Federal-State Joint Board on
Universal Service

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554	APR 12 1996


In the Matter of

CC Docket No. 96-45



COMMENTS OF THE IOWA COMMUNICATIONS NETWORK

The Iowa Communications Network (ICN) is a state of Iowa agency dedicated to the
integration of telecommunications and technology into education and public services
within Iowa.  The ICN owns and operates an advanced fiber optic network, that serves
citizens of the state of Iowa through the provision of deeply discounted
telecommunications services to educational facilities, including K-12 schools, entities of
higher education and libraries, public sector agencies of the state and federal
governments, and urban and rural health care providers throughout the state of Iowa.  The
ICN has operated since 1992, and offers comments based on its experience gained in
serving designated advanced communications needs in Iowa, which mirror exactly the
uses targeted by Section 254 of the Telecommunications Act of 1996.

Our portfolio of services includes full motion interactive video, high speed data transport,
Internet services, and standard equal access voice services.  Additionally, the Code of
Iowa requires equal access to all users throughout the state of Iowa, at equal costs.  
Currently, the ICN's rate structure offers video services at $5.00 per hour per site, for
educational usage, up to $40.00 per hour per site for health care usage.  These rates are
significantly lower than the charges for similar services offered by private sector
telecommunications providers.  The video rates charged to users of the ICN are based on
14 ongoing operational costs only."

The ICN asks recognition of its experiences in providing discounted advanced
telecommunications services to schools, libraries, and health care providers.  We offer
comments on: (1) the scope and definition of telecommunications carriers; (2) the
composition of universal services for schools, libraries, and health care providers; and (3)
the administration of the fund.

SCHOOLS.  LIBRARIES, AND RURAL HEALTH CARE PROVIDERS

The major point the ICN would like to impress upon the Commission as it considers rules
to implement the universal service fund portion of the Telecommunications Act of 1996
is that the ICN is a leader in the provision of discounted advanced telecommunications
services to schools, libraries, and health care providers.  Our charter is dedicated to the
same principles targeted by Section 254.  Accordingly, we feel that the Commission
should adopt rules broadly enough to include, in the definition of "telecommunications
carrier , those non-traditional special purpose carriers, such as the ICN. that have been
created as public institutions to achieve purposes in harmony with those of the
Telecommunications Act of 1996.  Allowing for the inclusion of those entities, such as
the ICN, in the definition of a telecommunications carrier will allow for those special
purpose carriers to be treated like all other telecommunications carriers, and will make
each of those entities eligible for reimbursement under Section 254(h)(B)(11).

The second point that the ICN would like to impress upon the Commission as it considers
rules to define universal services is that this definition should include certain advanced
telecommunications services that are fundamental to educators and health care providers
in the state of Iowa.  Through the ICN, Iowa has embarked on a plan to offer advanced
telecommunications services to facilitate distance leaming and coordinated Internet
services to all school districts in the state by the year 1999.  Currently, there are nearly
300 full motion interactive video classrooms, located in all 99 counties of the State.  By
June of the year 1999, it is expected that the number of classrooms will expand to over
700.  The ICN also has a number of urban and rural health care providers utilizing
advanced telecommunications services throughout the state, including full motion
interactive video services and high speed compressed video services.  These services are
being deployed by health care providers in the field of patient consultations, diagnostic
services, residency training, nurses training , etc.  In order for these uses to continue to
grow in the state of Iowa, the ICN would like to urge the Commission to define universal
services as: advanced telecommunications services, to include symmetrical facilities for
full motion interactive video, high speed data transport, Internet services, and standard
equal access voice services.  Furthermore, it is the ICN's position that the Commission
should adopt rules that will encourage single transport solutions.

Paragraph 81 of the Notice requested comment on the use of wireless technologies as a
method of providing more efficient service delivery.  With respect to this inquiry, it has
been the ICN's experience that wireless technology offers difficulties in both the ability
to equip advanced services with multiple channels, and also, in the ability to acquire
frequency licensing in some areas.  Because of the difficulties inherent in wireless
technology, the ICN does not support this delivery mechanism.  Accordingly, the ICN
requests that the Commission adopt rules that discourage wireless technology as a
delivery platform.


ADMINISTRATION OF THE FUND

The ICN supports a single non-governmental fund administrator to facilitate the
administration of the universal service fund.  The point the ICN would like to impress
upon the Commission, however, is that the selected fund administrator should have equal
representation of all telecommunications providers, including local exchange carriers and
limited access (special purpose) carriers.  It is imperative to have board representation
and/or affiliation with all telecommunications carriers, as defined by the Commission
pursuant to the Telecommunications Act of 1996.  Such representation will offer the
means by which the fund administrator can operate in an efficient,  fair,  and  competitively neutral manner.

CONCLUSION

Telecommunications  carriers,  such  as  the  ICN,  to  be  considered   telecommunications
carriers eligible to receive reimbursement under Section 254 (h)(B)(ii); (2) a broad
definition of universal services to include single transport, symmetrical facilities for the
transmission of full motion interactive video services, high speed data transport, Internet
services and standard equal access voice services; and (3) a single nongovernmental fund
administrator that is neutral in its affiliations.

Respectfully submitted,