Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of ) ) Federal-State Joint Board on ) CC Docket No. 96-45 Universal Service ) )To: Joint Board
COMMENTS OF THE U.S. NATIONAL COMMISSION ON LIBRARIES AND INFORMATION SCIENCE ON SPECIFIC QUESTIONS IN UNIVERSAL SERVICE NOTICE OF PROPOSED RULEMAKING
The Honorable Jeanne Hurley Simon,
Chairperson
U.S. National Commission on Libraries and Information Science
1110 Vermont Ave., N.W.
Suite 820
Washington, D.C. 20005
(202) 606-9200
Dated: 2 August 1996
The U.S. National Commission on Libraries and Information Science (NCLIS)[1] is pleased to provide the Federal Communications Commission (FCC) these comments on specific universal service questions related to the matter of the Federal-State Joint Board on Universal Service (CC Docket No. 96-45). These responses supplement the National Commission's comments and reply comments filed with the Federal-State Joint Board on 8 April 1996 and 7 May 1996, respectively.
These comments relate to the Joint Federal-State Board's consideration of universal service support mechanisms to assure public library access to advanced information and telecommunications services at discounted rates. They result from NCLIS's 1996 survey of public libraries and the Internet presented in The 1996 National Survey of Public Libraries and the Internet: Progress and Issues, July 1996, a pre-publication copy of which is attached to these comments as an appendix. The findings from the NCLIS 1996 survey of public libraries are relevant to the Federal-State Joint Board's development of universal service regulations for libraries. NCLIS Commissioners would welcome the opportunity to meet with the members of the Joint Federal-State Board to provide additional information related to the provision of special and core services for universal service support for eligible libraries.
The following general points summarize the National Commission's survey findings and highlight the need for universal service mechanisms that will allow public libraries to provide public access to advanced information and telecommunication services in the most dependable and straightforward fashion. The NCLIS survey findings emphasize the need to address serious discrepancies and disparities relating to levels of public library Internet service, types of Internet connectivity, the costs for Internet, and in the provision of Internet access services to the public.
1 Between 1994 and 1996 public library Internet connectivity increased 113% overall from 20.9% to 44.6%;
1 By 1997, public library Internet connectivity may exceed 90%;
1 Public library use of the Internet varies with the size of population served;
1 Public libraries in communities under 5,000 are significantly (59%) less likely to use the Internet than those serving populations from 100,000 to 1 million +;
1 Public libraries in different regions of the U.S. have different levels of Internet-connectivity;
1 Nearly 40% of public libraries without Internet have no plans to connect in the next 12 months;
1 The NCLIS surveys of public library Internet involvement reveal discrepancies related to
1 the extent of connectivity
1 the type of connectivity
1 connectivity costs, and
1 the provision of Internet public access services.
NCLIS Further Selected Comments on Specific Issues Relating to Universal Service for Libraries
Schools, Libraries, Health Care Providers
6) Should the services or functionalities eligible for discounts be specifically limited and identified, or should the discount apply to all available services?
Based on NCLIS's 1994 and 1996 survey research of public libraries and the Internet, the Commission recommends that discounts be applied to those advanced high-speed, switched, broadband telecommunications capabilities enabling users to originate and receive high-quality voice, data, graphics and video telecommunications using any technology. NCLIS found significant increases in public library Internet connectivity between 1994 and 1996, but also found that public libraries are: a.) committing significant resources to support information technology infrastructure development, b.) increasing the number and band-width of their connections to the Internet, and c.) providing additional public access terminals for their communities to access Internet-based services directly. Many public libraries are planning to embrace the global networked environment and are planning implementation strategies to provide networked information services to their patrons, but will be unable to realize these plans without effective universal service discount methodologies.
7. Does Section 254(h) contemplate that inside wiring or other internal connections to classrooms may be eligible for universal service support of telecommunications services provided to schools and libraries? If so, what is the estimated cost of the inside wiring and other internal connections?
Based on the results of research into the costs of public libraries and the Internet[2], the Commission has developed cost categories, elements, and models of public library Internet services that are useful in understanding the inside wiring and internal connections required for public libraries (both central and branch libraries) to provide access to advanced telecommunications services as addressed by Section 254(h). Estimated costs for inside wiring and other internal connections, from the Commission's research, constitutes between 20% and 35% of total initial costs for public libraries estimated to be spending between $12,635 and $168,220 per library in recurring annual costs for providing public terminals for accessing advanced telecommunications and interactive information services. Many complex factors influence telecommunication-based public library services in different regions of the country serving different population areas, and make it difficult to determine reliable estimates, however, the Commission interprets the universal service provisions included in Section 254(h) to apply to those wiring, hardware, software, telecommunication cabling, and facility renovation costs necessary for the library to offer services based on advanced telecommunications technologies.8.) To what extent should the provisions of Sections 706 and 708 be considered by the Joint Board and be relied upon to provide advanced services to schools, libraries and health care providers?
It is critical that the telecommunications regulations relating to the provision of access to advanced telecommunications capability to all Americans at the national and State levels help assure that public libraries to be able to present opportunities for the public to benefit from infrastructure investment. Public libraries need to develop a regular program of data collection, performance measures, and related statistics of networking activities and services, and it is necessary to develop a timely and accurate process for measuring the degree to which universal service goals have been achieved. This measurement process must also be able to identify what barriers remain to advanced telecommunications capability deployment to all Americans.
9.) How can universal service support for schools, libraries, and health care providers be structured to promote competition?
The Commission recognizes the need to formulate regulations which foster the development of a competitive market for telecommunications services, but NCLIS also recognizes the role of public libraries to function as training/education centers where the public can learn to use advanced telecommunication services effectively. Public libraries offer public access to competitive services and present opportunities for potential customers to identify specific competitive service features that best meet individual needs.
10.) Should the resale prohibition in Section 254(h)(3) be construed to prohibit only the resale of services to the public for profit, and should it be construed so as to permit end user cost based fees for services? Would construction in this manner facilitate community networks and/or aggregation of purchasing power?
In general, the National Commission's 1996 survey research shows that only 3.6% of public libraries offering Internet-services to the public charge some type of fee for graphical Web services, 3.3% have some type of fee for their e-mail account services, 3.1% have some type of fee for their text-based Web services, 1.7% have some type of fee for their gopher-based services, and 1.2% have some type of fee for their newsgroup services. Thus, few public libraries in 1996 offer fee-based services to users and, as public libraries expand public access service offerings to advanced telecommunications capabilities, it is questionable whether the principle of offering free services from publicaly-supported community-funded libraries will be modified. It appears that the prohibition against sale, resale, or transfer in consideration for money is construed to prohibit resale at a profit and to prohibit end user cost based fees for services.
12.) Should discounts be directed to the states in the form of block grants?
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 more efficient to employ block grants based on the population of the library's local service
area and the level of per-capita support provided to the public library. Whatever block grant mechanism or other discount methodology is selected, it should provide for a flexible range of services, including the capacity and speed to accomodate multiple simultaneous users.
13.) Should discounts for schools, libraries, and health care providers take the form of direct billing credits for telecommunications services provided to eligible institutions?
Direct billing credits for telecommunications services provided to libraries for staff and public use would appear to offer certain administrative efficiencies, but the advantages of direct billing credits compared with block grants and other universal service mechanisms need to be measured against current discrepancies and disparities in public library use of advanced telecommunication services. For example, NCLIS 1996 survey responses indicate that by 1997, for communities of 99,999 or less, a significant percentage of the libraries will have no Internet connections and even fewer will provide public access to the Internet. Indeed, for public libraries serving populations of less than 5,000 almost half will not have any type of Internet connectivity by March 1997. In terms of regions, 47% of libraries in the South will not have connections to the Internet whereas only 31% in the West will not have connections.
14.) If the discounts are disbursed as block grants to states or as direct billing credits for schools, libraries, and health care providers, what, if any, measures should be implemented to assure that the funds allocated for discounts are used for their intended purposes?
In comparing the percent of public libraries that provide public access to the Internet from 1994 to 1996, and projected to 1997, the growth rate is much smaller than the rate that the libraries are obtaining Internet access for the library only. Thus, despite significant gains in overall connectivity, only 50% of the public libraries are projected to provide public access to the Internet by March 1997. The vast majority of the public libraries not providing public access to the Internet serve populations of 99,999 or less.
15.) What is the least administratively burdensome requirement that could be used to ensure that requests for supported telecommunications services are bona fide requests within the intent of section 254(h)?
Reference in Section 254(h)(4) to entity eligibility for participation in Library Services and Construction Act programs is sufficient to ensure bona fide requests for supported telecommunications services. However, given the disparities between different public libraries in different size communities currently offering Internet services, proactive contacts to those public libraries eligible that are eligible to receive supported telecommunications services may be advisable.
16.) What should be the base service prices to which discounts for schools and libraries are applied: (a) total service long-run incremental cost; (b) short-run incremental costs; (c) best commercially-available rate; (d) tariffed rate; (e) rate established through a competitively-bid contract in which schools and libraries participate; (f) lowest of some group of the above; or (g) some other benchmark? How could the best commercially-available rate be ascertained, in light of the fact that many such rates may be established pursuant to confidential contractual arrangements?
The 1996 NCLIS survey that shows that 78.3% of the population of the library legal service area being served by a public library with some type of Internet connectivity in 1996 and projected to be 91% of the American population in 1997 may sound impressive but may also be misleading. In fact, a library that has one Internet dial-up connection and serves a legal population of about 200,000 provides relatively poor Internet-based connectivity, and possibly offers no Internet-based services to the public; whereas there can be another public library also serving a population of about 200,000 with 28 public access workstations, with Tl connectivity, managing its own Web site, and offering a range of networked services. Discount structures must allow both types of public libraries to offer their communities with advanced telecommunications connectivity appropriate to the needs of the population.
17.) How should discounts be applied, if at all, for schools and libraries and rural health care providers that are currently receiving special rates?
The National Commission's research which resulted in publication of Internet Costs and Cost Models for Public Libraries in 1995 identified institutions which received special rates in support of offering Internet-based services to the public. NCLIS would be pleased to offer additional information to the Federal-State Joint Board regarding these situations at a later time.
18.) What states have established discount programs for telecommunications services provided to schools, libraries, and health care providers? Describe the programs, including the measurable outcomes and the associated costs.
Throughout the National Commission's research from 1994 to the present, a number of state-based programs for support of public library offering of telecommunications-based services (such as the Internet) have been identified. These include programs in Rhode Island, Iowa, Maryland, Colorado, West Virginia, and California. NCLIS would be pleased to share more information regarding these programs with the Joint Federal-State Board.
19) Should an additional discount be given to schools and libraries located in rural, insular, high-cost and economically disadvantaged areas? What percentage of telecommunications services (e.g., Internet services) used by schools and libraries in such areas are or require toll calls?
Based on the results of the 1994 and 1996 NCLIS survey research on public libraries and the Internet, the Commission recommends an additional discount so that disparities across the country can be corrected. For example , NCLIS" survey research found significant disparities by size of population and by region. The following paragraphs describe in more detail these differences discovered by the research. Disparities also remain regarding the type of connectivity that the various public libraries have to the Internet. Roughly half of the libraries serving populations of 500,000 or more have T1 connectivity to the Internet, whereas very few of the libraries serving populations of 49,999 or less have Tl connectivity. The South and West have almost twice as many libraries connected with T1 compared to libraries in the Midwest and the Northeast.
21) Should the Commission use a sliding scale approach (i.e., along a continuum of need) or a step approach (e.g., the Lifeline assistance program or the national school lunch program) to allocate any additional consideration given to schools and libraries located in rural, insular, high-cost and economically disadvantaged areas?
Currently there are disparities in information technology expenditures, connectivity rates, and the type of connectivity available to public libraries, but, in addition, serious disparities appear in terms of the types of Internet-based services that the libraries can provide. Just as one example, approximately 50% of public libraries serving populations of 500,000 or more have Web servers whereas only 17% of the libraries serving populations of 50,000 - 99,999 have Web servers - and only 35% of the libraries serving populations of 9,999 or less have such Web-based services. These disparities can best be addressed by providing additional consideration to libraries located in rural, insular, high-cost and economically disadvantaged areas.
22.) Should separate funding mechanisms be established for schools and libraries and for rural health care providers?
The Commission's investigations and research into public library involvement with the Internet, together with discussions involving McKinsey & Company consultants who were involved with Connecting K-12 Schools to the Information Superhighway, suggest establishment of separate funding mechanisms which would address the differences between school and public library environments -- these differences include the technological, administrative, funding, organizational, and physical. At the same time, however, it is important to structure incentives for cooperation and collaboration among multiple community partners (such as schools, libraries, and other community organizations) that would leverage the advantages of advanced telecommunication capabilities for the benefit of the entire community.
23. Are the cost estimates contained in the McKinsey Report and the NII KickStart Initiative an accurate funding estimate for the discount provisions for schools and libraries, assuming that tariffed rates are used as the base price?
There are no cost estimates for public libraries in the McKinsey report, Connecting K-12 Schools to the Information Superhighway, or in the KickStart Initiative. The National Commission sponsored research in 1995 which resulted in Internet Costs and Cost Models for Public Libraries. However, this study was to develop models for local application, not national. As the foreword stated,
"The models developed in this study present possible alternatives for consideration at the institutional level. Because local circumstances, choices and alternatives for Internet access and services vary significantly, the cost elements, categories and models presented in this report provide illustrative examples, not implementation instructions."
24.) Are there other cost estimates available that can serve as the basis for establishing a funding estimate for the discount provisions applicable to schools and libraries and to rural health care providers?
The National Commission sponsored research in 1995 which resulted in Internet Costs and Cost Models for Public Libraries. From this research into cost elements, cost categories, and cost
models, it would be possible to develop cost estimates to serve as the basis for establishing a funding estimate for discount provisions applicable to public libraries. However, care must be taken to incorporate the variety of different and complex factors which affect the costs and investments of one community compared with those of another public library, since local and state conditions have a significant influence on the type, extent, and cost level.