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 )
)
REPLY COMMENTS OF THE
NATIONAL PUBLIC TELECOMPUTING NETWORK
The National Public Telecomputing Network ("NPTN"), by its attorneys,
respectfully submits these reply comments in connection with the
Commission's implementation of the "universal service" provisions of
Section 254 of the Telecommunications Act of 1996.[1] NPTN addresses in
particular the means for FCC achievement of the Act's goal of access to
advanced information services for all Americans, especially schools,
libraries, hospitals, and rural and underserved areas.
INTRODUCTION
Information service access, including the special needs of educational
and medical institutions and rural Americans, is a central concern of the
1996 Act. NPTN proposes a new model for meeting the universal service
mandates of the Act, centered on the role of community computer networks in
fostering the educational, cultural, and economic opportunity policies of
universal service.
NPTN submits that the FCC should establish a technology-neutral
universal service support mechanism focused not on funding
telecommunications or information service providers, but rather on funding
local nonprofit organizations creating community computer networks. This
approach better realizes the Jeffersonian ideals underlying the 1996 Act,
by empowering local organizations to decide and fulfill their own
information needs, while providing an electronic communications vehicle for
reintegrating citizens into the cultural, social and economic affairs of
their communities.
NPTN is a nonprofit organization dedicated to the development of
public-access community computer systems known as "Free-Nets.® Free-Nets
occupy a middle ground on the spectrum between commercial online services
(such as CompuServe or America Online) and individual computer bulletin
board services, or "BBSs." Free-Nets provide communities with public,
low-cost access to the Internet, but they are much more than "on ramps" to
the "information superhighway." Free-Nets are first and foremost local
systems, run by local people, using local resources to meet local
communications and economic needs.
This decentralized model for decision-making on information service
access methods and content is perfectly designed to meet the Act's
universal service requirements, and to achieve the Commission's traditional
communications policy goals of diversity and localism. It is also
consistent with the Act's requirements for an explicit, nondiscriminatory
system of universal service support mechanisms in a competitive
telecommunications marketplace. Community networks will create
concentrations of demand, providing substantial competitive incentives for
telecommunications carriers to develop low-cost, efficient communications
options for communities to use as their information infrastructures, and to
interconnect these community networks with each other across counties,
states and the entire world through the global Internet.
The most urgent requirement of today's plans for a National Information
Infrastructure is that no one's ability to be a full citizen in our
republic should be lessened by the rapid advances in technology.[2]
As a nation, America must ensure that over the coming decade all citizens have
public access to community computer systems, just as over the last
centuries we ensured that all citizens had public access to community
libraries. These 21st century community computer networks, like their
library antecedents, will provide people with affordable access to local,
national and international information resources and communications,
enabling them to function better as active members of their communities,
and in turn, as citizens of our nation, and the world. By adopting NPTN's
community network model, the Commission can thus meet the true economic and
informational opportunity ideals of universal service by facilitating the
development of local-oriented digital content and fostering a renew sense
of civic health and culture in an age of social disintegration, mass media
and interstate freeways.
I. NPTN AND COMMUNITY NETWORKS
NPTN is the parent organization to a growing family of "Free-Nets" --
on-line community computing systems -- throughout America and in many other
countries.[3] Free-Nets are multi-user, public access computer
networks with much of the power and sophistication
of commercial online services and Internet service providers. Yet each
system is locally owned and operated by a nonprofit, community-based
organization whose Board of Directors is made up of people active in local
community affairs. This community-based leadership ensures that each
Free-Net is driven by the information and communications needs of the local
environment, and tailors its technology and content to the informational
needs of the community it serves.
Free-Nets are dedicated to bringing the benefits of the "Information
Age" to as many people as possible at the lowest possible cost. Free-Nets
offer connectivity to the rich national and global resources of the
Internet, so that applications such as electronic mail, "distance learning"
and "telemedicine" can be made available to all subscribers, rural and
urban, as well as to all educational and medical institutions. But
Free-Nets are much more than simply "on-ramps" to the "information
superhighway." They are first and foremost local systems, run by local
people, using local resources, to meet local needs.
The Free-Net in each community thus helps recreate for the Information
Age the unifying and information functions historically served not only by
libraries, but also by village greens, town meetings and local newspapers.
Like these historical predecessors, Free-Nets are interactive in the best
sense: information is both generated onto and drawn off each Free-Net by
members of the community. The Free-Net becomes an additional medium
through which local citizens enhance their sense of community. Examples of
the type of information and services that can be found on these systems are
schedules for public transportation and adult education classes, job
opportunities, city legislation, school lunch menus, calendar of events,
homework help lines, advice from local professionals and tradespeople (from
auto mechanics to lawyers), library and police information, restaurant
listings, tourist attractions, motor vehicle renewals, health information,
business listings and advertisements, indexes to local newspapers, social
services information, and reports from members of Congress. In addition to
information services, community networks provide important, "virtual"
forums for residents to discuss local issues, including publicizing and
organizing local activities and bringing together local experts in various
fields with local students.
NPTN helps to bring Free-Net community computer systems online with
organizational and technical support, and welds them together into a common
framework. Free-Nets can also take advantage of high-quality
NPTN-generated information and communications services to supplement the
content the Free-Nets generate on their own. These features, known as
"CyberCasting"sm services, include information and communications features
in areas such as K-12 education, health and wellness, and local and
national government information services.
Under NPTN's leadership, more than 200 community-based Free-Nets have
been established since 1989.[4] These have included both Metropolitan
Information Networks (in communities of greater than 50,000 population) and
Rural Information Networks (in communities of less than 50,000
population).[5] Because they are premised on volunteerism, Free-Nets
are remarkably inexpensive to start and maintain. They typically have required
only $10,000 to $15,000 to launch, including the computing equipment and
suite of server software applications provided by NPTN. Free-Nets also
typically secure corporate and foundation sponsors to defray some or all of
their start-up and operational expenses.
II. THE NPTN COMMUNITY NETWORK PROPOSAL
The universal service provisions of the 1996 Act place great emphasis
on meeting the needs of America's educational and medical institutions for
access to advanced telecommunications and information services. The
Commission's mandate in Section 254(b)(6) of the Act[6] is that "Elementary
and secondary schools and classrooms, health care providers, and libraries
should have access to advanced telecommunications services." Section
254(h)(2)(a) of the Act specifically directs the Commission to craft
competitively neutral rules "to enhance, to the extent technically feasible
and economically reasonable, access to advanced telecommunications and
information services" for public and nonprofit K-12 schools and libraries.
Similar special universal service support mechanisms must be developed for
hospitals and for rural Americans.
The Commission's NPRM recognized that under the 1996 Act, the
historical universal service system needs to be restructured to serve the
new, competitive telecommunications environment. The era of monopoly
providers and homogeneous telecommunications needs is over. Modern
universal service policy must function in an environment of divergent
needs, of new technologies and of multiple providers, ranging from national
firms providing a range of services to niche and local providers serving
particular requirements.
A modern universal service policy must be competitively neutral and
technologically neutral, so that the market can determine -- and frequently
reconsider -- its choices of providers and technology. And a modern
universal service policy must also ensure that the benefits of the
Information Age are available to all Americans, rich and poor, urban and
rural. Our nation has understood for two centuries that an informed
citizenry is crucial to a strong republic, and that we have a national
obligation to ensure that equal information opportunity exists for all
citizens through community-based organizations like schools and libraries.
The Telecommunications Act of 1996 thus challenges the Commission to
conceive of the electronic libraries of the 21st Century: community-based
systems by which all citizens can have public access to the information
resources of the Internet. Fortunately, the technology is available to
accomplish this on a broad scale, at relatively low cost. NPTN's
leadership in development of community Free-Nets demonstrates that advanced
information service access can be made available to connect communities not
only with the wealth of information available on the Internet, but also
with local educational and medical institutions and businesses.
Free-Nets advance the goals of universal service directly, by offering
access to advanced information services on a public, low-cost basis for all
subscribers. And Free-Nets advance universal service by creating active
user communities across the country for which commercial telecommunications
providers compete to provide interconnectivity. Some commenters in this
proceeding have suggested that the Commission either defer decision on
information access for schools, libraries and hospitals, on the ground that
the market is changing too rapidly for the Commission to select specific
telecommunications services for universal service support, or that the FCC
should simply provide discounts for switched 56Kbps digital services to
schools.[7] Federally supported community networks are superior to
both these alternatives, because the Commission would defer to local nonprofit
organizations to select the optimal telecommunications services needed to
support their network infrastructure, and local needs would drive the
market for advanced information services.
With a pool of local capital available for information access,
communities themselves would be empowered to determine the most
cost-efficient means of making information services available to their
citizens and educational and medical institutions. Telecommunications
carriers, in turn, would have a clear business incentive to develop
cost-effective, broadband services for local community information access
requirements. And all of this could be accomplished without the
inflexibility arising from uniform national requirements for information
access in the rapidly changing telecommunications and Internet market
environments.
The Internet is organized with a similar decentralized, "bottom-up"
structure precisely because the access and interconnectivity requirements
for individual computer networks are a function of their own unique mix of
computing, telecommunications and economic resources. The FCC can ignore
this well-functioning model for information access only at the risk of
making premature or rigid technology choices. The better approach to the
information service access requirements of the Act is to avoid selecting
specific services or technologies for universal service support, instead
creating a structure under those decisions can be made on a decentralized
basis.
In this light, NPTN proposes that the FCC implement the Act's
requirement of universal information access for schools, libraries,
hospitals and rural and underserved areas by adopting a "community network"
model for universal service. What is needed is simply a mechanism to
provide federal funding to serve as "seed money" for establishing community
networks. As Ameritech points out:
Ameritech Comments at 21; accord, Information Technology Industry Council
Comments at 11. Thus, rather than providing universal service support
payments to telecommunications carriers, the FCC should instead make a
portion of these funds available directly to community-based organizations
dedicated to the creation of local information service networks.
Under this universal service model, each qualifying community network
would be required to provide free or low-cost access for all schools,
libraries and hospitals serving the relevant geographic area, and
subsidized access rates for low-income citizens. In this way, the
Commission would help achieve the Act's universal service mandates with a
system optimized for the unique informational needs of every community and
avoid the difficult, and perhaps impossible, task of creating national
information access standards for schools, libraries and hospitals.
NPTN proposes that the FCC establish a nonprofit organization, to be
known as the "Corporation for Community Networks," to screen applications
for federal seed money for community network projects. This organization
would be made up of volunteers chosen for diverse expertise in such fields
as education, computing, online services, and community service
organization. To qualify for federal funding, a community network
applicant would have to meet these criteria:
1. Local Participation. The applicant would have to be a nonprofit
organization, representative of its community, with sufficient expertise
and capacity to establish a community network and attract volunteers to
develop local content. This local participation will ensure that the
information service and access needs of the community are addressed,
without any need for the FCC to involve itself in determining either the
needs themselves or how they best can be satisfied.
2. Information Access. The applicant would have to demonstrate that
it will provide significant local content, the nature of which is
determined by the requirements of the community, as well as access to the
broader resources of the Internet. Once again, the FCC would merely have
to determine that the nonprofit applicant is organized to determine the
locally required scope of information access, and is competent to procure
the telecommunications services and information content necessary to met
community needs. The applicant must of course accept oversight
responsibility to insure that the project fulfills its mission and intent,
and that the federal funds, as well as all other financial resources, are
used for their intended purpose.
3. Open Access. The applicant would have to demonstrate that it will
provide dial-up access through a local call, free or low-cost access to
the community network at all area schools, libraries, and hospitals, and
access through public terminals and sites available to all residents,
including low-income and senior citizens.[8] This is one crucial facet of
universality, making physical access available to all citizens.
4. Training and Support. The applicant would have to demonstrate that
it will provide volunteer-based training and support. This is another key
facet of universality. Physical access to the Internet and information
services is meaningless unless people can competently use the technology to
meet their communication and informational needs. Training and support
will be key to
making universal access a reality. Computer-literate volunteers, including
students, will provide valuable community service, while building bonds
among diverse groups in the community.
III. COMMUNITY NETWORKS WILL BEST ACCOMPLISH
Community networks will be organized and run at the local level.
The FCC's involvement will be limited to providing seed money to a
competent nonprofit community organization. The result will be local
networks that serve as bridges among citizens, bringing them together as a
"community online" -- not just another "online community" -- as well as
linking them to the international "virtual" community of the Internet. The
technology and telecommunications service decisions, as well as the content
decisions, will be the result of local environment and local needs.
This model of federal funding but local decision-making will achieve
the true meaning of "universal service" in the Information Age. Whether on
a dial-up basis from their homes, from a terminal in their schools or
libraries, or from a public access site, citizens will be able to share
their community life as they once did in formal town meetings or informal
meetings on the village green, and to find even richer and more varied
sources of information than in libraries. This model will also stimulate
technological innovation and price competition among telecommunications
firms vying to serve these active user groups.
People will no doubt use these community networks to look for goods and
services they desire, ranging from baby sitters to new homes. Local
businesses will be able to make and modify announcements of their goods and
services, as well as available jobs, easily and inexpensively. People will
also use community networks to exchange ideas about personal and community
issues, allowing the same kind of easy and wide discussion and interaction
on community issues that the Internet now allows for a vast range of
interest groups. Community networks will serve as a forum for ongoing
"electronic town meetings" available to all citizens, conditioned only on
their willingness to participate.
In a very real sense, NPTN's community network proposal can serve as
the means for establishing a "critical mass" of electronically connected
Americans. The Act's information service access goals, like the special
provisions on educational and medical institutions, exist not just to
facilitate the widespread deployment of advanced telecommunications
technologies, but to encourage a new era of informational opportunity for
all Americans. Technology alone is useless unless it is coupled with both
content and usability. By funding community Free-Nets, the Commission can
spur the development of local-oriented information resources, assist in the
creation of community-based, user-supported training programs, and foster a
new sense of digital community that counter-balances the divisive social
effects of urban sprawl, family disintegration and neighborhoods in which
neighbors no longer know each other. These content and community
objectives are not ancillary to the Act's universal service provisions:
they are the very reasons universal information service access is vital for
21st century America.
CONCLUSION
The Commission has a unique opportunity to achieve the universal
service requirements of the 1996 Act with a system for funding locally
based public information access. Adoption of NPTN's community network
proposal would assure access to advanced information services for schools,
libraries, hospitals, and rural and underserved areas, further traditional
FCC policy objectives of localism and diversity, and encourage integration
of individual citizens with their local-and national-communities. Funding
universal service through community networks would in addition provide a
competitively and technology-neutral vehicle for achieving universal
participation for all Americans, regardless of income level or geographic
location, in the National Information Infrastructure.
Respectfully submitted,
Dated: May 7, 1996
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TRUE UNIVERSAL SERVICE FOR THE INFORMATION AGE
By:________________________________
Jeffrey Blumenfeld
Glenn B. Manishin
Blumenfeld & Cohen - Technology Law Group
http://www.technologylaw.com/techlaw
1615 M Street, N.W. , Suite 700
Washington, DC 20036
202.955.6300
Attorneys for the National Public
Telecomputing Network
FOOTNOTES:
Founded by Dr. Tom Grundner in 1986, the Cleveland Free-Net was the
first community computer network. It grew out of an experimental bulletin
board called "St. Silicon's Hospital and Information Dispensary" which
tested the effectiveness of using telecomputing as a means of delivering
health information to the public. A person could leave a medically-related
question on the bulletin board and have it answered by a board-certified
family physician within 24 hours. The project was so successful that AT&T,
the Ohio Bell Telephone Company and the University Hospitals of Cleveland
donated funds to expand and develop the concept.
The Cleveland Free-Net system began with 10 telephone lines and
provided information in law, medicine, education, arts, sciences, and
government, as well as free electronic mail. A second phase of the system
opened in 1989 with larger memory and hard disk storage. The system now has
over 60,000 registered users. In 1989, Dr. Grundner went on to found NPTN.
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Last Modified November 2, 1996 John M. Kurilec jmk@nptn.org