Summary:
Joint Comments of People for the American Way,
Alliance for Community Media, & Others

Contributed by: Carl Kucharski <cski@tiac.net>
Date: Wed, 4 Sep 1996 20:41:18 -0400

Joint Comments of People for the American Way, Alliance for Community Media, Alliance for Communications Democracy, Benton Foundation, Center for Media Education, League of Latin American Citizens, Minority Media and Telecommunications Council, National Council of La Raza, and National Rainbow Coalition.

Table Of Contents
Summary ii
Preliminary Statement 1
I.Basic Telecommunications Services Are Essential To Ensure Full Citizen Participation In Society. 2
II.The New Universal Service Provisions Of The Telecommunications Act Expand Upon, But Do Not Replace, The Commission's Universal Service Goals Under The 1934 Communications Act. 5
III.The Commission Should Recognize The Importance of Institutional Access To Advanced Services. 7
IV.The Commission Should Broadly Construe The Universal Service Principles Of Section 254(B) Of The Telecommunications Act. 9
A.Quality Services At Just, Reasonable, And Affordable Rates. 9
B.Advanced Telecommunications And Information Services. 12
C.Low Income Consumers And Those In Rural, Insular, And High Cost Areas. 13
Conclusion 16

Summary

The decisions to be made in this proceeding have profound implications for the next century. They will set the foundation for citizen participation in democratic processes, the economic marketplace, and social and cultural activities of the information age. In a technological environment in which these services are increasingly essential for information, education, emergency services, and commerce, as well as communications, it is no exaggeration to say that full, equal, and affordable access to a broad range of telecommunications services is a birthright of citizenship.

The Commission and Joint Board must adopt rules which employ the principle that new technologies have become instrumental in promoting First Amendment values. Even more importantly, they must expressly define these policies as guideposts for future actions under the universal service provisions of the 1996 Act.

Technological advances have created new applications, such as telemedicine, data and file transfer, news services, chat rooms, electronic classrooms, and virtual malls, which go far beyond ordinary telephone service. This new conception of telecommunications supplants and enhances traditional views of speech. Citizens without access are citizens without voices and ears - they are unable to engage in these fundamental new forms of speech and new means to participate in society.

Furthermore, for every additional individual who gains access to telecommunications services and advanced services, the benefits are felt not just by that individual, but by society as a whole. Employers, government agencies, public institutions, private businesses, educators, family and friends, and many others benefit from greater accessibility to connected individuals.

Moreover, Congress made plain that the universal service provisions of the 1996 Telecommunications Act do not replace traditional universal service principles. Indeed, every provision of the 1996 Act builds upon these principles to broaden the types of services included and recipients covered.

Congress has taken a momentous first step in expanding the notion of universal service beyond residences to recognize the capacity of institutions, such as schools, libraries, community computing centers, and community media centers, in bringing new services and technologies to all Americans. The Joint Board and the Commission should follow this initiative by adopting an expansive list of services and support mechanisms for schools and libraries, and confirming the important role that all institutions have to play. However, they must make clear that in no way should the institutional availability of a particular service become an excuse for not eventually providing that service to homes.

Finally, only by adopting policies which embrace and build upon the guiding principles enunciated in the 1996 Act can the Commission create a just, comprehensive telecommunications system that will serve all Americans well into the next century.


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