This response reflects the archived comments of the Education & Library Networks Coalition (EDLiNC See: "School Boards Association of" listing) They said it better than I could. 1. How can schools and libraries share services with each other and with other community groups? > Guilford County, North Carolina, has equipped all of its schools with interactive, > broadcast-quality distance learning facilities, connected all of its classrooms with fiber > optics, and installed an OC-3 fiber line to link its network to the public switched > network. Attendance rates are up, discipline problems are down, and the County has > reduced staff travel and the busing of students for special classes.2 > In Union City, New Jersey, the introduction of computers and Internet access has led to > marked improvement in the English language skills of the student body, 75% of whom > do not speak English at home. The use of e-mail has encouraged students to develop > their writing skills, the ease of on-line research has improved the quality of research > projects, and standardized test scores have gone from well below the state average to > above average. KickStart Report at 37. > The State of Maryland has developed "Sailor," a state-wide telecommunications > infrastructure connecting public libraries across the state and allowing patrons remote > access. Every Maryland resident can now reach the Internet and information about state > and local events, affairs, and resources with a local phone call. KickStart Report at 52. > The Southeast Kansas Interactive Distance Learning Network operates a fiber optic > network that can carry up to 16 channels of video simultaneously, and has been used to > conduct an interactive town hall meeting with the area's Congressman by linking ten > school sites. In addition to increasing the range of available courses, the network has > been used for special programs such as video conferences between American and > Russian students. See articles attached as Appendix C. > Beaver High School and three other Oklahoma schools have established an interactive > distance learning network that is also being used for weekly teacher training sessions. > NSBA telephone survey. > Approximately 200 public libraries now maintain World Wide Web sites, including the > Alachua County Library District in Gainesville, Florida, the St. Charles City-County > Library District in St. Peters, Missouri, and the Seattle Public Library in Seattle, > Washington. By establishing Web sites, these libraries have extended their reach beyond > their geographic boundaries and made their electronic holdings available to a new class > of world-wide patrons.(Comments 4-10-96 pg.5-6) > School- and Library-Based Networks Offer New and Enhanced > Roles for Those Institutions as Learning Centers in Their > Communities. > > The 1996 Act offers a mechanism for schools and libraries to strengthen their roles in their > communities, by serving as access points to provide all citizens with affordable access to > information. > > First, access to the Internet through schools and libraries -- or other access points such as > community colleges and community centers -- can become a cost-effective way for the country to > expand subscribership to all Americans, including those who cannot afford the proper > equipment. Second, schools and libraries can become community hubs for those who do have > the proper equipment. Parents can communicate better with teachers, and other residents can get > quick, easy access to information about community events and local issues through community > networks and local bulletin boards. Third, schools and libraries can address the peculiar > problems of rural areas. K-12 schools, libraries, teachers, parents, and other citizens in these > areas have to pay substantially more than their urban counterparts to reach on-line information > services and the Internet. A school or library in Java, South Dakota, or Rochester, Vermont, for > example, could become the access point for the entire community to reach on-line information > without paying prohibitive long distance toll charges.(Comments, 4-10-96. p.7) > F.Sharing of Facilities with Noneducational Users. > > The Commission should not take any action that would significantly restrict sharing of > facilities. So long as a facility is being used primarily for educational purposes, it should > be deemed to meet the requirements of the 1996 Act. Otherwise, innovative uses of > technology and enhanced roles for schools and libraries could be stifled. Schools and > libraries should remain free to share their networks with other entities in the community, > and schools and libraries should not be prohibited from charging lab fees or user fees to > defray expenses related to the use of a network. (Comments 4-10-96, pg.13) > Second, permitting aggregation on the broadest possible basis will also promote competition. > Allowing pooling of demand through liberal aggregation rules will make the provision of > advanced services to remote areas more economically feasible, thus expanding the reach of the > serving providers, and encouraging competitors to bid. (Reply to Comments 5-7-96 pg.2) > 10. Should the resale prohibition in Section 254(h)(3) be construed to prohibit only the resale of services > to the public for profit, and should it be construed so as to permit end-user cost based fees for services? > Would construction in this manner facilitate community networks and/or aggregation of purchasing > power? > > Answer: The resale prohibition should only apply to resale for profit, and should permit end-user > cost-based fees for services. By interpreting the prohibition narrowly, the Commission would further > support and encourage the development and proliferation of community and civic cooperatives by > allowing the aggregation of purchasing power. The comments filed by the Lincoln Trail Libraries System > describe a typical library cooperative, as found in several states: > > Lincoln Trail Libraries System is a state-sponsored organization serving > the libraries of 116 members in East Central Illinois. Academic, public, > school, and special libraries participate as members. Lincoln Trail member > facilities are spread over approximately 250 buildings in a nine-county > area. This area is largely rural. The median population served for participating > school districts is 795, and the median size for participating public libraries > is 3,042. The median budget of all participating libraries is $54,000, > with some annual budgets falling below $10,000 per year.10 > > This type of consortium -- which should, of course, include private schools -- allows individual entities to > broaden and expand the services they offer to the public. > > Furthermore, the rules regarding resale should distinguish between the telecommunication facilities and > services offered using those facilities. In its earlier comments, the Washington State Library suggested > that: > > [T]he FCC should seriously consider separating the telecommunications mechanisms that > make an electronically based service possible (the tool) from the > service itself (the product) in applying the 'no resale' prohibition. > For instance, a library may not resell its discounted access to its > city government, but it may levy a fee for Internet classes, or setting > up and maintaining an Internet account through the library, or for > maintaining a web site for its unit of local government. Such an application > would appear to satisfy the intent of the Telecommunications Act, but this > distinction would be more easily known and understood by all concerned if the > FCC clarifies it.11 > > > 11. If the answer to the first question in number 10 is "yes," should the discounts be available only for > the traffic or network usage attributable to the educational entities that qualify for the Section 254 > discounts? > > Answer: One of the primary goals of the Act is to ensure that educational institutions and libraries have > access to affordable telecommunications services. We believe that encouraging the growth of > community-based consortia which include libraries and schools is one highly effective method of > furthering this goal. > > These consortia further the goals of the Act in several different ways. The broad consortium approach to > community networking enhances the educational potential of the network by including partners and > resources that might not otherwise be available. By providing access to their resources, community > network partners (such as universities, local government, and local businesses) amplify the educational > benefits of the network above and beyond that which schools and libraries could provide on their own. > For instance, consortia might provide all members with access to the resources of the local university > library, as well as provide access to important information on local government. > > The Commission rules in this proceeding should encourage institutions to contribute their resources to the > educational efforts of schools and libraries. In addition to the obvious educational benefits of these > resources, access to this information can help build civic participation and interest by enabling all members > of a consortium to access important information. > > Consortia also improve the ability of schools and libraries to get access to the sophisticated > telecommunications services they need. Aggregate purchasing of services not only leads to lower prices > for schools and libraries but also enables schools and libraries to pool the demand in areas where local > providers might be reluctant to offer sophisticated telecommunications services. This aggregation of > community demand has proven an effective method for attracting telecommunications services in many > underserved communities across the country. > > Aggregation has also led in many cases to the purchasing of package deals which include services that, > while furthering the telecommunications goals of the educational entities, might not be eligible for > discounts under the Act. In these arrangements, schools are better able to serve their constituencies > because of the mix of partners in the consortium and the broad variety of services that these partners need. > > Finally, consortia are better equipped to deal with the ongoing costs of financing and supporting a > telecommunications service. While the ongoing technical support and training costs associated with a > network might be more than a school can support on its own, distributing these costs among the members > of a consortium is a proven method of supporting these ongoing costs. (Further Comments 8-2-96 pg.9-10)