Summary: EDLINC Further Comments

Contributed by: Christine Rademan <cradema@libby.litchpkeld.k12.az.us>
Date: Sun, 22 Sep 1996 18:09:05 +0000

The Coalition answers questions and elaborates on its plan for the implementation of universal service.

It believes that the fairest way to ensure affordable rates for schools and libraries is to establish a national competitive benchmark rate as the basis for discounted price; assuring all users of a competitive rate, even where no competition exists.

The Coalition argues that all services or functionalities should be eligible for discounts. It argues that Section 254(h) in conjunction with Section 254(c)(3) make internal connections to classrooms eligible for universal service support.

It supports competitive bids from service providers, discounted rates that continue to support longterm use of telecommunications services, community consortia, and narrow construction of the resale prohibition to encourage growth of new networks and aggregation of purchasing power.

It argues that existing legislation regulating procurement procedures provide enough protection against misuse of funds, so no further administrative bureaucracy needs to be developed.

It proposes a method of calculating discounts varying from 30%-70%.

It opposes industry efforts to develop a final model as likely to cause unnecessary delay. "We believe that the industry has an incentive to delay the process, both to reduce any perceived long-term harm to the industry arising out of the new universal service requirements, and to give it time to develop a regulatory structure that favors the industry's interests." (Further Comments 8-2-96 p.18)


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