FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

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

COMMENTS OF THE BLACK COMMUNITY CRUSADE FOR CHILDREN

The following comments are submitted by the Black Community Crusade for Children (the "BCCC") in response to the Notice of Proposed Rulemaking and Order Establishing Joint Board, FCC 96-93.

The mission of the BCCC is to ensure that no child is left behind and that every child has a Healthy Start, a Head Start, a Fair Start, a Safe Start and a Moral Start in life with the support of caring parents and nurturing communities. The BCCC is coordinated nationally by the Children's Defense Fund (CDF) in partnership with well-established and effective regional childserving organizations.

We urge the Commission to develop new pro-active policies to ensure that children from low-income families have access to basic and advanced telecommunication services as soon as possible. The Telecommunications Act of 1996 (the"Act") requires that universal services be available to all at just, reasonable, and affordable rates. The BCCC strongly supports the Joint Board's goal to ensure that consumers in all regions of the nation and at all income levels, including low income consumers, enjoy affordable access to a wide range of telecommunication services. Access to such services for low-income people is essential if they are to have equality of opportunity and be full participants in the political, economic and cultural life of the nation in the decades ahead.

The telecommunications revolution promises to provide extraordinary opportunities for many children. But it also threatens to leave some children at an even greater disadvantage by magnifying existing educational and economic disparities in the United States.

Black children and Black families in particular are facing one of the worst crises since slavery. Nearly 40% of Black children are living in poverty, compared to 12.5% of White children. In addition:

* Every 46 seconds of the school day a Black child drops out.

* Every 4 minutes a Black teen has a baby.

* Every 48 minutes a Black baby dies.

* Every 4 hours a Black child dies from gunfire.

While the educational gap between Black and White students has narrowed since the 1960s, there are still substantial disparities. For instance, Black high-school graduates are only half as likely as their White counterparts to have the benefit of advanced courses in science and mathematics. Many of the schools that serve Black children remain segregated by income and race, and have meager resources.

Several reports have documented the serious and growing differences between high-wealth and high-poverty schools in their students' access to computer technology. Students who are poor clearly have less access than their better-off peers to these increasingly fundamental tools, and when poor students do have access it is more often for routine drill and practice than for the kind of advanced-level programming offered to students in more affluent schools. It is crucial that all children have access to basic and advanced telecommunication services, and that they be able to utilize fully such technology.

The vast majority of schools do not have access to the services and equipment necessary to utilize interactive telecommunications services. A recent report on Advanced Telecommunications in U.S. Public Elementary and Secondary Schools 1995, E.D. TABS (Feb. 1996), shows that the current level of school usage of telecommunications, including the Internet, is inadequate and unacceptably low. For instance, only 9% of all instructional rooms (classrooms, media centers, and computer labs) are currently on the Internet. Schools with large proportions of students from poor families are half as likely to provide Internet access as schools with small proportions of such students. While nearly all schools have telephones, only 12% of classrooms have telephones.

The GAO has found that over half of all schools have reported "insufficient capacity in modems, phone lines for modems, phone lines for instruction, conduits/raceways, and fiber optics." General Accounting Office, School Facilities--America's Schools not Designed or Equipped for 2lst Century, B-259609 (April 4, 1995). Moreover, many schools are so financially beleaguered that they can not afford to buy computer terminals and other equipment to utilize telecommunication services.

We strongly endorse the Act's attempt to promote telecommunication access through public institutions, especially through elementary and secondary schools and libraries, to provide access for children who may not otherwise have access to advanced telecommunication technologies such as the Internet. These institutions can serve as gateways for children and parents, and for the broader public in disadvantaged areas.

All elementary and secondary schools and libraries should have access to full telecommunication services. All carriers should be required to provide substantial discounts for universal services and other designated services. We urge the Commission and the Joint Board in designating the additional services to include all telecommunication services currently available at the more advanced schools and libraries. We also urge that "those services which are likely to become available" also be included in order to ensure that facilities in disadvantaged communities can keep pace with advantaged communities. In any case, the regulations should use language that will allow for changes in technology. We further urge the Commission and the Joint Board to adopt regulations that would require periodic review to ensure that there is full equity in the availability of telecommunication services as technology advances.

Respectfully submitted,

Enola G. Aird
Acting Director
Black Community Crusade for Children