The Alliance for Community Media (the "Alliance") respectfully submits the following reply comments in response to the Notice of Proposed Rulemaking, FCC 96-93, in the above-captioned proceeding, released March 8,1996 ("NPRM").. The Alliance reiterates the points presented in its initial comments, and emphasizes that provision of universal service to "at-risk" communities could have enormous impact on those communities' full participation in American society. The Commission should adopt only those recommendations of the Joint Board which guarantee that telecommunications services are provided to all American people including individuals and groups that may heretofore have been denied access to the benefits of both basic and advanced services. The Alliance urges the Commission to promote localism, equitable access, and encouragement of diversity in considering and adopting any recommendations of the Joint Board.
The Alliance's initial comments were filed in conjunction with two coalitions: one including People for the American Way, the Alliance for Communications Democracy, the Benton Foundation, the Center for Media Education, the League of United Latin American Citizens, the Minority Media Telecommunications Council, the National Council of La Raza, and the National Rainbow Coalition ("Joint Comments" and "Joint Commenters").; and a second with the Office of Communication of the United Church of Christ and the Minority Media and Telecommunications Council ("UCC Comments" and "UCC Commenters"). In these comments, the Alliance and its co-commenters emphasized the importance of providing access to telecommunication services to all regions and all sectors of American society, for purposes of economic development, job creation and civil discourse. The Alliance believes that community computing centers offer a sensible methodology for providing advanced services to communities which might not otherwise have these services.
[snip] (PEG access centers refers to public, educational and government access channels and centers for cable television - ed.)
During the past few years a number of PEG access centers have expanded their menu of offerings to include access to advanced telecommunications service, including Internet and on-line services. This expansion is in concordance with Alliance members' belief that Americans should not be mere passive consumers of information and entertainment, but active participants in political dialogue, local economic development, and artistic endeavor. The First Amendment requires that schools, churches, community organizations, and individuals have meaningful access to advanced forms of media as telecommunications become increasingly sophisticated -- and increasingly concentrated. Consequently, the Alliance supports implementation of universal service that provide for the expansion of First Amendment access rights, and that guarantee that non-commercial, non-profit, educational and public institutions share the benefits of advanced communications technology.
Section 254(b) of the Telecommunications Act of 1996 (47 U.S.C. [[section]] 254(b)) instructs the joint Board and the Commission to "base policies for the preservation and advancement of universal service" on a number of principles, including providing services to consumers in all regions of the Nation, additional services for elementary and secondary schools, libraries and health care providers and " [s]uch other principles as the joint Board and the Commission determine are necessary and appropriate for the protection of the public interest, convenience and necessity and are consistent with this Act." The Alliance believes that designating community computing centers to receive and offer special services similar to those provided pursuant to Section 254(h), would be an appropriate additional policy for the Joint Board and the Commission to promulgate, based on the principle that a range of institutions, not just libraries and schools, can offer meaningful opportunities for people who otherwise could not "get connected." Community computing centers serve much the same purpose as PEG access centers, and would have much of the same client base. And, as many centers are already expanding to include availability of, and training in the use of, computer and communications services, providing low-cost advanced services to PEG access centers would provide an efficient way to provide universal access to these services. This could potentially reach a population group, including a range of non-profit organizations, that may not be able to be reached by public libraries.
Community networks link computers of citizens, institutions, organizations and businesses to one another, providing information from a multitude of sources and two-way communications opportunities for all that are connected to it. Community computing centers can fulfill an important role in the future of video-voice-data convergence; integrated PEG-computing centers allow video programming, databases, and two way communication to support each other and provide a range of social and information services to the community. The Alliance believes that the joint Board, in considering how to serve a range of previously-excluded communities, should direct universal service funds to support these growing institutions that offer residents of a community meaningful opportunities for access and expression at minimal cost to service providers. Such centers will give meaningful additional services to low-income telephone subscribers in concordance with the Commission's expressed desire to provide low income services that are consistent with public interest, convenience, and necessity and will promote First Amendment values which ensure that every citizen can fully and equally participate in society.