JOHN E. CAWTHORNE
VICE PRESIDENT FOR EDUCATION
106 CAMPION HALL.
Voice 617/552-4265
Fax 617/552-8419
Electronic john.cawthorne@BC.EDU
May 7, 1996
CC Docket Number: 96-45
To Members of the Joint Board
Federal Communications Commission
On behalf of the National Urban League and its 114 affiliates in 34 states, I am writing to comment on the "Special Services" under 254(c) (3) and (h) and to suggest that the Commission be proactive in characterizing additional "special services" for schools and libraries. I wish to make two points: 1) that the definition of "special services." be broad enough to encompass on going changes in the technology, and 2) that all schools and libraries have access to "state of the art" technology as it evolves.
It is critical that. the Commission interpret the "special services" section to include all telecommunications that are currently available to the most advanced schools and libraries. The Urban League, representing clients in some of the most financially strapped cities in the country, wants to emphasize the importance of ensuring that the poorest citizens in those districts always have access to whatever the most technologically advanced schools and libraries possess. Otherwise, poor urban and rural schools and libraries will always lag behind the more advanced ones, and their children, and the country as a whole, will suffer.
The National Urban League believes that a broad definition of "special services" should be evolutionary rather than static. To rigidly define hardware and broad band external connections in terms of today's technology will not allow poorer school districts to keep pace with their more affluent competitors as the definition of "state of the art" evolves. We, further, believe that the proposal to connect schools externally but not internally unnecessarily limits their capacity to grow. We believe that all schools need the capacity connected internally and to external resources. For these reasons. we believe that "special services" should be emphasize capacity rather than function--that is, the regulations should stress what schools and libraries are able to do rather than how they will use the new technologies.
The National Urban League requests that schools and libraries be charged for such services based either on their ability to pay or other mechanisms that ensure that all "special services" are available to all. Such a "sliding scale" fee structure would ensure that no child and no community would have either an advantage or a disadvantage due to the size of its tax base or the wealth of its citizens.
As the Commission thinks about how to select providers of "special services" it should consider as one criterion the proposed provider's willingness to provide discounted rates (and in some cases "scholarships") for those districts most challenged economically. Such a provision would not only enrich the poor districts but would serve businesses well, since it would open up whole new markets to the private sector.
As a nation, we cannot and we date not deprive large numbers of our citizens of the emerging technology simply because of where they live. It is in the best spirit of this country, that all schools and libraries have access to "state of the art" technology--that all schools and libraries support common and evolving standards of what every community must have in order to be competitive within this nation and with other nations.
The National Urban League recommends the Joint Board adopt rules and regulations that ensure that all schools and libraries have access to the broadest range of services at prices that are affordable to all.
Please include this letter in the formal recording of the record.
For more information contact:
John E. Cawthorne
Vice President for Education
National Urban League
617-552-4076