I am posting my own ideas here, not acting as moderator.
To further stimulate your interest in what the FCC and Joint Board
will do (as well as to stimulate heated debate) I've decided to post
some very rough thoughts that I jotted down after reading the Notice
of Proposed Rulemaking and Order Establishing Joint Board. I am
exploring the possibility of getting CPSR to write a comment based on
these notes.
Craig Johnson pointed out that this round of comments is only a first
stage. This FCC notice just establishes a board to deal with
implementing universal service; more important interventions can come
when the board actually is formed and starts to meet.
Paragraph 4 of the FCC notice explains that the concept of
"affordable" is new in universal service objectives and says,
We seek comment on whether there are appropriate measures that
could help us assess whether "affordable" service is being
provided to all Americans.
Paragraph 57 returns to the issue of what new services should be
offered to low-income consumers. We could point out here that the
most socially valuable information is in text form, which is very
low-bandwidth compared to video offerings being considered by
companies. Therefore, a way should be found to make text
transmissions (such as email, downloading schedules from a community
bulletin board, etc.) so low-cost so as to have almost no incremental
cost to consumers who possess the equipment to do the downloading. We
should perhaps address this equipment too. In any case, it should be
a high priority to ensure that providers cannot impose a minimum
charge per transmission or some other pricing structure that
effectively makes it costly to do a small email message or text
download. (Thanks to Richard K. Moore for pointing out this danger.)
We have to show that our proposal "is consistent with the public
interest, convenience, and necessity."
Paragraphs 5 and 6 talk about making advanced telecommunications
available to "all regions of the Nation" and to "rural, insular, and
high-cost areas." Paragraph 17 asks for services that should be
considered universal. Here perhaps we could introduce wireless
transmissions and the idea of setting apart part of the high-frequency
spectrum for public use. We have to explain why this should be
universally available and how it could be implemented. Wireless is
specifically mentioned as a possible solution to providing schools and
libraries with network access in paragraph 81. Also, the FCC has
responded positively to the Apple petition to set aside part of the
spectrum for public wireless networks, although only 10 Megahertz were
set aside.
Paragraph 8 asks, "We invite interested parties to propose additional
principles relevant to the choice of services that should receive
universal service support." One principle we should stress is that of
two-way communication. The bandwidth going out of the home does not
necessarily have to support video transmissions, but it should at
least allow email. What should be avoided is a rigid system that
allows video on demand to come in, but only a tiny set of user
commands to go out.
It is not presumptuous to suggest Internet access (full connection for
Web access, etc.) as a goal of universal service. We should point out
the television is a potential medium for providing Internet service,
and point to the V-chip as a proof of concept. (The V-chip, which is
meant to monitor and screen out violent programs, is a digital
transmission channel.) If the television industry can design a
digital channel for this narrow purpose, they should be able to work
toward more general Internet access (although a user interface needs
to be added). Thanks to Arun Mehta for this intriguing observation.
Another important criterion is the assurance that all information
providers have access to channels used for universal service--that the
facilities provider cannot censor content or discourage competition in
order to favor its own content.
For sections IV and V, I have trouble suggesting what minimum
requirements should be made for educational institutions and health
care facilities. My gut-level reaction is to suggest that money from
the universal service fund be set aside to raise teacher wages, create
smaller class sizes, and provide universal health coverage! Back to
reality, all that the law provides for is discounts, apparently, but
the FCC asks for additional measures that it could take.
Internet access should certainly be an advanced service that should be
offered to all schools and health care providers.
Strangely, while the Telecom Bill contains a whole section on access
by persons with disabilities, the FCC's notice does not mention this
aspect of service (maybe they don't consider it to fall within the
definition of universal service). It may still be worth submitting a
comment on the disabled. A big problem is emerging with the
popularity of clickable graphics on the Web, which exclude both blind
people and those who have trouble manipulating a mouse.
We should probably also develop guidelines for section D, ensuring
that standards for universal service evolve over time to fit changes
in network usage.
I don't have any particular interest in Curtiss Priest's campaign to
make the Universal Service board contain a representative from each
state.
Andy
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Posted by Andrew Oram - •••@••.••• - Moderator: CYBER-RIGHTS (CPSR)
Cyber-Rights: http://www.cpsr.org/cpsr/nii/cyber-rights/
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CyberJournal: (WWW or FTP) --> ftp://ftp.iol.ie/users/rkmoore
Materials may be reposted in their _entirety_ for non-commercial use.
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