In the Matter of

April 4, 2000

Introduction

The Alliance for Public Technology ("APT") submits the following reply comments in response to views expressed on the Commission's Notice of Inquiry1 for its review of the deployment of advanced telecommunications services to all Americans. Among the comments, two recurring issues are of particular concern to the Alliance: the standards for two-way transmission speed; and the state of deployment for advanced telecommunications capability. While the comments express divergent viewpoints on the status of deployment, most of them reflect the competitive interests of the telecommunications industry. APT, however, offers a unique perspective on behalf of the broad diversity of consumers who comprise its membership. They include, for example: rural and urban residents; older Americans; ethnic and racial minorities; low-income and working families; health care providers; educators; people with disabilities; and small business owners.

A leading proponent of equitable access to advanced telecommunications capability, the non-profit organizations and individuals represented by APT have as a unifying purpose:

to make available as far as possible, to all people of the United States, regardless of race, color, national origin, income, residence in rural or urban area, or disability, high capacity two-way communications networks capable of enabling users to originate and receive affordable and accessible high quality voice, data, graphics, video and other types of telecommunications services.2

II. Discussion of "advanced telecommunications capability"

Some commenters have argued that advanced telecommunications capability should be redefined to include slower upstream speeds. To the contrary, the Alliance has always advocated for high capacity communications networks in both directions, not for entertainment or shopping, but for life-enhancing applications, such as education and training, social services and health care. Not only do these current applications require high speed networks in both directions, but "there is no way to predict how far and how fast these technological innovations will proceed … as we enter the Internet 3 phase of development and applications."3

Therefore, the Commission's definition of advanced telecommunications capability should do more than "retain the symetric two-way minimum standard that is reflected in the current definition,"4 as the Public Utility Law Project ("PULP) suggests. It should, in fact, "be upgraded as Internet usage becomes more pervasive in the general population."5 Asymmetric standards would preclude the optimum benefits of the technology to those who have the most to gain. The challenge, as we have previously stated, is to "make the marketplace work for everyone."6

III. Discussion of advanced telecommunications capabilities deployment

While competition spawns an abundance of advanced services for lucrative markets, particularly large businesses, major segments of our population are being left behind.7 Numerous commenters, such as the Association for Local Telecommunications Services ("ALTS") have argued that "the market for advanced services is thriving,"8 and "proceeding even more rapidly than projected,"9 according to the National Cable Television Association. From APT's perspective, it appears that these associations are in a state of denial about how the marketplace really works, bypassing huge segments of our population. "Without market-oriented public policy incentives, major sectors of our society will always be left in the dust of the digital age."10 That is why APT has been advancing the need for the ubiquitous deployment of advanced telecommunications services throughout our nation, and "social compacts" as a strategy to implement 706 in connection with mergers.

APT commends the Commission for establishing the Federal-State Joint Conference on Advanced Services. It is imperative to continue these cooperative policy efforts in order to overcome the opportunity costs of R and D investments that direct product development to the high end of the market. Instead, these partnerships can nurture demand for advanced services in communities where carriers presume it does not exist at sufficient levels to warrant investment11 by (a) aggregating effective demand for community-based application and information technologies, and (b) building a strong "demand pull" base for advance infrastructure investments in the home.12 APT also welcomes the support the American Library Association (ALA) has indicated in its comments, as well as other community partners, for pooling the demand that will facilitate the development of appropriate applications and associated services and programs.13

IV. Conclusion

Early in its history, APT developed the concept of connecting each to all. That is, the network gains its value by having everyone connected. President Clinton is to be commended for leading the nation in efforts to conquer the digital divide and reach that goal. In meeting its obligations under Section 706, we urge the Commission to take compatible action. By adopting policies that build the capacity of community based organizations to provide market-driven incentives for infrastructure investment, we can link innovative applications of the advanced technologies to the needs and cultures of marginalized communities.

Respectfully submitted by,

Deborah Goldman
Chair, Public Policy Committee
Alliance for Public Technology
919 19th Street, NW, 9th Floor
Washington, DC 20006

2Principles for Implementing the Goal of Advanced Universal Service, Alliance for Public Technology, 1995 at p. 2.

3See Comments of the Alliance for Public Technology, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, March 20, 2000 at p. 4.

4See Comments of the Public Utility Law Project, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, at p. 6. 5Op. Cit.

6Ibid, p. 5

7Falling Through the Net: Defining the Digital Divide. National Telecommunications and Information Administration, Department of Commerce, July 8, 1999. 8See Comments of the Association for Local Telecommunications Services, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, March 20, 2000 at p. 3.

9See Comments of the National Cable Television Association, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, March 20, 2000 at p. 18.

10See Comments of the Alliance for Public Technology, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, March 20, 2000 at p. 5.

11Ibid.

12Alliance for Public Technology, September 14, 1998 Comments to the Federal Communications Commission, CC Docket No. 98-146, p. 5.

13See Comments of the American Library Association, In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, And Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, March 20, 2000 at p. 10.