promotion, and other peripheral matters are absolutely essential in the creation and presentation of any worthwhile program. At the very least, the provisions of HR 3333 should be clarified to make clear that the funds made available to public broadcast stations may be utilized for all program-related activities. In the absence of such clarification, the public broadcast system may find itself in a position in which it cannot effectively utilize the generous funding provided by the bill. The present Community Service Grant example should be followed and, in order to accomplish the bill's ultimate objectives, the proportion of funding transmitted directly to the stations should be doubled.

6.

A National Non-Profit Corporate Entity
Should be Preserved with Responsibility
for the Overall Development of Public
Telecommunications

The need for national coordination and planning

of public telecommunications services will surely be increased in the future with the advent of and reliance upon the new techniques which our technology is making available. The present bill limits the function of the national funding entity to the provision of funds solely for program production and acquisition. OETNC sincerely believes that a federal entity should exist charged with responsibility for coordinating and directing development of public telecommunications policy, a feature which the present legislation does not provide.

7.

Federal Support for Facility Expansion

and Improvement Should be Continued During
this Period of Rapid Technological Change

The present facilities funding program will terminate in a few years in the absence of legislation to continue it. The cooperative effort between the federal government and local governmental and non-governmental sources which has resulted in the creation of the existing public broadcasting system should not be abandoned. Even if it were only a matter of maintenance and replacement of facilities which are rapidly becoming worn or obsolete, this program should be continued. It is all the more required, however, in light

of the new emphasis on technological development of delivery systems other than broadcasting. The federal-local partnership which has resulted in our present broadcasting system is even more essential for the creation and development of a broader system based on new and developing methods for transmitting information.

It is hoped that these comments will prove helpful to the deliberations of the Subcommittee. They are submitted with a sincere desire to support and aid the Subcommittee in its deliberations.