In the Matter of		)
				)
Federal-State Joint Board on	)	CC Docket No. 96-45
Universal Service		)
				)

Re: Notice of Proposed Rulemaking
and Order Establishing Joint Board

Request for Extension of Deadline for Reply Comments
from Information Renaissance

prepared by
Robert D. Carlitz

(April 30, 1996)

Information Renaissance is one of the respondents to the Notice of Proposed Rule Making on Universal Service. This nonprofit organization presented views based upon experience with a number of school and community networking projects over the last four years. We hope to continue to participate in the rule making process on this issue and to facilitate the participation in this process of schools and community groups.

We note that there are severe handicaps for the participation of these groups, given the structure of the current process. A simple look at the statistics relating to Comments submitted for the April 12, 1996 deadline helps to illustrate this point. Most of the regional Bell operating companies, long distance telephone carriers and telephone company trade associations filed testimony. Yet, even though the Notice of Proposed Rule Making dealt extensively and explicitly with matters relating to schools, libraries and rural health care providers, the number of organizations with direct field experience in these areas submitting testimony on the Notice of Proposed Rule Making was minuscule.

Of 50 state departments of education we noted only 3 submissions, or a figure of 6% participation. Of 16,000 school districts we noted only 2 submissions, or a figure of 0.01% participation. There are several reasons for this low turnout, most notably the lack of familiarity that these groups have with the whole regulatory process. We feel that the FCC has an obligation to assist these groups to participate in the process and that this obligation has not been met in the initial stages of deliberation on the Universal Service issue.

Information Renaissance would like to assist school districts, libraries and rural health care providers to participate in the Rule Making process for Universal Service. To this end we have purchased copies of all submissions in the original round of Comments. We are presently scanning this information, processing it with Optical Character Recognition equipment, editing the resulting text and placing it online via the World Wide Web. We have been aided in this task by the FCC's decision to place some fraction of the submitted material online in the form of binary word processing files. Unfortunately the files that have been placed online by the FCC represent no more than 1/3 of the total comments received by the FCC, and these files are extremely awkward for most people to access and read.

In order for significant numbers of school districts, libraries and state departments of education to be able to file Reply Comments based upon adequate knowledge of the original Comments, we would like to request a one week extension of the deadline for the receipt of Reply Comments. This would establish a new deadline of May 14, 1996. We believe that with this new deadline, and with the material that Information Renaissance is now placing online, there can be true representation of affected groups in the important deliberations now before the FCC.

Respectfully Submitted,
Robert D. Carlitz, Executive Director

Information Renaissance
c/o Anthony P. Picadio
Suite 4680
600 Grant Street
Pittsburgh, PA 15219