear Fellow Participants,
I have been trying to keep up with this seminar since it began and have
found it to be very time consuming, but worthwhile to read other people's
viewpoints, questions and concerns. Thank you Information Renaissance.
I work for the California Department of Education. The following ideas
have NOT yet been thru our department's review and approval process.
However, our Unit within the Department of Education formed a small
working group called CCUSAT, which consists of myself, Carole Teach and
representatives from Alameda, Santa Cruz, Los Angeles, and Kern County.
I wish that we could have included more representatives from other
California regions but time would not permit. The following are the ideas
that we have incorporated into a draft that is still being worked on and
I hope to submit as ex parte to the FCC very soon.
I anticipate a variety of responses to our ideas and welcome any
comments, whether they be supportive or non-supportive, constructive
criticism, etc. We are all just trying to propose the best, most
realistic and equitable suggestions that would support the real
intentions of the Telecommunications Act of 1996.
Here goes:
Schools and libraries should have discounts for basic and advanced
services. The discounted services would be achieved through a
competitive procurement process. What has historically been defined as
"basic and advanced services" are not to be construed as separate. All
services, whether basic or advanced, would be available to schools and
libraries as discounted rates and all telecommunications carriers
including internet service providers should be considered as providers of
these services. We define universal services to be that which is defined
for "advanced telecommunications capability" in Section 706. It is
"broadband telecommunications capability that enables users to originate
and receive high-quaility voice, data, graphics, and video
telecommunications using any technology". Universal services should also
include new products and service enhancements that are not presently
available. We agree with California's Oakland Unified School District
"Comments on Proposed Rulemaking" that Internet access should be included
under the classification of advanced services and Internet Service
Providers (ISPs) be included under the category of telecommunications
carriers.
A new agency, whether it be at the national level, state or both, needs
to be formed. This new agency would embody equitable representation from
various interests such as education, libraries, health care, the
community, local government, the business sector, the
telecommunications industry and the State Commission. They would be
empowered to establish accountability measures, establish a competitive
bidding process to leverage Universal Services Fund, qualify
institutions who would submit their requests, provide funding incentives
and monitor various activities. The intent is to create a competitve
market place where technological innovations, economic efficiencies and
competitive procurement will replace direct subsidies and taxes on the
ratepayer.
All services would be unbundled and any telecommunications carriers
including internet service providers wishing to participate in the
competitive bid process can submit their proposals. The bids would take
place at the state level. A base line would be established for the
educational discounts which may result from the bid process. These rate
floors could be based on the existing tariff rates currently paid by
schools. I have attached Oakland's further comments to Public Notice
question #9 to the end of this email because I feel it is the needle in
the hay stack that addresses how universal service support for schools,
libraries and health care providers can be structured to promote
competition.
But for now...
Let us pretend that the FCC supports our competitive procurement
process... this would open the following scene:
a) Each state PUC would form an agency that would be the administrator
of their portion of the universal service funds. This agency would
establish the criteria for the bid proposals, etc.
b) Next, this agency would make public that the state is now accepting
bids for a list of unbundled services by a certain deadline.
c) The deadline arrives and the agency selects the winners of the bid
for the different types of services.
d) The agency makes this list available to all schools, libraries and
rural health care providers.
e) The institutions now have a choice... They can choose a low cost
telecommunications carrier from the established state list or they can
go off on their own and select a carrier of their own choosing.
Ideally, the institution could use the state bid as leverage to obtain a
lower bid from some other telecommunications carrier or just use a
winning bid...
For those with concerns about services within the rural and insular
areas, Oakland's proposal addresses these areas in their comments below.
Thanks,
Way Jane Wong
The following is the Oakland Unified School District's response to
question #9 of the Further Comment on Specific Questions From Common
Carrier Bureau Public Notice:
Question #9
How can universal service support for schools, libraries, and health care
providers be structuerd to promote competition?
Oakland response -
The Oakland Unified School District Proposal
I. A contract agency should be established by each State Public Utilities
Commission. This agency could be a part of the State Public Utilities
Commission or an actual independent body similar to the nonprofit
organizations established in the Act.
II. The contract agency would be empowered to issue a Request For
Proposal (RFP) to all telecommunications service providers interested in
providing discounted universal and advanced services to schools,
libraries and health care providers within the jurisdiction of the State
PUC.
III. The contract agency would designate the service categories up for
bid and permit service providers to bid on any and all service
categories.
IV. The contract agency would designate applicable geographic service
areas. The total number of service areas must cover the entire state.
Examples of geographic service areas could be:
( a single geographic service area covering the entire state;
( geographic service areas coterminous with existing LATAs within
jurisdiction of the PUC; or
( specific geographic service areas designated as rural or urban, high
cost or low-cost.
V. Service providers responding to the RFP should be permitted to bid on
any and all service categories.
VI. In the bids submitted by the service providers there must be three
cost items:
( the basic cost for providing their universal and advanced services;
( the discount cost offered to schools and libraries for each service
category; and
( the cost subsidy required by the service provider from the universal
fund to fund the discounted services.
VII. If there are geographic areas where no service provider makes a bid
to provide service, the contract agency will issue another RFP permitting
the winning bidder to qualify for high cost or low income subsidies from
the universal fund.
VIII. The contracting agency could avoid the problem of lack of
participation in high cost areas through a careful mapping of the
geographic service areas and combining rural/urban and high income/low
income locales. For example, LATA 1 in California not only includes the
very dense urban San Francisco- Oakland Metropolitan Area, but the rural
Mendocino County as well.
IX. Interexchange access should be unbundled from the local loop and no
universal fund subsidies be allowed for interexchange access. An
exception to this prohibition would be in the area of rural subsidies for
health care Further Comments Page 6. providers. Furthermore, universal
fund supports for lifeline services should be limited to local access.
X. It is proposed that each State PUC establish a universal service
advisory council composed of fund recipients, contributors, state
regulators and consumer groups to insure the neutrality of the contract
agency and to provide a forum for airing the concerns of all parties.
XI. The award of a contract for the provision of discount services will
be made to the lowest responsible bidder. The contract agency will
evaluate the bid responses and make its recommendations to the universal
service advisory committee.The contract agency will be responsible for
the administration of the award. The universal service advisory committee
will provide administrative oversight.