United States Department of the Interior

OFFICE OF THE SECRETARY
Washington, D.C. 20240

April 12, 1996

Honorable Reed E. Hunt
Chairman
Federal Communications Commission
Washington, D.C. 20554

RE: Federal-State Joint Board on Universal Service CC Docket No. 96-45

Dear Mr. Chairman:

The Office of Insular Affairs wishes to submit comments on the Notice of Proposed Rulemaking and Order Establishing a Joint Board which implements the Congressional directives set out in Section 254 of the Communications Act of 1934, as added by the Telecommunications Act of 1996.

The Department of the Interior supports the goals and principles of universal service support mechanisms, especially for Guam and the Commonwealth of the Northern Mariana Islands (CNMI). We urge the Commission to do everything in its power to ensure that they are included in all aspects of universal service.

JWe support the Joint Board and the Commission basing the universal service policies on the seven principles listed in the Notice and Section 254 (g). We urge that those principles' have full application to the CNMI and Guam:

1. The residents of these insular areas should have quality service at just, reasonable, and affordable rates. We support domestic rate integration for these areas as a means for quality service at affordable rates. At the present, these insular areas must pay higher prices for telecommunications services and many times are deprived of certain services available to other Americans.

2. Access to advanced telecommunications and information services must include those insular areas. We urge the Commission to seek ways to facilitate access to the distant geographical of the islands.

3. Consumers in the insular areas should have access to telecommunications services. They are low income customers in high cost areas. We, also, support the inclusion of Guam and the Commonwealth of the Northern Mariana Islands into the North American Numbering Plan to facilitate this access.

4. All providers of telecommunications service, including those in the insular areas, should make an equitable and nondiscriminatory contribution to the preservation and advancement of universal service. We support the inclusion of Guam and the CNMI governments, residents and businesses into the "core" group for universal service.

5. The specific and predictable support mechanisms should be extended to these insular areas.

6. Access to advanced telecommunications services for schools, health care, and libraries must be given to the CNMI and Guam. we support universal service support for these additional services. Their distant location and small population make access difficult and expensive; therefore, it is imperative that a special effort be made to see that these services are extended.

7. In whatever other principles as the Joint Board and Commission may determine necessary, we ask that special consideration always be given to the insular areas. We support voice grade network access, touch tone dialing, single party service, emergency services, and access to operator services as "core" services receiving universal service support. In addition, we ask for universal service support to include toll-free access to 800 services and on-line information services for the CNMI and Guam.

Universal service is important to Guam and the CNNI as it will facilitate closer economic, social and political ties with the contiguous United States. Without universal service, the United States citizens in the insular areas will be unable to access a comparable level Of affordable telecommunications services, causing them to be left economically and socially isolated from the mainland United States. It is the responsibility of the United States Government to assist these insular areas achieve economic development, and telecommunications is a primary basis for such development.

Sincerely,

Allen P. Stayman
Director
Office of Insular Affairs