Federal Communications Commission
Attention: Federal-State Joint Board on Universal Services
(FCC-96-93)
CC Docket No. 96-45
1919 M Street N.W.
Washington DC 20554

Ladies and Gentlemen:

We are pleased to have the opportunity to comment on the Notice of Proposed Rule making for Section 254 of the Telecommunications Act. Our commentary follows:

I - Comment on NPRM Question No. 4 about how each of the seven principles enunciated in Section 254(b) should influence Board policies on universal service.

a. Seven Principles. Each of the seven principles address an important concern; and, collectively, they should serve as the basic criteria for judging whether Joint Board recommendations and/or Commission rules are appropriate. The following two principles are especially important as criteria for rules relating to school, classroom, and library access:

(1) Principle Five--SPECIFIC AND PREDICTABLE SUPPORT MECHANISMS. It is essential that educational programs and libraries operate in an environment where carefully planned efforts are sustainable over a minimal 3- to 5-year life cycle. Therefore, specificity in regard to available services, pricing, and support mechanisms for defined periods is essential.

(2) Principle Six--ACCESS TO ADVANCED TELECOMMUNICATIONS SERVICES FOR SCHOOLS, HEALTH CARE, AND LIBRARIES. This principle must be applied literally; and, in conjunction with Sections 254(c)(1)(A), 254(c)(3), 254(h)(1)(B), 254(h)(2)(A), and Section 706, should be interpreted as requiring rules to ensure that affordable telecommunications access is available equitably for ALL school offices, classrooms, and libraries in America.

b. Quality. In regard to educational services, quality should be measured by three criteria: first, by the extent to which consumers operating and using telecommunications services in schools, classrooms, and libraries believe that they are able to utilize such services to accomplish their respective educational objectives; second, by an index which quantifies the Opportunity to Learn provided to teachers and learners through the use of telecommunications; and third, by both quantitative and qualitative indices which represent Increased Student Achievement attributable to the use of telecommunications. These should be assessed periodically through a variety of methods, and the quality of service provided to educational and library users should never be lower than that provided to the average business customer.

c. Affordable. For educational purposes, this notion relates to the ability of schools, classrooms, and libraries to acquire and utilize telecommunications services. In order for this to be equitable, a single flat rate for basic service to all schools, classrooms, and libraries in a given state should be established, benchmarked at a rate no higher than 50% of the average business rate for that service in that state. Similarly, a single flat rate for advanced telecommunications services should be established, benchmarked at a rate no higher than 75% of the average business rate for that service in that state.

II - Comment on NPRM Question 16 about "core services". The following very basic voice services should be included among those core services that are included in the definition of universal services for educational purposes with the "point-of-presence" (i.e., final point at which services are provided) being to every school or classroom and library in America: (a) voice grade access to the public switched network, with the ability to place and receive calls; (b) touch-tone dialing; (c) single party service; (d) access to emergency services (911); and (e) access to operator services.

III - Comment on NPRM Question 17 about what additional services meet the statutory criteria of Section 254(c)(1) and therefore should be among the services that should receive universal service support.

Based on the four criteria specified in Section 254(c)(1), frame relay services, ATM, directory listings, access to interexchange services, voice mail, local (or 800 number supported long distance) internet access, student and educator electronic mail accounts, data transmission capability, optional Signaling System Seven features or blocking of such features, and high speed transmission and broadband telecommunications services [including, but not limited to, ISDN PRI (23B &1D channels) operating over a T-1 line with data rate transmission capability of at least 128 kbps, 56KB leased lines, and T-1 leased lines] should also be considered additional basic "core services" for educational purposes.

Sincerely,

INSTRUCTIONAL RESOURCES

David A. Kennedy, Director           Dennis Small, Program Supervisor
Educational Technology               Educational Telecommunications
dkennedy@ospi.wednet.edu             dsmall@ospi.wednet.edu

Office of Superintendent of Public Instruction
Old Capitol Bldg, PO Box 47200
Olympia, WA 98504
(360) 753-2574