================================================================= ALAWON Volume 5, Number 54 ISSN 1069-7799 August 16, 1996 American Library Association Washington Office Newsline In this issue: TELECOMMUNICATIONS: pt. 2 of 2 (120 lines) ALA FILES RESPONSES IN 3RD ROUND OF FCC UNIVERSAL SERVICE PROCEEDINGS FCC'S INTERCONNECTION RULEMAKING SUPPORTS "TELRIC" METHODOLOGY ________________________________________________________________ ALA FILES RESPONSES IN 3RD ROUND OF FCC UNIVERSAL SERVICE PROCEEDINGS TO SEEK DISCOUNTED TELECOMMUNICATIONS RATES FOR LIBRARIES In its continued efforts to advocate for discounted telecommunications rates for libraries, ALA prepared responses in a third round of the universal service proceedings (CC Docket No. 96-45) before the Federal Communications Commission (FCC). This is the latest opportunity to expand upon the various arguments ALA has made in previous steps in this proceeding before the FCC-Joint Board as the Board develops recommendations for the full FCC as part of its universal service rulemaking. NOTE: Please see the ALA web site for the full text of this third filing as well as ALA's original Comments and Reply Comments and more information about the FCC-Joint Board and the universal service proceeding. Direct your browser to: http://www.ala.org/oitp/uniserv.html ALA's Office of Information Technology Policy (OITP) and the Washington Office (WO) collaborated on the filing which was one of 75 submitted in this phase of the rulemaking. One FCC staffer has reported that of the 75 respondents, the single largest number of responses are from libraries and related library groups. This is a strong and effective response from the library community and ALA appreciates these grassroots efforts! Expanding in more detail on the key points made in the original ALA comments, ALA emphasized in its third filing the following in response to the specific questions asked by the FCC: 1. A broad definition of discounted services for libraries and schools which includes all telecommunications services available commercially by tariff or through contract. 2. Emphasis on the need to support high bandwidth, interactive, applications in libraries and schools. 3. Discount rates for telecommunications services that would be the lower of either a) the lowest price offered to any customer or b) a wholesale price or fair cost price that would be based on the "total service long run incremental cost" (TSLRIC). 4. Deeper discount support for libraries in rural, high cost, and low income areas to assure affordability. 5. Definitions of core universal services that support convenient and reliable residential access to networks such as the Internet and other online services. 6. Certification and eligibility requirements that are not onerous, provide accountability, and that include libraries and schools that participate in cooperative arrangements. ________________________________________________________________ FCC'S INTERCONNECTION RULEMAKING SUPPORTS "TELRIC" METHODOLOGY The FCC adopted the Interconnection rule at its meeting on August 1, 1996 paving the way for the states to open markets for local telephone service to competition. The Interconnection rule is important because ALA's discount proposals are based on a similar cost-based model, TSLRIC. ALA has urged the Commission to adopt TSLRIC for library and school discounts in the upcoming final Universal Service rulemaking which should be issued in May 1997. (See above.) Specifically, the FCC's interconnection rule directs states to use Total Element Long Run Incremental Cost (TELRIC) in determining the charges new entrants will pay to the local Bells in the event the parties cannot agree on prices among themselves. One FCC observer describes TELRIC as using "elements" or breaking down a "service" into separate components to determine the embedded costs. ALA has asked the FCC to adopt Total Service Long Run Incremental Cost (TSLRIC) as the discounted rate libraries and schools will pay for telecommunications services. (TSLRIC would consider a total service rather than its subset of elements.) Based on such a cost-based methodology deeper discounts could also be determined, under Universal Service, for rural, high cost and low income community applications. (Universal Service essentially means reducing or subsidizing rates to give greater access to telecommunications services to certain groups such as disadvantaged and now, for the first time, schools and libraries.) TELRIC and TSLRIC are very similar, both focusing on forward-looking economic costs. Both models also have in common the idea that the price prevailing in a fully competitive market (as predicted by economic theory) should be the starting point for deciding the actual rates users will pay. ALA has also recommended to the FCC in the Universal Service proceeding that the rates libraries pay should not exceed the fully competitive price as represented by TSLRIC. The Commission's adoption of TELRIC in the Interconnection rule provides a regulatory underpinning to ALA's position regarding Universal Service. For information on it at the FCC: Http://www.fcc.gov/interconnection/96325.html _________________________________________________________________ ALAWON is a free, irregular publication of the American Library Association Washington Office. To subscribe, send the message "subscribe ala-wo [your_firstname] [your_lastname]" to . ALAWON archives gopher.ala.org; select Washington Office Newsline. Web page HTTP://www.ala.org/alawashington.html. ALA Washington Office 202.628.8410 (V) 1301 Pennsylvania Ave., NW, #403 202.628.8419 (F) Washington, DC 20004-1701 Lynne E. Bradley, Editor Contributors: Andrew Magpantay All materials subject to copyright by the American Library Association may be reprinted or redistributed for noncommercial purposes with appropriate credits. =================================================================