U.S. National Commission on Libraries and Information Science
Comments
to
Notice of Proposed Rulemaking and Order Establishing joint Board
before the
Federal Communications Commission
FCC 96-93
in the matter of
Federal-State joint Board on Universal Service
CC Docket No. 96-45
8 April 1996
U.S. National Commission on Libraries and Information Science
1110 Vermont Ave., N.W., Suite 820
Washington, D.C. 20005-3522
(202) 606-9200
Fax: (202) 606-9203
I. NCLIS Background Information
The U.S. National Commission on Libraries and Information Science
(NCLIS) was established by P.L. 91-345 (19 July 1970) to conduct studies,
surveys, and analyses that appraise the adequacies and deficiencies of current
library and information services in order to advise the President and the
Congress on the implementation of national policies.
Throughout the 25-year history of the National Commission,
significant program attention has been devoted to the impact of network and
information technologies on libraries and information services, and on the
evolving roles of U.S. libraries. Activities have included the Commission's
funding of a 1974 study by Westat, Inc. which resulted in the publication of
Resources and Bibliographic Support for a Nationwide Library Program. The
Information Services. Goals for Action in 1975 advanced the concept of a
nationwide network of libraries. This was followed in 1976 by NCLIS's
publication of a study titled Evaluation of the Effectiveness of Federal Funding of
Public Libraries.
In the area of technical standards for la national network, the
Commission published the results of a NCLIS/NBS Task Force on Computer
Network Protocol in 1977: A Computer Network Protocol for Library and
Information Science Applications. Additional Commission publications in the
area of national networking include the 1978 study of The Role of the Library
of Congress in the Evolving National Network and in 1982 publication of
Toward a Federal Library and Information Systems Network: A Proposal.
Over the past eight years the National Commission has worked closely
with the National Center for Education Statistics (NCES) at the U.S.
Department of Education on developing cooperative programs for improving
the collection and distribution of national statistics related to academic',
public, school, and special libraries. This closely coordinated work involves
the annual transfer of non-reimbursable appropriated funding from NCES to
NCLIS for various support and coordination services relating the statistical
specialists at NCES to the various library communities.
The Commission's statute [P.L. 91-345 (July 20, 1970)] was amended 14
August 1991 by P.L. 102-95 to include the following function in Section 5
(a) (6):
"The Commission shall ... promote research and development activities
which will extend and improve the Nation's library and information
handling capability as essential links in the national and international
communications and cooperative networks.
H. NCLIS Research Related to Library Networks and the Internet
The National Commission continues to be involved with programs
related to recommendations resulting from the 1991 White House Conference
on Library and Information Services (WHCLIS). One of the priority 1991
WHCLIS recommendations receiving current NCLIS program emphasis calls
for libraries to 'Share Information Via Network 'Superhighway." This
recommendation calls for the developing national "information superhighway"
network to "...be available in ad libraries and other information repositories at
every level. " This and other recommendations relating to the role of libraries
and information services in national networks received strong endorsement
from the 2,000 1991 WHCLIS delegates who represented librarians, citizens,
and elected officials from all 50 States, the territories, and Indian Nations.
Since the 1991 Conference, the National Commission has sponsored a
number of events and studies related to the implementation of
recommendations relating libraries with information network technologies.
The first of these involved representatives from national organizations and
allied groups offering testimony to an NCLIS open forum on the
recommendations from the 1991 White House Conference. This forum was
held in Washington, D.C. 10 March 1992. A second Commission-sponsored
open forum was held in Washington, D.C. 20-21 July 1992 to focus
specifically on identifying and clarifying the issues and concerns of the library
and information services community, both as providers of information to be
carried on the National Research and Education Network (NREN). The
event involved representatives of large groups of users and potential users of
the network. The results of the NCLIS Open Forum on the National
Research and Education Network were conveyed to the Office of Science and
Technology Policy in a Report on Library and Information Services'Roles in the
National Research and Education Network issued in November 1992.
One--clear and consistent message resulting from these Conunission
activities involving the role of library and information services in the
emerging national networked information infrastructure, concerns the need
for reliable and current national and state statistics on the extent of the library
community's involvement and use of the Internet and network services.
Additionally, effective planning for deployment of advanced communications
and information infrastructure requires current descriptive statistical
information about the rapid changes occurring in the public library
community. While many academic and research libraries in colleges,
universities, and research institutes are involved with Intenet/NII
applications accessible through computer center links to global high-
performance network interconnections, many public libraries are in the early
stages of involvement with advanced communications and information
services and networks such as the Internet. Without current statistics and
longitudinal statistics on public library use of the Internet and analysis of the
potential of network service capabilities in public libraries, national policy
formulation c2nnot proceed.
More recently, in 1994 the Commission sponsored survey research
about the extent of public library involvement with the Internet. The results
of this project were included in the publication Public Libraries and the
Internet Study Results, Policy Issues, and Recommendations [1] which was issued
and distributed by NCLIS in June 1994. Over 3,000 copies of this publication
have been distributed in response to demand fromthe public. The report has
been widely cited and serves as the basis for several bills introduced to the
104th Congress to update and reauthorize the Library Services and
Construction Act. In addition, the NCLIS study formed the basis for the
work of the National Information Infrastructure Advisory Council's
MegaProject II which researched the costs of involving schools, libraries and
community centers in the NII.[2]
The Public Libraries and the Intenet report served as the basis for
NCLIS briefings on libraries and the Information Superhighway which were
conducted in Washington, D.C. 21-22 September 1994. The first briefing
included reports by State Library Agencies from 15 states on statewide
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1 U.S. National Commission on Libraries and Information Science. Public Libraries and the Inter=
Study Results, Policy Issues, and Recommendations. Washington, D.C., June 1994. [A copy of this
?ublication is included as an appendix to these comments.]
2 United States Advisory Council on the National Information Infrastructure. KickStart lnitiative:
Connecting America's Communities to the Information Superhighway, Washington, D.C., January 1996.
p. 96-98.
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projects involving Internet/NII services and public libraries. Further, this
briefing on statewide networking was followed by a briefing focusing on
federal networking activities and initiatives. The federal networking session
included representatives from Congress and the Administration, as well as
state and local sectors, discussing ways to coordinate the involvement of
public libraries in the Internet.
The Commission's 1994 study resulted in the first national statistics
describing the services and resources of public libraries that included
information on public library use of the Internet or of information network
services, costs, applications, and usage. As a result of the Commission's
survey, data elements about networking activities in public libraries have been
identified for inclusion in future surveys of the Federal State Cooperative
System for Public Library Statistics. This annual survey is a ered by
the National Center for Education Statistics with program coordination by
the National Commission.
In 1995, NCLIS sponsored research into the cost elements, cost
categories, and cost models for public libraries and NII technologies. The study
resulted in the Co ion issuing Internet Costs and Cost Models for Public
Libraries [3] in June 1995. This study addresses public library community's need
for practical cost information related to Internet connectivity and services. The
realization of the need for reliable and current information about Internet costs
for public libraries came from the Commission's review of the findings reported
in Public Libraries and the In While this study found 20.9% of U.S. public
libraries were involved with the Internet, respondents reported difficulty in
identifying and describing specific Internet costs. Public librarians highlighted
the critical need for reliable cost information to assist in planning Internet
connectivity and in developing networked library services for the public.
Costs and Cost Models for Public Libraries is not intended as a
"how-to" manual for connecting public libraries to the Internet. The cost
elements, categories, models, and worksheets serve as useful guides for
communities and public libraries planning Internet connections and services.
The study provides guidance for initial Internet planning and for the
identification and evaluation of issues related to public library/Intemet
planning. By identifying five representative connectivity models and seven
broad cost categories, the report offers examples for use by public libraries
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3 U.S. National Commission on Libraries and Information Science. Internet Costs and Cost Models for
Public Libraries. Washington, D.C., June 1995. [A copy of this publication is included as an appendix to
these comments.]
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planning latemet connectivity and services. Cost elements relating to
communication hardware and fees are included in the models developed for this
study.
The value of the Commission's study of public library costs related to
Internet rests more with the development and establishment of generic public
library cost models and cost categories than with the applicability of
representative costs to individual circumstances. However, the representative
costs included in the models developed for the report illustrate the wide
variations that are encountered in planning the networking permutations and
configurations available to the public library community. These variations have
important policy implications for the development of mechanisms to assure
service availability on a universal basis. The costs for connecting a public
library to the Internet vary with the type and level of connectivity, the services
the library will support, the users of the services, and the specific local and state
provisions for providing connectivity for libraries.
No one typical or generic cost model emerged for public library
connection to the Internet from the Commission's study. Rather, great
variances were found between different libraries located in different geographic
regions and locations around the Nation. These variances between connectivity
and telecommunication costs for public libraries connecting to the Internet and
planning to offer patron access to advanced information services based on digital
network technologies, present distinct problems in achievement of a "level
playing field'. Libraries in rural or remote areas serving widely scattered and
diversified populations are paying much higher costs for dial-up connection to
the Internet than other libraries in more suburban or urban areas. Thus, the
Commission's cost study identifies model access for a single library using a
single workstation for text-based access to the Internet. This configuration
requires that the library pay an annual cost of $12,635. 95% of this recurring
cost is related to telephone lines, line charges, and Internet service provider fees.
Typically, other model configurations for public libraries accessing the Internet
using multimedia workstations from multiple service points involved between
6% and 17% of annual recurring costs going for telecommunications charges.
The Commission's public library Internet cost study shows that for an
initial one-time cost of $1,475 and a recurring annual cost of $12,635, a public
library can establish a minimal level of single-workstation, text-based Internet
connectivity. At a more complex level, the report describes a representative
multi-media Internet public library connectivity model involving multiple-
workstations at multiple library locations for a one-time cost of $266,375 and a
recurring annual cost of $154,220. The wide variation in total initial and
recurring representative costs associated with public library Internet
connectivity indicate the difficulties involved with stipulating a few standard
and generic cost models for deployment of advanced communications
infrastructure capability in libraries.
The Commission's examination of Internet costs for public libraries is
based on the belief that these community information centers will comprise an
essential component of the NU in the future. The findings of the studies are
intended to provide a basis for extending the benefits of advanced information
services to the Nation through 8,929 U.S. public library administrative entities.
The Commission is committed to providing assistance in realizing the vision of
universal service that will allow all Americans to take advantage of our rich
resources in libraries, information, communication, and computing
technologies. Libraries have an essential role in achieving the vision of equal
and equivalent access to advanced networking information services for all.
III. NCLIS Comments on Specific Provisions Included in FCC 96-93:Notice of
Proposed Rulemaking
A. Introduction (p. 3) [4]
With the extremely rapid pace of development and change characteristic
of advanced telecommunication and information technologies, it is important
that the FCC and the Federal-State Joint Board regularly and routinely review
current state-of-the-art capabilities in relation to universal support mechanisms
involving libraries at periodic intervals. This review is needed in order to assure
that the provisions affecting access to the latest advanced services at discounted
prices enable libraries to provide access to the widest array of information
services and resources permitted by the capabilities of current technology.
The mechanisms developed to the quality of service provision as
well as the extent of success in achieving universal service and access to
advanced information services through libraries must involve measurement
capabilities that respond to the rapid pace of technological change in the field.
Establishment of performance standards needs to take into consideration the
widely varying community characteristics that exist from library to library, and
for different types of libraries. In addition, the measurement and assessment
mechanisms should allow for different levels of advanced service offerings
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4 Page references in parenthesis for these headings refer to FCC Notice of
Proposed Rulemaking FCC 96-93, 8 March 1996.
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available through libraries. The rapid development of technology for
communication networks requires that libraries be provided with a range of
discounted rates for services that address the quickly evolving and changing
array of different technical information systems architecture in libraries.
Flexibility is required to accommodate the complex arrangements and
alternatives needed to provide library patrons access to networked information
system resources.
Libraries' use of advanced telecommunication services for connection to
Internet services for both library staff and public access is increasing at an
extremely rapid rate. So, too, libraries are rapidly changing the nature of
connection and access to networked systems and services. They are increasingly
providing multimedia-graphical patron access services that require more
advanced telecommunication links and services. Thus, the Commission's 1994
national sample survey of U.S. public libraries showed a connectivity rate of
20.9%. Preliminary indications from the NCLIS 1996 national sample survey
are that the public library connectivity rate has increased to between 40% and
50%. Further, in response to a question about library plans to connect to the
Internet in the next 12 months, for those public libraries that reported that they
were not currently connected to the Internet in early 1996:
17.5 % indicated plans for staff access to Internet
45.2% indicated plans for staff and patron access to Internet
37.3% indicated no plans for access to Internet
With between 40% and 50% of U.S. public libraries connected to the
Internet in 1996 and 62.7% of those not connected planning for Internet access
in 1996-1997, preliminary results indicate that it is quite possible that between
75% and 80% of U.S. public libraries will have some form of Internet
connectivity by late 1997. This represents an extremely rapid increase in public
library Internet connectivity since the Commission's first survey in 1994. The
rate of Internet connectivity of public libraries between 1994 and 1996 is greater
than the rate of Internet access reported for U.S. public schools' which
increased from 35% in 1995 to 50% in 1996 according to a study by the
National Center for Education Statistics. In addition, as with those public
libraries not currently connected to the Internet (62.7%), a significant number
of schools (740/o) indicated plans to obtain Internet access in the future.
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5 National Center for Education Statistics. E.D. Tabs. Advanced Telecommunications in U.S. Public
Elementary and Secondary Schools, 1995. Washington, D.C., February 1996.
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Not only is the percentage of public libraries connected to the Internet
increasing, the type and level of public library connectivity to the Internet are
expected to change rapidly as well in the near future. These changes will
require that libraries have access to more sophisticated telecommunications
capability. The Commission's 1994 survey revealed that the most common
type of public library Internet connection is VT-100 terminal access at 47.1% of
library connections, followed by e-mail gateway (13.9%), and dial-up Serial Line
Internet Protocol (SLIPP)/Point-to-Point Protocol (PPP) connection at 11.8%.
In general, findings from the'1994 survey indicated that larger libraries
have Internet connections that support a fuller range of access to Internet
services through the use of direct connect and SLIP/PPP connections. Smaller
libraries employ modems for dial up connections to the Internet. With the
rapid proliferation of graphical interfaces and World Wide Web capabilities, it is
anticipated that the NCLIS 1996 public library Internet survey will show a
significant change in type of connectivity to more advanced capability.
Along with these changes in type of connection, public libraries
increasingly require higher speed and higher capacity telecommunication
capability to support both library staff networking functions as well as increases
in public access connectivity to advanced networked information services.
Thus, it is critical that library discount rates address the increasing
sophistication of networked information services in libraries that require
advanced telecommunication support and linkages. In 1994, 87.3% of public
libraries reported that they did not provide public access Internet terminals for
patrons. It is expected that the 1996 survey results will show a significant
increase in public libraries offering patron access to the Internet.
The Commission's 1994 public library/Intemet survey responses show
that costs for connection to the Internet are a major factor in determin' g
library connectivity. Costs were identified as the most important factor for
public libraries serving populations of under 10,000. Costs were not as
important a factor in determining connectivity for libraries serving more urban
populations. Responses to the NCLIS 1994 survey also revealed regional
variances in connectivity: public libraries in the Mid-west and the West rated
connectivity costs to be the most important factor affecting Internet
involvement. Rural libraries also indicated that Internet connection costs were
very important, while urban libraries were less concerned about the costs of
connection.
As higher percentages of public libraries establish and expand Internet
connections for staff and for patron access to networked information services,
and as increasingly advanced and sophisticated Internet connections are required
to support additional functions and to accommodate access to expanded services
which involve interactive services and retrieval of graphics, audio, and full-
motion video, tight library budgets face additional strain. This situation
presents the danger that libraries may not have sufficient resources available to
respond effectively to increased community demands for advanced network
information services. This situation is especially true for those advanced
telecommunication services that require higher speed levels of digital
transmission for multiple simultaneous users.
If libraries are unable to allocate scarce resources to establish, maintain,
and upgrade communication links to support electronic networking in the
future, the situation would be equivalent to keeping a newly constructed public
library branch closed to the public due to the lack of funds for staff and
resources. Failure to implement provisions for discounts and support
mechanisms that are necessary to allow libraries to keep pace with increasing
community demands for public access to advanced communications and
information services, at this state of network development in libraries, could
impose significant barriers to the evolving roles of libraries in providing access
to electronic materials from a wide range of collection resources. The situation
is especially critical for those remote and rural community libraries which are
required to pay higher telecommunication fees to support community access to
network information services.
Libraries typically provide information services to users based on policies
that structure the terms and conditions by which patrons can take advantage
and use these standard services. In the case of those library services that are
based on library use of advanced telecommunications and information services
such as the Internet, libraries offering such services have developed policies that
determine patron use, including responsible activities that reflect personal use
not business applications. The use of advanced networked information services
in libraries at present under clearly established patron policies is protection
against individuals using these services in such a way as to take advantage of
discounted service offerings on a pass-through basis, especially from remote off-
site locations.
Public libraries offering public access to the Internet encounter
significant technical and service demands in addition to telecommunication line
charge costs required to offer network based services. In certain circumstances,
these additional demands on library budgets and on library staff for technical
support, patron training, content development, program planning and
management, software integration, and systems maintenance present challenges
for library managers and administrators confronted with static budgets,
increased costs, and declining purchasing power. The transition of libraries
from providing services based primarily on printed textual collection resources
to an environment offering a mixture of print and digital resources presents
challenges and opportunities. Additional factors related to fluctuating and
unpredictable telecommunications costs may present insurmountable difficulties
and problems for library managers and may impose barriers to the ability of
libraries to provide enhanced access to an increased volume of information to
their communities.
B. Goals and Principles of Universal Service Support Mechanisms (p.4, p. 35)
In developing mechanisms based on the seven policies for the
establishment, preservation, and advancement of universal service, the joint
Board and the FCC should clarify the sixth principle, concerning the provision
for libraries to have access to advanced telecommunications services. The term
'Libraries" needs to be more carefully defined. Clarification is needed that this
principle applies to libraries in public and private (not-for-profit) elementary
and secondary schools, as well as to academic libraries in colleges, universities,
and research institutions, as well as federal, State, and local government
libraries, law libraries, medical libraries, state library agencies, public libraries
(including central libraries, branches, and other service outlets of public library
systems), as well as those not-for profit cooperative systems and networks that
provide a range of support services to libraries at the local, State, regional, and
national levels. These various types of libraries, as well as libraries designated as
official depositories for government documents and information as provided by
the Superintendent of Documents at the Government Printing Office, are
important links in providing access to information resources and services for
educational purposes.
1.) Schools, Libraries, and Health Care Providers:
a.) Goals and Principles (p. 35)
Public libraries provide an institutional presence in most American
communities. With 15,904 public library branch service outlets providing
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6 National Center for Education Statistics. E.D. Tabs. Public Libraries in the United States: 1993.
Washington, D.C. September, 1995.
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services to a service area population of 261,052,000, the Nation has a significant
public institutional infrastructure with the potential to function as the basis for
public access to digital information services and resources rapidly becoming
available through advanced telecommunications and information service
technologies. Public libraries have the potential for introducing these new
service capabilities and technologies to those within their legal service
communities who otherwise might not encounter the benefits of advanced
information systems. just as public libraries provided many young children and
older citizens their first hands-on experience with personal computers used as
online public access catalogs, so libraries are play an important role in
introducing and training patrons in the use of networked information services.
Unlike elementary and secondary schools, which focus primarily on
providing enrolled students with access to advanced telecommunications
services for educational and leaming purposes, public libraries serve the lifelong
learning, educational, and informational needs of the entire community, from
children to senior citizens. Public libraries are centers for students of all ages,
from pre-school to adult learners. They have functioned as the public's
university. Public libraries are also central to the cooperative efforts within
communities which link other types of libraries (university, college, school,
governmental, and special) together to share systems, resources, and programs.
Libraries are using interactive two-way, advanced communication
capabilities to support patron access to a range of networked information
services and resources. In addition to providing access to information through
networked communication services, public libraries are linking with
community networks ("Free Nets'), schools, universities, and other
community-based organizations in their regions in partnerships which link
various groups and interests together. Such sharing and cooperative activities
involving library use of advanced telecommunication and information services
extend the benefits of public library services to additional aspects of
communities.
b. Library Services to Support (p. 38)
Support mechanisms to enable libraries to receive both core and
advanced telecommunications services included among those eligible for
universal service support must respond to the needs of libraries for both
flexibility and consistency. This support is critical if libraries are to continue to
build upon their initial involvement with electronic networking through
connections to the Internet for both accessing digital information resources and
for developing information resources for use by others. Flexible support
mechanisms are needed for libraries to move from providing limited network
information services (text-based Internet services) to more extensive network
services (graphical based WWW services) and to be able to take advantage of
future applications requiring additional telecommunications bandwidth.
Consistent support mechanism structures are needed to allow libraries to plan
future service offerings and to budget for those costs associated with these more
advanced services. These more advanced services and applications involve the
creation of information resources and facilities by libraries, not just the
provision of access to network content resources available from other providers.
Formulation of discount methodologies and support mechanisms to
ensure that libraries have the opportunity to provide access to advanced
telecommunications and information services are critical to the successful
implementation of the universal service provisions of the law. Construction of
these methodologies and mechanisms should minimize those administrative and
operating expenses incurred while assuring uniform or standard practices that
protect against inequalities from state to state, region to region, and for those
libraries, schools, and other educational institutions that require interstate
telecommunication support services.
The technical architecture of library connections to advanced networks
and information services is often quite complex.,, It is not uncommon for
libraries to contract for network telecommunication services separate from
Internet provider services, using discounted service offerings available through
State library agencies, State public higher education systems, or other
cooperative regional educational service authorities. Library costs for text-based
Internet connectivity for single terminal access to information services can
constitute over 90% of total annual recurring costs for Internet services.
Effective use and integration of network access to electronic information
services available through the Internet require that libraries have multiple
terminals and communication lines available for those hours the public library
is open for service. The discount formulae and support mechanisms need to
address a wide array of technical architectures some provided through private
carriers and others provided through state library networks, or other regional
or local educational organization which is eligible for discounted rates.
In order to minimize the barriers to the provision of telecommunications
services to schools and libraries, functions to be supported through universal
service mechanisms must allow libraries to receive advanced services in the most
dependable and straightforward fashion. Rather than pay full service rates with
subsequent rebate through a separately administered fund for universal service,
it may be administratively more efficient to develop formulae for calculating
discounts based on the population of the library's local service area and the level
of per-capita support provided to the public library, or the total operating
income of other types of libraries. Whatever mechanism or discount
methodology is determined, it should provide for a flexible range of services,
including the capacity and speed to handle multiple connections simultaneously.
In addition, there should be built-in methods of constant and periodic review to
assure that discount structures address the continual rapid pace of technological
change.
In addition to offering these comments, the National Commission plans
to provide the FCC with results from a national sample survey of libraries
conducted in early 1996 to determine the current state of public library
involvement with the Internet. Analysis of responses from this survey is
expected to provide detailed statistics for consideration in establishing
mechanisms for achieving the principles of universal service. The Commission
plans to provide additional comments using the results of the 1996 survey study
prior to the 3 May 1996 deadline. The additional comments are expected to
address the following:
* The percentage of public libraries that connected to the Internet in 1996
* Comparison of the percentage of public libraries connected to the Internet
1994-1996
* Projection of the percentage of public libraries that are not now connected
that are planning to connect to the Internet over the next 12 months
* The percentage of public libraries that are connected to the Internet that
offer public access to network services
* The percentage of public libraries that are connected to the Internet that
have text-based and graphical-based browsing capabilities