Universal Service/Network Democracy
Week One (August 26 - September 1)


Discussions in the first week of the Universal Service/Network Democracy on-line seminar will deal with the following topics:

The sections which follow contain information on these subjects and suggestions on how seminar participants can work together to develop these topics and help provide useful input to the Federal Communications Commission as it works to implement the Telecommunications Act.


Preliminaries

If you have not yet read the page on Preliminaries to the Universal Service/Network Democracy on-line seminar, please read it now. The Preliminaries page contains information on the following items:


The Telecommunications Act of 1996

The Universal Service/Network Democracy on-line seminar deals with the provisions of the Telecommunications Act of 1996 which provide possible support for the telecommunications needs of schools and libraries. The seminar brings together teachers and librarians with direct experience in the educational applications of telecommunications, people associated with the businesses who provide telecommunications services and government staff working in the areas of education and telecommunications. Through the seminar it may be possible to shape the implementation of those provisions of the Act which affect schools and libraries in such a way as to maximize the educational benefits of the new law.

There are three broad areas that will be covered in the seminar:

Seminar participants bring expertise relevant to all these areas, and the goal of our on-line discussions will be to share this expertise.

The information given on this Web page is meant to provide a framework for further discussion on-line. Through the on-line discussion we will be able to sharpen our focus and cover in a adequate manner the broad set of issues which underly this debate.

Major Features of the Act

If we attempt to reduce a very complex topic to a few sentences, we could describe the Telecommunications Act of 1996 as having the following two major features: In essence, the competitive and Universal Service aspects of the law attempt to strike a balance between the desire to provide a free market economy for telecommunications services while preserving some notion of equity or universal access to these services.

Implementation Schedule

When the Telecommunications Act was signed into law earlier this year, it set in motion a series of activities to implement the Act through the development of a set of rules. The official calendar for these activities is maintained at the Federal Communication Commission's Web site. A summary of the dates relevant for the present discussion is as follows:
February 8, 1996: Enactment of the Telecommunications Act
The Act involves many more issues than Universal Service. We will touch on some of them in the seminar, but in the timetable which follows we list only those dates which realate directly to Universal Service provisions for schools and libraries.

March, 1996: Appointment of the Federal/State Joint Board.
This Board is charged with making recommendations to the FCC on the content of its rule for Universal Service.

March 8, 1996: Notice of Proposed Rule Making (NPRM).
This notice provided a running commentary on the Telecommunications Act with specific questions on items that require clarification for the FCC to develop its rules on Universal Service.

April 12, 1996: Public Comments to NPRM are due.
Public Comments, limited to 25 pages in length, could be submitted by any parties interested in participating in the rule making process. Traditionally such Comments have been available at the FCC's reference room in Washington. Through the efforts of Information Renaissance, this material is now available on-line.

May 8, 1996: Reply Comments to NPRM are due.
Public Reply Comments, issued in response to the original Comments received by the FCC, were to be filed by this date. This material is also available on-line.

July 3, 1996: Request for Further Comments.
The FCC published a list of 72 specific questions relating to areas of the Universal Service discussion which had not been adequately addressed by previous respondents.

August 2, 1996: Further Comments are due.
This material is currently being processed by Information Renaissance and will be made available on-line during the next week.

November 8, 1996: Report of the Joint Board to the FCC is due.
At this point the FCC will be able to begin drafting of its rules to implement the Universal Service provisions of the Telecommunications Act. There will follow another round of Comments and Reply Comments, which will be of crucial importance in shaping the final rules.

May 8, 1997: FCC shall implement recommendations of the Joint Board.

As you can see, the present seminar is placed at a critical time relative to the activities of the Joint Board. Although the seminar is taking place too late for participants who have not already done so to be able to file formal Comments, Reply Comments or Further Comments. There remain, however, many avenues through which the public can communicate with FCC staff. These include:

Informal Comments.
These can be sent to the FCC by e-mail or post.

Ex Parte Presentations.
You can request an appointment with FCC staff to present your views in person, or you can submit material for inclusion in the Universal Service docket.

Participation in this seminar.
The entire proceedings on this on-line seminar will be filed by Information Renaissance as an ex parte presentation to the FCC. Hence all of your remarks in this seminar will find their way into the official record. Equally importantly, both FCC staff and representatives of organizations which have been participating in the rule making process will be participating in this seminar. This makes the seminar an easy entree into the process.

Universal Service Provisions for Schools and Libraries

Traditionally, the Universal Service Fund has existed to help equalize the charges for telecommunications services experienced by customers in different regions of the country. Through this fund, customers in regions with intrinsically high costs, such as rural areas, have their telecommunications services subsidized by the Fund. The Fund is circular in nature, in that the same telecommunications providers will typically contribute to the fund and draw from the fund.

The Telecommunications Act of 1996 mandates that the concept of Universal Service should be extended to provide support for the telecommunications needs of schools and libraries. A brief summary of the provisions of Section 254 of the Telecom Act has been provided by one of our seminar participants. This summary encapuslates some of the language of the Act and some of the procedures by which these provisions of the Act are to be implemented.


Participants' Summaries

There has been an enormous amount of material submitted to the FCC as part of the Universal Service discussion. While it is almost impossible for any single person to read through al 15,000 pages of these submissions, the Universal Service/Network Democracy has hundreds of participants who can divide this task, making it a practical effort for us to approach.

Although the total volume of submissions on this topic has been very large, it's important to note that the provisions for schools and libraries represent only a small fraction of the topics under discussion. Hence there is a need to dig out those portions of the material submitted to the FCC which are actually relevant to the needs of schools and libraries. Here, too, it's useful to have many people available to share the task. If we can distill the information submitted to the FCC into more manageable chunks, we will be able to share the results and use this information more effectively.

With this in mind, I would like to propose the following assignment to all seminar participants:

  1. Pick Comments, Reply Comments or Further Comments that have been submitted by groups which relate most directly to your concerns. You can make your choice based upon geography (by picking a service provider in your region), association (by picking an organization of which you are a member) and randomly. An index of available material is accessible at this site.
  2. Read the items you have chosen with an eye toward their applicability to the needs of schools and libraries.
  3. Prepare a brief summary of what you have read and send it to library@info-ren.org for inclusion in the Universal Service/Network Democracy Web site.

Topics for the Following Weeks

There is a broad range of topics which we can choose to explore in the upcoming five weeks. Given the interactive nature of the medium in which we are working, I prefer not to fix a rigid syllabus for the seminar in advance. Rather, I would like to let the participants help select which topics we will cover in the next few weeks. Hence I am making the following assignment:

As an example of possible topics, I have put together the following list. This reflects my own interests, and topics which others have pointed out as ones that are important to consider. If your suggestion simply endorses some of these points, that's fine, but feel free to add whatever topics you feel are most important for us to take up.

Scope of Universal Service subsidies for schools and libraries
Should they simply cover connectivity to the buildings, or should they include other aspects of telecommunications services? Specifically, should they cover such items as in-house Local Area Networks, user devices or training?

What already exists?
Are there already special arrangements that schools and libraries have made with telecommunications providers in their areas which make it easier for schools and libraries to acquire needed telecommunications services? These could be discounts, bulk purchases, give-aways or other subsidies. It's important that new subsidies not be set up in such a way as accidentally to eliminate existing mechanisms that might serve schools and libraries better than the new subsidies. Alternatively, one might look to existing mechanisms which work well and should be included in the new FCC rules.

Present approaches to low-cost connectivity
Independent of any special discounts, subsidies or gifts, many school districts and library systems have found clever ways to gain access to advanced telecommunications services at low cost. By sharing this information, we will enable others to make use of it, and we will ensure that the underlying mechanisms will be included in new FCC rules. Otherwise there is a danger that new rules might undermine some of the mechanisms that have been used effectively in the past.

Flat rate versus metered pricing
It is my impression that Internet connectivity depends upon flat rate (untimed) pricing of the network connection. Is this true? To what extent is flat rate pricing currently available?

Unbundling
One facet of the sort of competition that the Telecommunications Act of 1996 seeks to promote is the unbundling of various telecommunications services. This allows purchasers of these services to look for the best provider in each category of service. To what extent is unbundling essential for schools and libraries? To what extent is it currently being used?

How should the subsidies be allocated?
Commenters on the NPRM have suggested a number of alternatives for dispensing funds from the Universal Service Fund for schools and libraries. These include discounts administered by the telecommunications carriers, cash grants or vouchers to individual schools or school districts, and block grants to states. Which is these mechanisms is likely to be the most efficient and the most effective?

What constitutes a bona fide request?
The NPRM and the Request for Further Comments raise the issue of what should constitute a bona fide for telecommunications services that should be eligible for a Universal Service subsidy. There exist a wide range of recommendations on this point - from requiring school districts to receive state approval for a technology plan which incorporates the requested services to simply having the request submitted by the school district's technology manager. This will be an important issue in the practical implementation of a Universal Service subsidy.

Advanced services for schools and libraries
An important part of the Telecommunications is contained in Section 706, which deals with the provision of "advanced services." This is a plausible mechanism for ensuring that schools and libraries will continue to be provided with telecommunications services comparable with those available to the business community and other institutional users.
If you are still looking for ideas, another good place to look is the FCC's Request for Further Comments, which contains 21 questions directly related to schools, libraries and health care providers.
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