Superintendent John Benson's Letter to the FCC on Universal Service

December 11, 1996

Office of the Secretary
Federal Communications Commission
Room 222
1919 M Street, N.W.
Washington, D.C. 20554.

RE: CC Docket No. 96-45.

Dear Commissioners:

As state superintendent I applaud the actions of the Federal-State Joint Board in recommending telecommunication rate support for our schools and public libraries as required by Section 254 of the Telecommunications Act of 1996 (PL104-104). The discounts will be a critical factor in insuring that our schools and libraries have the networking connectivity they need to help meet the challenges of the Information Age.

The Joint Board's decision to recommend that schools and libraries be allowed maximum flexibility to purchase whatever telecommunications services will meet their needs is a step in the right direction. Furthermore, I am pleased to see that the Joint Board has rejected the narrow interpretation that discounts only be applied to narrow "core" of telecommunication services or a set package of services. Schools and libraries should, as the Joint Board notes, be able to apply appropriate discounts to whatever telecommunication services best meets their needs. With the rapid pace of technological change the whole concept of "core" services or prepackaged services is out dated.

More specifically, I have made several suggestions below based on requested input from the Commission. The Commission asks for input on the following issues as part of its PUBLIC NOTICE [DA 96 1891] released on November 18, 1996

Principles. How should the additional principle of competitive neutrality be defined and applied within the context of universal service?

Any telecommunications services available commercially by tariff or through contract should be available to libraries and schools at the proposed discounts. Schools and libraries should have the ability to contract with a telecommunication provider that will give them the best value for the requested service. To promote competitive neutrality the Commission should move as soon as possible to open intrastate competition to any provider including entities which have not traditionally been viewed as telecommunication providers like cable carriers and electric utilities.

Schools/Libraries. What methods should the Commission use for identifying high cost areas for purposes of providing a greater discount to schools and libraries located in high cost areas? What measures of economic advantage may be readily available to identify economically disadvantaged non-public schools and economically disadvantaged libraries or, if none is readily available, what information could be required that would be minimally burdensome?

High cost areas are most often associated with smaller communities in rural areas. In addressing this, I suggest the Commission review census or school district data showing what percentage of a school district's student population comes from outside a municipality greater than 50,000 population. A similar type of measurement can be used for public libraries. That is, how many public libraries are in municipalities under 50,000 population. To eliminate school districts or libraries communities that are in smaller suburban, the Commission can look at an actual mileage figure. For example, in addition to the above criteria, it can further define high costs areas as being at least 10 miles from a municipality greater than 50,000 population.

For economically disadvantaged areas, I endorse the Joint Board's suggestion to look at the percentage of students eligible for subsidized lunches under the Title I program. For public libraries using both a measurement of per capita income and the level of per capita assessed evaluation of their service area will give a good indication of what libraries are located in economically depressed municipalities.

Finally, I would like to comment on section X. SCHOOLS AND LIBRARIES E. Restrictions Imposed on Schools and Libraries. I strongly endorse allowing consortia of schools and libraries to be eligible for the rate discounts. Many schools in Wisconsin are part of distance education networks and libraries are part of consortia offering computerized library systems. Allowing consortia to be eligible will make it easier for these groups to serve their constituents and also ease any burden that smaller schools and libraries may confront as they review the procedures and processes they must follow to take advantage of the reduced rates.

Thank you for this opportunity to respond to the recommendations from the Federal-State Joint Board. I look forward to the final rules when they are issued in May 1997.

Sincerely,

John T. Benson
State Superintendent

Go to the Wisconsin E-rate Update Page

December 11, 1996

For questions about this information, contact Robert F. Bocher (608) 266-2127

Last updated on 2/25/2008 9:05:59 AM