Summary:
Comments of the Benton Foundation

Summary

The Benton Foundation offers comments regarding the Common Carrier Bureau's Public Notice on universal service.

• Using Census Bureau statistics from November 1994, Benton finds that basic services included within the definition of universal service are not affordable to all and therefore should not be the baseline for affordability at present. In households with incomes below $30,000 Ð over 53 percent of all households in America Ð telephone subscribership can represent too much of the family's earnings to bear.
• Percentage of income and other "non-rate" factors are critical when determining affordability. When the cost of basic telephone service drops below one percent of household income, the penetration rate begins to exceed 90%. About 99% of all households choose to have basic telephone service when rates fall below .7% of annual household income.
• Discounts and support for schools, libraries, and health care providers should be structured to allow the greatest range of choice to the public institution. The decisions concerning what services and functionalities are needed in these areas should be left to professionals in these relevant fields, not telecommunications regulators.
• In Section 254(h) of the Telecommunications Act, it is the plain intent of Congress to connect classrooms, not just to reach the school house door. For the intent of Congress to be met, the inside wiring should be supported as part of the universal service mechanism.
• Sections 706 and 708 are important legislative steps towards facilitating the goals of advanced telecommunications access to all Americans and equal learning opportunities for America's school children. The fulfillment of these goals set forth in Sections 706 and 708, however, relies on the successful implementation of 254 (h). As such, the provisions of 706 and 708 are important elements but cannot be relied upon to provide advanced services in the absence of a successful conclusion of this Joint Board's work in establishing underlying connections.
• The Commission should narrowly construe the legislative prohibition on the resale of telecommunications services by public institutions so as, for example, to permit end-user cost based fees for services.
• Most states have programs to provide telecommunication services to schools and some have extended services to libraries and health care providers. In order to support use of these services, some states have offered additional discounts to institutions using these facilities. Attached as Appendix II to this filing is an overview of state strategies for connecting schools, which take many different forms.