SHLB Coalition Comments in the USF-ICC Transformation Proceeding (8/24/11)

Comments from the Schools, Health and Libraries Broadband (SHLB) Coalition (www.shlb.org) in response to the Federal Communication Commission's "Further Inquiry Into Certain Issues in the Universal Service-Intercarrier Compensation Transformation Proceeding" (August 24, 2011).

These comments speak to the needs of community anchor institutions to have "open, affordable, high-capacity broadband to provide all the essential educational and informational services that their communities demand, especially vulnerable and 'at-risk' populations." SHLB argues that, as the program is primarily supported by the general public, that in this reformation of the USF-ICC at least some of the funds should "support broadband to community anchor institutions that, by definition, are focused on serving the general public."

As such, SHLB notes that the "4 Mbps standard identified in this proceeding for residential consumers is far too low for most community anchor institutions" and that the FCC "should find that providing high-capacity broadband services to anchor institutions is a supported service under section 254 and should directly fund a portion of the costs of such deployment." The comments further state that federally funded broadband networks should be designed to locate high-capacity network nodes at community anchor institutions, and that these networks should be open to interconnection by other providers, so as to potentially extend deployment of network infrastructure.

The Coalition is dedicated to ensuring that each and every library, health care provider and school (including K-12 schools, colleges and universities) has robust, affordable, high-capacity, broadband connections. EDUCAUSE is a member of the SHLB Coalition.