FARNET
The Federation of American Research Networks
AGIS April 11, 1996
Federal Communications Commission
ANS 1919 M Street, NW
Washington, DC 20554
ASPIN Reference: CC Docket No. 96-45
Washington Office
1112 16 Street, NW
Suite 600
Washington, DC 20036
(202) 331-5342
BBN Planet In the Matter of Federal-State joint Board on Universal Service
Bellcore Honorable Commissioners and Members of the joint Board:
CICNet On behalf of the Federation of American Research Networks (FARNET), I
Cornell University submit the following informal comments on the Notice of Proposed
CREN Rulemaking regarding Universal Service.
CSUnet FARNET is a not-for-profit organization formed in 1987 to facilitate
cooperation and discussion among educational institutions, corporations and
the government in the building of the Internet, primarily through the
Merit NSFNet program. FARNET members consist of both not-for-profit and for-
MOREnet profit organizations, including Internet Service Providers, Network Service
Providers, Interexchange Companies, Regional Bell Operating Companies,
MRNet Universities and Supercomputer Centers. Although the NSFNet backbone
transitioned to commercial providers (many of whom are FARNET
NC-REN members) in April of 1995, FARNET and its members continue to work
net ILLINOIS together to ensure that the advancing needs of the research and education
community are met by present and future networks.
Nevada Net FARNET commends the Congress for its foresight in taking into
North WestNet consideration the evolving nature of electronic communications
infrastructure and services. The 1996 Telecom Act states that, "Universal
service is an evolving level of telecommunications services that the
OARnet Commission shall establish periodically under this section, taking into
account advances in telecommunications and information technologies and
PREPnet services." (PL 104-104 Sec. 254 (c) (1)) The Commission and Federal-State joint
PSC Board have a tremendous opportunity in defining which services will be
included in "access to advanced services" generally and "access to advanced
Sesquinet telecommunications services for schools, health care, and libraries" especially.
Sprint I would like to comment specifically about the possible inclusion of "Internet
access." In paragraph 22 of Section III of the NPRM, the Commission asks for
SURAnet comments on whether "Internet access availability" is a service "that may
VERnetN warrant inclusion, now or in the future, in the list of services that are
supported by universal service support mechanisms" for rural, insular and
high cost areas. In Section V, paragraph 36, of the NPRM, the Commission
contemplates its role in establishing rules to enhance the availability of
advanced telecommunications and information services to schools, libraries
and rural health institutions, including, possibly, "dedicated data links" and
the ability to access information "carried over the Internet."
The "Internet" is primarily a collection of mutually agreed upon protocols
which allow computers to communicate with one another over private and
public networks. Today, access to the Internet for most rural and many
suburban Americans is available only over analog (POTS) telephone circuits.
On the other hand, a number of broadband transmission technologies are
currently available to urban residential and business customers, including
ISDN and Hybrid Fiber-Coax cable systems for connection to the Internet.
These technologies are much more capable for providing access to advanced
communications such as the Internet.
There have been barriers to reaching that goal. For example, FARNET notes
the difficulties many of its members' customers have had in obtaining even a
relatively easily-installed technology such as ISDN from their local telephone
companies. 1
FARNET urges the Commission to make a distinction between the access
technologies necessary to deliver services and the enhanced services
themselves. A participant in last year's NII 2000 workshop convened by the
Computer Science and Telecommunications Board of the National Research
CounciL put it this way, "Yesterday the term universal service did not
differentiate between access and the service itself, because for a phone call the
phone and the service were essentially the same thing. Now, or in the future,
we are talking about two different things."'
The provision of Internet service (not the provision of the lines or cables
needed to access that service) is already a highly competitive market with
multiple providers in almost every LATA. (see for example, TheList at
http: / /www.thelist.com/) Furthermore, if FARNET members are any
indication, many Internet Service Providers are already engaged in providing
Internet service to the K-12 community, often at a significant discount. More
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Integrated Services Digital Network (ISDN) gives the user 128 Kbps access to the Internet,
almost 4.5 times faster the fastest analog modems currently available at 28.8 Kbps. ISDN
plays an important role in giving business, educational and residential users a stepping stone
between modem access and dedicated access. However, the pricing and availability of ISDN
around the country have varied widely. For example, residential tariffed prices for 100 hours
of 2B + D usage per month vary from $17.90 to $314.83. (See Selected ISDN Tariffs, Consumer
Project on Technology, version 1.0b, March 8,1996, http:/ /www.essential.org/cpt)
2 Computer Science and Telecommunications Board, The Unpredictable Certainty, National
Academy Press (Washington, DC): 1996, pg. 201.
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importantly, many are engaged in the even more important provision of
human resources to help those schools realize the most out of their
connection.
FARNET urges the Commission to ensure that adequate investment is made
in a physical infrastructure (technologically neutral) capable of delivering
high-performance access to the Internet.
As the Commission cited in its NPRM, one of the foremost problems schools
cite as obstacles to getting on the Internet, is "inadequate telecommunications
links."' Little can be achieved by giving schools, libraries and health care
providers discounts for Internet service if the underlying transport facilities
are not capable of delivering meaningful (i.e. video, voice, graphical and text
enabled) access. As we have discussed above in terms of ISDN, the current
system has worked against the rapid deployment of new transport
technologies. While ISDN is probably not a long-run solution to the access
needs of schools, it might have been a cost-effective stepping stone to higher
performance technologies.
Finally, the Internet serves as an excellent model for future networking
infrastructures. However, FARNET recognizes that the Internet is just the
beginning. Keeping universal service focused on the availability of various
transmission technologies will allow all types of advanced communications
services to flourish.
On behait of FARNET, I thank the Commission for the opportunity to
comment on this issue. FARNET would be happy to provide additional
comments on any of these issues.
Sincerely,
Jim Williams
Executive Director
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3 National Center for Educational Statistics, US Department of Education, Advanced
Telecommunications in US Public Elementary and Secondary Schools 1995, Feb. 1996.
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