TO: Office of the Secretary, Federal Communications Commission

FROM: Dr. Stanley Gardner, Missouri State Library
Barbara Reading, Missouri State Library

DATE: April 3, 1996

RE: FCC request for comment and response to "Notice of proposed Rulemaking"

In response to your request for comments on the "Notice of Proposed Rulemaking..." dated March 8, 1996, the Missouri State Library submits responses specifically to the following.

On page five, item four, you request "comments on how each of the seven principles enunciated in Section 254(b) should influence our policies on universal service." On page thirty-six, item 73 specifies that the FCC seeks "to identify the services to be supported..." On page thirty-eight, item 78 you "seek comment ~ on the additional services..." and in item 80 you "seek comment on what functionalities should be supported..."

High bandwidth: The Missouri State Library is in the process of bringing up on online database of the holdings of Missouri libraries, to facilitate resource sharing. In addition, some libraries will use the system as their automation system, to circulate materials. These libraries will use the Internet for their connection to our central system. Both libraries to be involved in our pilot project have several branches which will use the Internet for their communications system for this process.

Distance learning is a critical issue as adult workers are faced with the need for training and retraining in all areas of the state. Missouri's geography and road system makes it difficult for adult workers to get to campuses, even for evening classes. Institutions of Higher Education are developing more distance learning packages, but public libraries need the capability to act as access points for distance learning, as they reach into many more communities than have 2 or 4 year college campuses.

Both the access to and the cost of teleconferencing is an issue. Currently, any face-to-face meeting of committees may require a drive of up to 6 hours each way; access to teleconferencing will have to reach into rural and smaller communities to enable statewide committees to use it as an alternative. E-mail and fax are used extensively to distribute information, but are not always effective substitutes for face-to-face discussion.

In Missouri, local taxes provide 98% of library support. Funding for ongoing telecommunications costs would need to come from increased voted levies or shifting funds from other areas of libraries' budgets. State initiatives have been used to build the telecommunications infrastructure, with local libraries paying for internal lines, equipment, and ongoing costs. The average rural Missouri library operates with an annual budget of less than $50,000. State money has also been used to provide some services, such as access to a large magazine database. However, state money is unlikely to be available for ongoing costs or add-on services.

Wireless technologies would be of benefit in the many older school and public library buildings, and where current wiring cannot handle digital transfer. Some schools with several buildings are looking to wireless connections as an economical alternative.

Frequency of review - Should be based on functionalities, and technology development, as this area is moving too fast to tie it to a specific projected time frame. Access to teleconferencing and distance learning are critical for economic development.

The Missouri Public Service Commission has regulations in place stating allowable uses of state telecommunications lines. These regulations clearly preclude use of the lines for commercial purposes, or reselling of telecommunications services. MORENET, or the Missouri Research Educational Network, is contracted by state government to supply telecommunications services, i.e., Internet, to schools, academic institutions, government agencies, and public libraries.

Examples of places where users are accessing library catalogs, Web services, and other online services via modem: (All sites listed are in Missouri)

Daniel Boone Regional Library, 3 counties in central Missouri: - COIN, Columbia Information Network: http://www.coin.missour.edu/library/dbrl/index.html.

Springfield-Greene County Library - ORION, Ozark Regional Information Online Network: http://www.orion.org/library/sgcl/

Kinderhook Regional Library, 3 counties, LLION, the Lebanon-Laclede Information Online Network. Http://llion.org.

St. Charles City-County Library District, WIN - Westplex Information Network, Http://www.win.org.

St. Louis City - Enterprise Zone Community Network - Http://www.st-louis.mo.us/st-louis.city.

Henry County Library, TACNET, Truman Area Community Information Network, http://hclib.hcl.lib.mo.us.

Northwestern Missouri - RAIN, http://vax2.rain.gen.mo.us

Kansas City - Community Information Network - Magic at Http://www.sunflower.org/magic.html.

City of Rolla - RollaNet at Http://www.rollanet.org.

Riverside Regional Library - 3 counties - http://www.showme.net/~rrl/

In addition to the libraries listed above, there are 30 libraries with dedicated Internet connections and 30 with dial-up connections. Generally, the libraries with dedicated connections provide patron access, while the dial-up libraries use staff to access services in response to reference questions from patrons. Dedicated connections require a LAN with 5 computers.

The policy of (1)Quality and Rates are a very important issue in Missouri. There are several cities sharing common borders with other states, and the impact of interstate phone rates will affect the services libraries and educational institutions can share. In addition to the cities, there are regions of the state where the economical center is not in the state. An example of this is Joplin Missouri. It provides an economic center for both Northeastern Oklahoma and Southeastern Kansas.

There is a very large number of libraries in Missouri that use the Online Computer Library Center (OCLC) in Ohio for bibliographic services, Inter-library Loan services, and reference database services. Following the suggestion listed in item 113 on page 51, a flat rate cost for advanced interstate telecommunications would be the most effective way to provide access to advanced services. This is listed as (2) Access to advanced Services on page 4.

A flat rate charge would also meet several other of the Commission's base policies including: (3) Access in Rural and High Cost Areas, (4) Equitable and Nondiscriminatory Contributions, (5) Specific and Predictable Support Mechanisms, and (6) Access to Advanced Telecommunications Services for Schools, Health Care, and Libraries. Libraries budgets are never large enough to cover all the demands placed upon them by the public. The predictability of a flat rate in telecommunications cost will mean that libraries will be able to budget for and encourage the usage of advance telecommunications for digital transmission of the community through the libraries and educational institutions.

In Missouri the Universal service concept follows that of item 115 on page 52, where a common fund is established to support rural areas and areas where it is not economical for telecommunications carriers to compete due to a lack of customers or the high cost of establishing or maintaining the infrastructure necessary to offer service. If the FCC would encourage this concept in areas that are not highly profitable to telecommunication companies, it would be a useful assist to the states that are pursuing this path.

To recapitulate, in Missouri telecommunications for libraries are used to:

Provide requests for materials for interlibrary loan services between libraries;

Access the Internet;

Access state government information;

Access local government information;

Access a statewide bibliographic database of holdings of all libraries in Missouri;

Connect via the Internet library automation systems for circulation, public access catalogs, serials holdings, and other library functions;

Connect to a statewide full text magazine database through all academic, school, and public libraries; and

Communications via e-mail between teachers, faculty, librarians, and administrators of schools, libraries, and state agencies.

The availability of digital telecommunications services at an affordable price are a matter of extreme importance for Missouri libraries. The ability to provide services mandated by state law, and the expressed needs of the local citizenry depend on the availability of access to digital telecommunications.