Summary:
Comments of America's Public Television Stations (APTS)

Summary of Comments of America's Public Television Stations (APTS):

The APTS submitted comments on two main issues:
The Commission should adopt rules making it clear that--

1. Educational video services provided to elementary and secondary schools, libraries and rural health care providers, including interactive capabilities afforded by high-speed data links, qualify for discounted rates under Sec.254.
2. Consortiums of educational television stations that provide distance learning services to those facilities are eligible for discounted rates under the statute.

Reasoning: The noncommercial educational television stations provide a wealth of educational services, including video and on-line services as well as interactive capabilities, to their communities and fulfill a multitude of needs. Public TV stations reach millions of classrooms, workplaces, homes, agencies, child care providers, and share multiple resources with higher educational institutions, caretaking institutions, and government educational departments.

Knowledge beyond the scope of the meeting facility, whether a classroom or workplace, expands understanding and provides motivation and participant interaction through electronic field trips and two-way video conferencing. The limitations on technical facilities should not be written into the rules by the Commission because no one knows what the future holds for needs and opportunities in advanced telecommunications possibilities for educational services.

Summary of Further Comments by APTS and joined by PBS (Public Broadcasting Service):

The comments respond directly to questions 6 & 18.

Question 6 response: APTS and PBS believe that rules adopted to implement the universal service provisions of Sec. 254 should 1) not unnecessarily limit the services to be included for discounted rates, but instead allow eligible institutions to determine what services and facilities they need to accomplish their educational goals and provide a written certification to the telecommunications carrier that the requested facilities will be used for educational purposes; and 2) must include, as services eligible for discounted rates, the educational services offered by PBS and public television stations, including consortiums of educational stations that provide distance learning services to educational facilities, interactive video, and on-line services.

Question 18 response: APTS and PBS provided information regarding discounted educational telecommunications services currently provided by state public television networks to schools, state agencies, and health care facilities. These entities expand the opportunities throughout the state at substantial savings in cost and time; however, only a handful of states support these networks. Most schools, state agencies, libraries, and health care facilities do not have access to such services as provided by state networks.

The universal service rules would allow these places to also have access to the educational opportunities of telecommunications and would expand and enhance the state networks currently operating services.

Their report includes many examples of measurable outcomes, cost-saving factors, efficiency of staff resources, expanded curriculum for classrooms of all ages and needs from K-12 to in-service training of all walks of life.