Federal-State Joint Board on
Universal Service (FCC 96-93)

CC Docket No. 96-45

COMMENTS OF THE COUNCIL OF THE GREAT CITY SCHOOLS

The Council of the Great City Schools, a coalition of nearly fifty of the largest urban, central city school districts of the nation, request the consideration of the following comments to the Notice of Proposed Rulemaking on Universal Service.

1. NPRM Question 4: Regarding Principle Three of Access to Telecommunication and Information Services, an express reference to "high poverty urban/central city area" should be incorporated into the regulations which would implement the provision's reference to low-income as well as high cost areas. Regarding Principle Six of Access to Advanced Telecommunications Services for Schools, Health Care and Libraries, such access should be interpreted to include all classrooms and offices within a school rather than just a single point within the school building. Also inherent in the concept of access, particularly for school districts serving low-income areas, is affordability.

2. NPRM Question 9 and Section IV(B): Based on the rapid evolution of telecommunications technology and the increasing capacity of schools to utilize that technology, if accessible and affordable, the Commission should determine that all available telecommunications services which hold the promise of improving the knowledge base or instruction of children are "essential."

3. NPRM Question 83: Regarding Discounts for Schools and Libraries, the discount rate charged for telecommunications services will affect access as substantially as the infrastructure in schools through which such services will be delivered. In recognition of the direct relationship between the ability to pay even a discounted rate and the overriding principle of access, the Commission should consider establishing discount rates in declining amounts for schools in direct proportion to their ability to pay such races. The best, though not only, proxy for ability to pay would be the rate of poverty in the school district 'Jurisdiction. Further, it is important that the federal (interstate) and state (intrastate) discounts be established in a coordinated manner. Additionally, the complexity of the access issues in education and the direct relationship to rates suggests the establishment of a permanent advisory body under the Commission comprised of representative of school districts, particularly those with identifiable access problems such as inner city and rural schools.

CONCLUSION

The Great City Schools and the low-income communities which they serve, continue to find significant barriers to access to services, including telecommunications, which or-her school districts do not encounter. The effective implementation of the Universal Service provisions of the Telecommunications ACE Of 1996 Is critical to the improved delivery of education and to economic viability of low-income communities and their residents.

Respectfully submitted,

Michael Casserly, Executive Director
Council of the Great City Schools

Address: Council of the Great City Schools
1301 Pennsylvania Ave. NW Suite 702
Washington D.C. 20004
Phone: 202-393-2427