Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 2OS54

In the Matter of
Federal-State Joint Board on CC Docket No. 96-45
Universal Service

COMMENTS OF ALLIANCE FOR PUBLIC TECHNOLOGY

SUMMARY

The Alliance for Public Technology, a coalition of 105 public interest organizations ands more then 200 individuals, comments to the Commission and the Joint Board on the questions raised in its Notice of Proposed Rulemaking to implement the universal service provision of the Telecommunications Act of 1996.

APT's vision of universal access to advanced telecommunication services at the earliest possible time is the focus of these comments. Section 706 of the Act endorses the APT vision of advanced universal service, borrowing language directly from APT policy papers, describing it "without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality, voice, data, graphics, and video telecommunications using any technology."

APT urges the Commission and the Joint Board to measure all proposals for universal service against whether they will speed the day when there is widespread deployment and use of advanced telecommunications services. We urge them to establish a path for migration from the more limited definition of a telephone based universal service to advanced universal service.

Our comments also endorse a funding mechanism that is fair and equitable, but we point out the Act's mandate that funding for universal service be from carriers. Thus, we encourage the Commission to focus on collection and administration methods that result in contributions by all carriers to universal service obligations. It should be left up to carriers, once there is effective local competition, on how to recoup their costs from their customers.

Finally, APT believes that Section 706 of the Act, which authorizes the Commission and the States to utilize regulatory and deregulatory mechanisms to incent the deployment of advanced infrastructure and services applies to the instant proceeding. Specifically, the Commission would be authorized under Section 706 to develop regulatory incentives in this proceeding to encourage more rapid deployment of advanced telecommunication services.

I. Introduction

The Alliance for Public Technology (APT) [1], is a Washington, DC based nonprofit, tax-exempt coalition of public interest groups with diverse grassroots membership and of individuals that is concerned with promoting policies that foster a maximum contribution by the telecommunications and information services to the quality of life of all Americans, especially in fields like education, health care, and democratic processes. The Alliance therefore fully agrees with the Commission on the great importance of this proceeding and others to follow in this area. In that respect, we call the Commission's attention to the APT's declaration of principles, Connecting Each to All, and to its implementing proposals contained in Principles to Implement: the Goal of Advanced Universal Service. Both documents have previously been supplied to the Commission in other proceedings. [2] We believe strongly that APT’S principles, particularly those related to the universal deployment of an advanced telecommunications

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1 The Alliance was founded in 1988 and now has over 325 members, including 105 organizational members.

2 A courtesy copy is being supplied under separate cover to the Commission and members of the Joint Board. Copies of the reports are available to the public from the Alliance for Public Technology, PO Box 28578, Washington, DC 20038-8S78.

infrastructure and network, are most pertinent to the Commission's task in this proceeding.

We shall focus here on four facets -- the concept of universal service; the appropriate recipients of universal service subsidies; the administration of the concept in the new "pro-competitive, deregulatory environment," [3] and the Snowe-Rockefeller provisions dealing with schools, libraries, and rural health providers.

II. The Concept of Universal Service

The Alliance has articulated a vision for this country of universal access by every American to an advanced telecommunications system and its services at reasonable rates. our vision closely parallels the definition of advanced telecommunication services contained in Section 706 of the Act, to be "without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality, voice, data, graphics, and video telecommunications using any technology.”[4] We urge the Commission and the Joint Board to embrace this vision and evaluate each proposal

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3 Notice of Proposed Rulemaking and Order Establishing Joint Board, FCC 96 -93, released March 8, 1996, at par. 30 (herein Notice).

4 APT particularly applauds the critical element in this definition that users must be able to originate as well as receive so that the future does not entail large commercial companies simply dumping on a one-way basis vast quantities of entertainment, shopping channels, etc. on consumers with no capability for two-way symmetrical transmission of high speed data-- so essential for the delivery of educational, health care, public information transactional and telecommuting services.

and rule against the standard of whether and to what degree it will promote the rapid deployment of such a nationwide and worldwide advanced telecommunication system.

We recognize that the goal of universal advanced telecommunications to every home at affordable rates cannot be fully and instantly implemented today. The concept of universal service -- as Congress has recognized -- is an evolving one, and necessarily so in light of the dynamic technology, market and societal needs as Section 254(c) has laid down.

We believe that the structure of the new Act, including the requirement in Section 254 (b) (3) , the policy contained in Section 706, and the mandate to deploy advanced services to schools, libraries and health care facilities, dictates that the Commission and Joint Board map out a strategy and migration path from the immediate, limited telephone based universal services suggested in the Notice, to the time when the advanced network and services envisioned by Section 254 (b) (3) and Section 706 are universally deployed.

We urge the Commission and the Joint Board to address how universal service mechanisms can be directed to foster these goals and to implement a strategy for accelerating deployment of advanced telecommunications services. We believe such an approach is consistent with 2S4(b) (3) and also can be justified as a "regulatory mechanism designed to remove barriers to infrastructure development." (Section 706).[5]

The dilemma is patent -- how can a service or functionality meet principles ii and iii -- widespread availability and adoption -- unless the network itself is capable of supporting the service. We fear that a minimalist definition of universal service will not provide sufficient incentives for infrastructure investment necessary

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5 Section 706 does not leave the matter to the general public interest standard. It is explicit: The Commission and each State " ... shall encourage the deployment on a reasonable and timely basis of advanced telecommunications capability to all Americans (including, in particular, elementary and secondary schools and classrooms) by utilizing, in a manner consistent with the public interest ... price cap regulation, regulatory forbearance, measures that promote competition in the local telecommunications market, or other regulating methods that remove barriers to infrastructure investment." The Commission is directed to institute an inquiry within 30 months to determine whether such advanced capability is being deployed in a reasonable and timely fashion, and if it finds that it is not, to take immediate action to accelerate such deployment by removing barriers to infrastructure investment and promoting competition. But our point here is that the Section 706 process includes the instant universal service proceeding.

to foster the rapid development and deployment of advanced networks and services.[6]

If the Commission and the states do not act now to reasonably promote investment in advanced telecommunication infrastructure, such advanced services will not be timely available to be chosen by a majority of consumers, and thus will not become timely available to all Americans under the universal service concept. We recognize that the Commission and states have great discretion in how they proceed to meet this vital responsibility under the Act. But the Act does settle some issues that have long been in dispute. Some consumer groups have stressed that with declining costs because of dynamic technology, the sole emphasis should be on corresponding declining rates for consumers. While we are concerned that consumers not pay unfair or unreasonable rates, rates emphatically are not the sole consideration: If, for example, price cap regulation can be utilized to accelerate advanced telecommunication investment, that also is a

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6 See Sec. 254(c). We, therefore, are concerned that the definition in that section may not be adequate: In deciding the telecommunication services to be supported by federal support mechanisms, consideration is to be given to the extent to which such services are (i) essential to education, public health, or public safety; (ii) have, through the operation of market choices by customers, been subscribed to by a substantial majority of residential customers; (iii) are being deployed in public telecommunications networks; and (iv) are consistent with the public interest. We believe that an additional consideration should include whether the service or functionality is or will be necessary for access to advanced services.

most important contribution to the public interest, and must be taken into account by the policy makers.[7] We believe the 1996 Act settled the dispute, and in a manner markedly favorable to the APT position. And we specifically urge that the Commission and the states move to implement this facet of the Act now, beginning with this proceeding. It would be most unsound not to take immediate action and to postpone action until some time three or more years from now. It is a truism, but worthy of noting, that for every year wasted, the opportunities lost are irretrievable.

This need can be pointed up by consideration of the role of advanced telecommunications in the education, health care, civic information and telecommuting fields if our nation is not to be irrevocably divided into information haves and have nots, and significant segments of our population deprived of the ability to participate in critical elements of our society.

There is a national consensus about the importance of educating for the high tech future, so that the current income disparities in our society are not exacerbated. Access to health care is an equally .critical concern for citizens particularly those without insurance or in the lower income brackets. Participation in the democratic process

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7 So also the Commission must be alert to promote advanced infrastructure investment by the cable television industry during the three year period when a substantial portion of that industry remains subject to rate regulation.

must obviously be as accessible for disadvantaged and lower income citizens as it is today for the upper income technically sophisticated citizens. It must also be available to all citizens regardless of income and not simply to citizens lucky enough to live in communities with an advanced telecommunication network infrastructure. As telecommuting involving video connections between home based workers and their supervisors, peers and subordinates in the office and home setting grows, access to jobs will increasingly require access to advanced telecommunications services in the home. If all citizens do not have access to these services because their communities are not wired up, we will have created one more insuperable barrier for citizens to participate in main stream society. That is one of the main reasons why the 1996 Act places such emphasis on the availability of advanced telecommunication and information services for schools and libraries (e.g., Internet access). See Sections 254(h), 706. Thus, the Commission can designate "a separate definition of universal service applicable only to public institutional telecommunications users" (Notice, par. 11); section 254(h) (1) contemplates federal support mechanisms to make available services additional to the "core" ones already described, and section 254 (h) (2) directs the Commission to adopt competitively neutral rules to enhance school and library access to advanced telecommunication and information services to the extent technically feasible and economically reasonable.

This means that it is much in the national interest to have the universal service support mechanism kick in for advanced services as soon as feasible. For this to happen under the Act, advanced telecommunication services must be widely promoted by the Commission and the states, so that they will be widely available and taken by consumers. So once again regulatory policies that promote infrastructure investment are crucial to the universal service concept and the national interest.

It is clear, therefore, that universal service mechanism must be developed to respond to the evolving telecommunication network infrastructure as it is gradually deployed. Today, telecommunications services have already significantly embraced high speed data and graphics and have started to embrace video. Demand for higher speed communications is beginning to mount. Since deployment of this evolving infrastructure will be uneven from community to community and region to region, it is essential that the Commission and Joint Board not create static mechanisms on a one size fits all basis.

It is also likely that in the advanced telecommunication world there will not be a widespread demand for one set of "basic services."[8] Rather different demands for services of critical public interest and significance will be generated by different segments of the population at different times in their lives. A crude example of this changing demand might involve demands by families with children for educational services, by working families for telecommuting and by retirees and families with aging realities for electronic delivery of health care services to the home. Thus, basic services in the advanced telecommunication world will probably embrace a series of basic public service packages from which families can choose the basic package they want. This package will probably be a mixture of bandwidths geared to different usage's which these various applications may require.

The Commission and the Joint Board must be careful to design its universal service mechanisms to create incentives for advanced telecommunication network deployment and develop flexible mechanisms which can be adapted as advanced networks and technologies are deployed.

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8 Indeed, these "services" may simply be a bundle of bits and bytes with various kinds of instructions or capabilities built in. (See, e.g., Nicholas Negroponte, being digital (Vintage Books, 1995)) The line between communications and content are also going to blur.

III. The Appropriate Targets for universal Service

APT thus stresses that all Americans should be the beneficiaries of government policies that promote the infrastructure investment to bring them advanced telecommunication services as soon as feasible. See Section 706; above discussion. The issue here is that whatever the level of basic universal service may be at a particular time (in light of the four criteria), how the universal service subsidies will be made explicit and disbursed in a way consistent with the Act and a competitive telecommunication industry.

The Act (Section 254(b)(3),(h)) explicitly identifies three groups -- (1) low income consumers; (2) consumers in rural, insular, and high cost areas; and (3) rural public or nonprofit health providers, elementary and secondary schools, and public libraries. We discuss (3) in Point V, infra.[9]

As to (1) , there is full agreement as to the need to extend basic universal service support to low income consumers and, indeed, to do a much better job in this respect. The Commission has determined that subscribership levels for low income persons fall

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9 We also do not treat here the implementation of Section 255 concerning access by persons with disabilities. Implementation of those provisions will be dealt with in other proceedings. Many of APT member organizations are groups advocating for people with disabilities. Section 254 and universal service mandates should be viewed with respect to all consumers, including those people with disabilities.

substantially below the national average; [10] thus, 31% of all families on food stamps have no telephone, and telephone penetration for women with children living at or below the poverty line is about 50%. The Commission has noted some of the problems leading to these depressing figures and we fully support the suggested efforts to deal with these problems.

This brings us to the second group, support for consumers in rural, insular and high cost areas. We certainly join in recognizing the obvious desirability of extending universal service support to those in rural or high cost areas that are in need of such support. When universal service support is viewed strictly from the perspective of how much any one individual is "subsidized" to receive a particular set of services, there is a perception of unfairness when support goes to the very affluent in ski resorts like Aspen and Vail, to rich ranchers or casino owners, and to many others in not the slightest need of a subsidy, as well as to low and middle income residents. That is why an infrastructure investment perspective on universal service may be a more appropriate view, providing financial incentives to encourage the deployment of technology in a way to assure these communities have access to advanced services. Initially, the Commission and Joint Board should examine the extent

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10 See Subscribership Notice, at 13003-04.

to which elimination of artificial barriers to new entrants, particularly the interlata restrictions, may enable more efficient and affordable deployment of technology to these areas. The Commission and Joint Board should also examine opportunities to foster the development of multi-state regulatory experiments and compacts as a means of fostering innovative solutions to delivery of advanced services through more efficient mechanisms than have existed prior to the Act.

The Commission is aware of the problems and, as shown in the discussion in the Notice, pars. 27-40, is seeking new ways that might better comport with Congress' intent "to provide for a pro- competitive, de-regulatory national policy framework... opening all telecommunications markets to competition" (par. 30) We encourage the Commission to explore carefully avenues like the proxy models and distributing high-cost assistance on the basis of competitive bids. We also support the notion that any plan here should be technology neutral (par.32), in light of the great promise of wireless to eventually alleviate problems in the high cost areas.

APT's position is simply stated: It favors most utilizing Section 706 incentives for carriers to provide the most advanced network and services to all areas of the country. We believe that universal service subsidies and recovery mechanisms can qualify as a Section 706 incentive. To do so will lower the cost of providing services, ultimately minimizing the cost of traditional universal service mechanisms, such as life line and link-up.

APT recognizes the requirement of the Act to make subsidies explicit. We believe, however, that the Act envisions that these subsidies be contributed by "carriers". The Commission should consider the use of systems (such a the "NeTrans" fee proposed by Eli Noam) that assure that all carriers contribute to the cost of universal services. once there is local competition, then the Commission should permit carriers to decide how best to recover local loop and other costs from their customers. Some may elect to utilize a flat, subscriber line like fee, while others may average the cost in the price of their services and others still might develop volume discount systems or other innovative pricing schemes.

It seems clear that it will be decades before facilities based local competition reaches and benefits residential consumers. Competitors will of necessity resell local loops under discounted prices. These prices should be the source of recovery of explicit subsidy amounts. A number of different means of recovery have been proposed. One plan, proposed by NYNEX, does not rely on a usage sensitive element, but instead is a flat fee per line ordered by IXCS. APT strongly believes that all of those competitors who use the public network must contribute to the cost of providing universal service. Similarly, to the extent these competitors themselves become eligible carriers, they should be entitled to receive the subsidies."[11]

IV. Administration in the New Competitive Era

As indicated above and in APT's policy papers, we support a system that ensures that carriers' contributions to fund universal service support are collected "on an equitable and nondiscriminatory basis" using "specific, predictable, and sufficient mechanisms" (par. 118) (e.g., TRS (par. 122) or contributions based on revenues net of payments to other carriers (par. 123).

We touch only briefly on this topic to raise a matter germane to the states rather than the basic federal universal service support system. The 1996 Act (Section 254(f)) permits the states to preserve and advance universal service so long as the state pays its own way and does not conflict with the federal system or rules. We believe that the states can play a most important role in this field.

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11 APT is concerned that universal service policies not promote the continuation of uneconomic business enterprises such as very small telephone companies. Small phone companies serving very small populations do not enjoy the economies of scope and scale inherent in larger telecommunications networks. Federal policies that encourage the maintenance of these uneconomic entities do not serve to incent widespread deployment of advanced network infrastructure.

Experience shows that many States have been leaders in advancing universal systems, and have admirably fulfilled their role as laboratories by blazing new trails for others to follow (e.g., inclusion of touch-tone in universal service support) We strongly hope that they play a leading role in promoting the earliest possible use of advanced telecommunication and information services by, for example, formulating a process for aggregating demand through use of community based centers in libraries, schools and other suitable places (see discussion, infra, at page 17)

Some states have also been most innovative in the administration of their universal service undertakings. Thus, Maryland, like most states, imposes a gross receipts tax on all telecommunication carriers, and it simply permits a carrier that affords a designated universal service package to a qualified low income consumer (i.e., on welfare) to deduct that amount from the sum remitted to the state treasury. This not only fits the competitively neutral requirement, is available to all carriers, but most important, comes from the general treasury and thus promotes the fullest and most efficient use of telecommunications services. We believe that the Commission and Joint Board, in addition to their very important assigned tasks, can also act as a clearinghouse for innovative techniques that might be employed on the state level.

V. The Snowe-Rockefeller provisions,

As we have already stated, these provisions are of great importance because of the critical relationship of education to the future of our nation. In acting here, the Commission must take into account not only the issues raised in Part IV of the Notice but the desirability of surveying this requirement in the context of national and statewide educational reform efforts.

A. Education

While we would expect the Commission to rely most heavily on the comments of schools, libraries and health care providers in crafting its rules, APT would like to comment on at several points in the context of Snowe-Rockefeller. First, Federal policies designed to accelerate educational access to and uses of the NII through electronic linkages or "on/off ramps" to schools and libraries should reflect the diverse needs of states and local communities. No one technology or type of electronic service can address adequately the complex and emerging needs of schools and libraries Incentives in the form of regulatory incentives and waivers could stimulate states and local municipalities to demand and negotiate services with the competitive providers they know and trust. Federal telecommunications policies should be changed and implemented in tandem with other federal regulatory and spending policies. Schools and libraries should be given the discretion to use and co-mingle multiple categorical grant allocations to extend educational and informational services electronically. Enabling schools and libraries to communicate and share services directly with families and households may have a far greater impact on education than goals and strategies limited to a nation of wired classrooms. In the immediate future, wireless services may offer a practical alternative to schools and libraries, particularly those servicing low-income urban neighborhoods.

B. Community Base Organizations and Snowe-Rockefeller

There is the clear desirability of using schools and libraries as the base for community-based technology application assistance centers. We have attached as an appendix an example of the great worth and the process for such centers in California.

While the statute provides definitions of eligible health care, educational institutions and libraries, APT urges the Commission to clarify that eligible institutions may partner with community based organizations and still be eligible to receive discounted services. While a non-profit, community based organization (e.g., a local chapters of La Raza, or LULAC or NAACP) might not itself be eligible for the discounts for advanced services, they may well be partners with eligible institutions in the delivery of health services or providing educational opportunities to the community. In those circumstances, the participation of the community based organization ought not to result in disqualification of a project. Indeed, many eligible institutions may need to partner with community base organizations to accomplish their own objectives. They test ought to be that an eligible organization is order the services for a qualifying purpose.

C. Aggregation of Demand

The goal of providing access to advanced telecommunication services to schools, libraries and health centers as a means of meeting universal service needs and to foster the broader availability of these services is laudable. The Notice anticipates that by deploying advanced services to these favored institutions, the public may become more familiar and adoption rates increase. APT has stated in its principles the following:

A federal commitment to an advanced universal service goal must give a clear mandate to state and local governments to develop even-handed incentives for competitors to aggregate demand for community-based applications of advanced telecommunications technology (i.e. education, health care, labor market operations, and the needs for the disability community.)

Snowe-Rockefeller provisions of the Act provide an important opportunity to create these incentives. APT agrees that, in a competitive environment for modernizing telecommunications networks and services, public policy must give the marketplace a major role in deciding which advanced services are essential for participation in society. But it must not be an unfettered role.

We embrace the marketplace because of its unmatched capacity to develop and deploy advanced technologies that are critical to the nation's future. But it has limitations. It works best through investment strategies that are guided by the "effective demand" perceived to be exploitable in a market sense. The fundamental challenge in extending universal service to include advanced technology applications is to find market-compatible ways of overcoming the implicit "social engineering" of the marketplace in developing and deploying new technologies.

APT's principles stated above embraces all the aspects of the Snowe-Rockefeller focus on community applications, but it does so in a broader context of building community support behind the aggregation of demand for technology applications which both address community priorities and bring advanced applications within the reach of a broader spectrum of the society.

We believe that as the Commission and Joint Board develop support mechanisms to encourage advance universal services, it should include a specific financial incentive to the States to open proceedings which are focused on developing strategies and market- oriented options which are designed specifically to facilitate competitive deployment of advanced services to the full spectrum of individual and community-based needs. In the context of the current proceeding, the Snowe-Rockefeller provisions provide the best avenue for achieving this mandate.[12]

VI. CONCLUSION

APT applauds the Commission's prompt and serious effort to rapidly implement the universal service provisions of the Telecommunications Act of 1996. APT urges the Commission and the Joint Board to keep in mind the ultimate goal of universal service to advanced telecommunications technologies and services -- a switched broadband network to every home in America at reasonable and affordable rates capable of high quality voice, data and video communication into and out of the home.

While advanced services may not be widely deployed today, the Commission and Joint Board should be carefully crafting their rules to incent carriers to provide the functionality and technology as

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12 Similar mandates should be developed in the implementation of Section 706.

rapidly as possible, eliminate barriers to infrastructure investment and set the stage for the day when many of these services will in fact be widely available and subscribed to by a majority of consumers.

Respectfully Submitted
Alliance for Public Technology

Chairwoman

Mary Gardiner Jones
President

Of Counsel:
Henry Geller
Samuel A. Simon

901 15th St. Suite 230
Washington, DC 20005
(202)408-1400

April 12, 1996

Subcommittee =3 of California Education Technology Task Force (CETTF) --Draft Suggestion for Recommendations on items referred to me by Subcommittee, D. Vial

Draft Suggestion under 2.0--Technical Assistance

2.6--Establish community-based Technology Application Assistance Center-, as forums for discussion- and a locus for information and -software applications- and response centers to meet the needs of different groups

The restructuring and regionalization of technology- leadership services under CTAP, as initiated by the Superintendent of Public Instruction, provide a solid framework for breathing life into many of the recommendations advanced in this and other sections of the Task Force's report. What needs reinforcement in the Superintendent's restructuring is how the development of effective demand for applications of the new technologies is to be fostered, as well as supported, by the technical assistance services that are to be organized and provided through the ten CTAP Regional Councils. Building and aggregating effective demand (what drives the allocation of telecommunications resources in a competitive, market environment) for deploying advanced technologies in our financially-strapped schools is essentially a community-based undertaking that transcends the more immediate interests of educators responsible for school performance. There is an inexorable link between the development and deployment of advance telecommunications technologies in our schools and the broader societal purposes of an advanced communications system.

AB 3643 (Ch 278, Stats. 1994) mandates that education, along with health care and other community and government institutions, be "early- recipients of the benefits of the information age" This mandate is now embraced in national policy under the "Snow-Rockefeller" provisions of newly- enacted federal telecommunications legislation. Within the federal/state framework established for advancing universal service goals and objectives, schools and classrooms, heath care providers, and libraries are to have access to both basic and advanced telecommunications services at discounted rates.

The priority reflected in the federal and state mandates is a clear recognition of the integrative, community-building potential of advanced telecommunications technologies. Education is at the top of the list -- everybody’s list -- because an accessible, effective education system is the most powerful integrative force in the society, working to mitigate and to overcome societal tendencies toward economic and social polarization.

For this reason among others, technology in the schools must not be elevated in status or viewed as an end in itself. Fundamentally, the priority we give it is a sober recognition that technology applications which enhance the effectiveness of education --especially in opening up of new educational vistas for children and families having to overcome largely negative educational environments in their homes and communities-- also advances the integrative, community-building potential of a technologically advanced telecommunications system. In this respect, the Superintendent's new framework for the regionalization of technical services opens the door to full community participation in how technology in the schools is to advance the historic mission of our public school system.

The Task Force believes the mission of the ten CTAP regional councils needs to be buttressed by fostering within each region the development of community-based technology applications centers (CTACS) which have applied access to state-of-art telecommunications technologies, Structurally, within the frame work of CTAP, the CTACs would:

In the same vein, we cannot expect parents who have little or no opportunity to understand, work with, or benefit from new information technologies to give priority to technology in the schools when their main problems may be keeping food on the table, their children healthy and the drug pushers at bay. What many teachers, administrators and families require in common are meaningful opportunities to understand and experience the capabilities of the technologies in addressing educational needs from their respective perspectives. For many families living on the edge of society telecommunication technologies have educational values which transcend internalized applications that are school-focused to the exclusion of other community-based applications.

In short, teachers, administrators, parents and others with a community interest in education and related technology applications having high social and community value need to be provided with opportunities through the CTACs to (a) gain "hands-on" experience with the educational potential of advanced technology applications, (b) identify applications which they value and which will assist them in carrying out their respective educational responsibilities, and (c) participate in cooperative, community-based efforts to aggregate effective demand to develop and deploy the advanced technologies, cutting across the established domains of community-based applications.

In a competitive environment for interactive, multi- media communications, the mission of the CTACs should be viewed as competitively neutral market-building for telecommunications products and services. The Task Force anticipates that competitive providers of products and services will be eager to provide access to technologies for "hands-on" experiences with applications determined to be valuable by- participants in the programs and projects of the CTACS. Development of the Centers, their design and structure to meet local needs, largely paralleling the organization of technical assistance, should be left in the hands of the ten Regional CTAP Councils and their Coordinating Councils.

While there are many reasons why it is important for the CTACs to reach out to involve community groups and institutions in the areas in which they serve, foremost is the role communities play in determining the importance and value of technological innovation in our educational system.

In a public education system, the value of technology is rooted in the way applications mesh with the education function in society to enhance learning, individual opportunities, and the quality of community life. Standards for technology training and deployment are critical elements of a technical assistance program, but the ultimate value of technology is established in the process of its development and deployment by those who experience its usefulness.

In this respect, the utilization of technology to address educational objectives is a value-added process that demands a closer link of schools and community, as indicated throughout this report. Financial support for technology in the schools is not likely to exceed the value communities see in integrating advanced technology throughout the education process. One way and perhaps the best way, to provide for the underpinning of financial support of technology application in education is to involve the community more effectively in determining how technology can enhance the quality of education, and to do so cost effectively.

The CTACs are intended to help build a broader base of community involvement in the development and deployment of technology applications in education. To the extent that they do so effectively, technology may also become a vehicle for bridging the gap in community support that has sanctioned the across underfunding of our public education system.

4.4 Establish communication links between home/school

Implicit in the Task Force's recommendation to buttress the CTAP's restructuring of technology assistance by establishing functioning CTACs is the priority to be given to using advanced telecommunications technologies to develop effective communication links between home and school.

In many communities, especially in poverty-ridden areas of central cities, meaningful communication links do not exist. Further, declining incomes of wage-earner families over the past two decades, requiring more spouses to enter the labor market, is exacerbating home/school communication problems over a broad spectrum of the society. There is an urgent need to develop new was of establishing communication linkages which are compatible with the changing structure of both employment and the State's work force.

Using the CTACs to address these communications issues will go a long way toward developing a broader understanding of the capacity to telecommunications technologies to address pressing problems which are education-related. It is this kind of focused, largely community-based development of technology applications, that will build broad-based support for deploying the advanced technologies throughout the education system to enhance the quality of education cost-effectively.

Even more fundamentally, a focus on home-'school communications will bring into sharper perspective major equity issues limiting the educational use of the new technologies were compatibility of home and school learning environment is necessary. Environments that are lacking in the home and communities cannot be left to market forces to be overcome. The CTACS, having a market-building function, are needed to help identify public policy options for meshing home and school learning environments that will garner broad community support.

Telecommunications and Technical infrastructure Section: 4.7 Use CTAP for assistance in establishing requirements, for implementation. for training.

In the restructuring of technical assistance under CTAP, each of the regional centers will be in position to make recommendations affecting the development of telecommunication infrastructure and how it is to be utilized, including the adoption of training standards and the provision of training.

It is important to recognize that the development and deployment of infrastructure is to be driven by market forces under the competitive policies of the new federal telecommunications law enacted by Congress. While the mandate of the new national telecommunications law requiring providers to respond to requests of schools for services at reduced rates will be helpful, the new law does not give schools authority to require providers of telecommunications products and services to meet specific needs or standards that are not part of the services they are offering in the area.. What the CTAP Centers can and must do, utilizing the proposed CTACs where feasible, is to develop working relationships with providers that are applications-oriented so that competitors have a market incentive to make the infrastructural investments required by the schools. Competitors have to see the profitability down stream of investments in infrastrutural development and deployment before they will make them.

The interfacing of CTAP regional centers with competitive providers is the only way in which technical infrastructure requirements can be addressed effectively. Through their, technical assistance programs and projects, the Centers should have a working knowledge of how school districts are progressing with technology applications. In much the same way in which major corporations establish interfacing links to providers in developing technical infrastructure requirements for utilization of advanced technologies, the CTAP Centers need to assume responsibility for providing the interfacing linkages to the schools. As in relationships with the "high end" of markets for telecommunications products and services, "learning-by-doing" is an important mode of operation.

Across the board, "learning-by-doing" should be a driving force behind using technology in education.

4.9 State should explore the possibility of favorable telecommunications rate structures for schools and non-profits (tech centers, community-based centers) as state level group discounts.

Note This issue takes on new importance as a result of the enactment of federal telecommunications legislation containing the so-called Snow-Rockefeller Amendment, which targets schools, health care, and libraries for reduced rates within the framework of rather complex provisions for advancing "universal service" in a competitive environment. This requires careful review before a position should be staked out by the Task Force.

The Snow / Rockefeller amendment is complex because identification of the services and funding of reduced rates is to go through a federal-state joint board process called for by the legislation to implement universal service requirements. This will involve both the FCC and the State CPUC. But I am sure that the Legislature will want to be involved.

As I understand it, the reduced access rates apply to both basic and advanced services. The costs are to be internalized and requirements can be addressed effectively. Through their technical assistance programs and projects, the Centers should have a working knowledge of how school districts are progressing with technology applications. In much the same way in which major corporations establish interfacing links to providers in developing technical infrastructure requirements for utilization of advanced technologies, the CTAP Centers need to assume responsibility for providing the interfacing linkages to the schools. As in relationships with the "high end" of markets for telecommunications products and services, "learning-by-doing" is an important mode of operation.

Across the board, "learning-by-doing" should be a driving force behind using technology in education.