US/ND-2: Re: Greetings from the FCC
Re: Greetings from the FCC
Ronda Hauben (rh120@columbia.edu)
Thu, 5 Sep 1996 05:23:11 -0400 (EDT)
Open email to Reed Hundt,
Chairman, Federal Communications Commission
I wondered if you could explain a bit about the nature of the online
seminar mailing list on Universal Service that Bob Carlitz is moderating?
In welcoming the seminar you wrote:
>To Seminar Participants:
>Greetings and good luck in beginning your on-line course! Bob Carlitz
>has set up a great example of the way technology can increase
>communication, learning, and participation in public debate.
>As you know, Universal Service policy will impact all Americans, but it's
>especially important for our education hubs: schools and libraries.
>Universal Service can help bridge the gap between the information
>"haves" and "have nots" by giving every child the tools and knowledge
essential for the 21st century.
>I look forward to reading your course discussions in the official FCC
>record, and thank you for your contribution to this important
>policy-making process.
>Best Regards,
>Reed Hundt
>Chairman, Federal Communications Commission
Reed, my questions are:
In comments to the FCC on the issue of Universal Service, in email,
and in questions raised at the INET '96 (the Internet Society Meeting)
in Montreal to the FCC chief of staff who gave a talk for you, and in
a Report from INET '96 circulated on the Internet after the conference,
I stressed the importance of opening up the comment process in the
rule making procedure so that those who would be affected by the rule
making on the issue of universal service in the new Telecommunications Act
would have a chance to provide input to the FCC on this issue.
Others have supported this sentiment.
Yet no one from the FCC ever commented on these comments nor made any
effort to talk about the need for some form of online process
to open up the rule making process.
Instead there was this online seminar announced. Who is funding it and
why? And what is the role of the FCC in the online seminar?
Is the online seminar to be a means for the FCC to justify removing
universal service from the home telephone user by raising the cost
of their service to subsidize school and library service because
corporate entities will be getting all kinds of lower prices from
the new telecommunications law?
Why was the online seminar created with a strict moderator to direct
discussion away from the broad set of issues that need to be
discussed and considered in any rulemaking process regarding
universal service? Why wasn't the unmoderated prototype created
by the NTIA online hearing on the issue of the future of the Net
held in Nov. 1994 followed, where there were newsgroups created
and a mailing list and public access terminals made available
around the country to provide for a broad set of views and input?
(See http://www.columbia.edu/~hauben/netbook/ -- especially
chapter 11 and 14 describing that online conference)
Didn't the Communications Act of 1934 charge the FCC with promoting
"a rapid, efficient, nationwide and worldwide wire and radio
communications service with adequate facilities at reasonable charge"?
Has that changed? Has the FCC now become the U.S. Department of
Education obligated to provide service to the schools and libraries
at the cost of the home user?
Previously the Department of Education was obligated to oversee
what was provided to the schools and libraries out of general tax
funds. Has the new telecommunications act changed that so that
the home telephone user is now obligated to support lower prices
for the schools and libraries for undefined telecommunications
services and at the expense of POTS for the home user?
The Telecommunications Act of 1996 was drafted with no discussion
nor input allowed from the home user, those who have the need for
the universal service provision. Instead the teleco's and even
some nonprofits had a means to promote their interests to those
in the U.S. Congress. But laws, especially laws regarding
telecommunications infrastructure need to be crafted considering
the interests of all involved. If the issue before the FCC is
the issue of universal service, then the needs and interests
of the home user have to be solicited and considered.
In my efforts to participate in the current seminar, just as in
my efforts to contribute comments to the proceedings, I have tried
to raise the questions involving the interests and concerns of
the home user. These should be similar to the interests of those
involved in the schools and libraries. However, instead of the FCC
encouraging seeing this similarity of interest, there seems to
be the encouragement that schools and libraries seek out to get
lower rates at the expense of the home user.
Subsidizing school and libraries at the expense of the home telephone
user cannot provide for universal service. It can only provide
for the taking away of universal service where the home user
is seen as needing a certain minimal level of service (traditionally
called POTS - Plain old telephone service).
Is there some reason why the FCC has not addressed this issue?
Also, the issue of providing funds to schools and libraries for
telecommunications should be part of what the U.S. Department
of Education funds out of general tax revenue, not a burden on
the home telephone user. Or it should be the concern of the
National Science Foundation, or other appropriate government body.
The National Science Foundation demonstrated that by providing
start up funding for access to the Internet to colleges and
universities it helped make that access broadly available in
the academic community. The U.S. government should be drawing
on these lessons and creating a similar way to make access
available to schools and libraries. But it isn't the home
telephone user who can be asked to subsidize such access or
it will lead to the taking away of universal service rather
than a means of implementing universal service.
Regardless of what the telecommunications act of 1996 states, the
job of the FCC is to provide Congress with the information and
background to understand the needs and interests of those for
whom universal service was crafted over 50 years ago.
A moderated seminar with a moderator who is encouraging schools
and libraries to see their interests as different from those
of the home telephone user cannot be helpful in sorting out the
principles to guide universal service rulemaking.
Also an online moderated process which discourages the broad
discussion that is needed to determine the principles that
are needed to guide rulemaking can't be helpful.
Since I have clearly asked for an online process, I wondered why
instead of anyone from the FCC ever contacting me or discussing
what I was proposing, a strictly controlled and moderated seminar
was set up to narrowly focus the issues that could be discussed.
Who is funding this effort and why?
And why isn't the FCC willing to help open up the rule making
process so that appropriate rules can be drafted?
In the development of the Internet, J.C.R. Licklider, who was
one of the important visionaries helping to guide the earliest
developments that led to the Net, recognized that when there is
a need to figure out a real problem, a broad investigation
is necessary to solve the problem. "There's a lot of reason
for adopting a broad delimitation rather than a narrow one
because if you are trying to find out where ideas come from,
you don't want to isolate yourself from the areas they come from."
(see quote in Netizens: On the History and Impact of Usenet and
the Internet, chapter 8, http://www.columbia.edu/~hauben/netbook/)
Ronda
rh120@columbia.edu
ae547@yfn.ysu.edu
------------
Netizens: On the History and Impact
of Usenet and the Internet
http://www.columbia.edu/~hauben/netbook