National Association of Educational Broadcasters Convention Educational Broadcasting and the FCC, National Association of Educational Broadcasters

It's a pleasure for me to be associated with these that you see before you hear. Every remark. We renew our license next year but we have representation from the various. Communications Commission. And every one of these tremendous broadcasting and educational broadcasting. I'd like first to introduce. A distinguished educational broadcasting at the Federal Communications Commission Dr. Robert Hillyer. We got to say a few words about Austin first.

Just such a very nice place but I wish they would move their convention closer to the hotels of the hotels closer to the convention hall. My five o'clock shadow begins two o'clock in the morning after the night before because the show earlier and I steal as many of you do that would be nice. At this point we are in the hotel room. We often think of the government agency as a cold place. When I came to Washington all of three weeks ago I was a little concerned about what the relationships might be in this kind of a governmental bureaucratic situation. And I think that some of the fears that I might have very quickly dispelled what you see before you I think is rather where.

We have key thing our very first person to head up the educational broadcasting several years ago is not only still on speaking terms with Assistant Chief has us under his wing and Mike Parker the man as you know makes recommendations and allocations and applications but he's even willing to sit in close proximity with them so everything seems to be warm and happy. The Federal Communications Commission I'm looking forward to a very pleasant relationships. The very same factor that is the large and increasing number of educational broadcasting stations in the country that prompted the Federal Communications Commission to authorize an educational broadcasting branch in 1961. Prevents me in this new position from meeting with each and every one of you individually as I like to do.

I feel that the privilege of serving you through the FCC carries with it a responsibility that I certainly cannot discharge effectively without your assistance. The duties of this office are manifold. I think the ultimate purpose of a unified one to aid and facilitate the growth of educational broadcasting public interest. Commission Chairman he William and Ray has frequently indicated the importance of educational broadcasting and I think he's encouraged the work of the FCC in this regard and former chairman Hugh minnow in his recommendation that an educational broadcasting branch be established. Illustrated a number of areas of operation including the following. To study in conjunction with educational organizations immediate and long term needs for educational AM FM and TV frequencies as affected by social and technical

developments and to make recommendations as to present and future education requirements to compile information on and study trends in applications for educational stations. The factors encouraging or hindering the growth of new stations and the experience of stations in operation. To study the present commission rules and regulations governing educational broadcast services and to make recommendations as to revisions or additions as warranted. To analyze current commission application and report forms required to be filed by education applicants licensees to ascertain whether these forms are best suited to serving the need both of the commission and of the educational services to coordinate with and consult with other branches in the broadcast bureau concerned with processing of applications when the walls rule making and other activities involving educational brought Tate encourage

and develop the educational services to serve as liaison with the various educational broadcasting organizations in order to fully be fully apprised of their plans and activities in connection with the full utilization of educational broadcasting and to provide comprehensive information to such groups as to commission procedures forms rules and regulations affecting educational broadcasting. Those of you who may not remember having read it or who have forgotten what was in it I'd like to refer you to an issue of any journal that you sure show you have a round someplace. That of the May June 1962 issue in which I go an article called The new educational broadcasting branch which describes in some detail the purposes and policies. We in the educational but casting office. Hope you feel free.

We put a better way. I hope you will feel urged and encouraged to communicate with this office at any time with information problems plans suggestions that you think may be of value to us in our efforts in those various areas noted above or indeed in any pertinent area of educational broadcasting. Please feel free to direct any questions eating answers for facilitation of your operations. And at the same time we hope we can call on you and perhaps frequently for information and advice in our own studies and deliberation. As time goes by we hope to have an opportunity to visit each of you in your broadcasting situation observe and

learn and converse. We hope that any of you whenever you're in Washington please come up to our offices and see us and talk to us and let us know what you think we can do. The excellent work 13 is done during the past few years. Set a standard I think you'll be easy to duplicate so that it's only with your cooperation and help. But I think this office may be able to make the kinds of contributions to educational broadcasting. I feel that all of us by the very commitment and dedication to it you know play such a significant role in the advancement of human affairs in our society. Thank you. Thank you very much Bob I see that the distinguished gentleman from

California is here Larry wanted to come up and be the recorder this is Dr. Lawrence from our. I'm not saying why he got out but he recently got out of the out of the kitchen. Is now director or coordinator or whatever title they concoct for Educational Television for the state of California formerly chief of the education broadcasting branch of the FCC. This time it's my great pleasure to introduce Mr. McCarver Parker who is the supervisory electronics engineer rules and standards division of the FCC. And as Bob has said he is the gentleman who works out the allocations. He is the godfather in the commission. Twenty five hundred mega cycle. He has a delightful fund of stories and is really important avocation and life is a square dance caller.

We have more girls here to have a change isn't what I'm going to say. When we first were told we were coming down here it was my understanding this was going to be a question and answer period. And I find that in most of these sessions where there are talks and questions and answers there is more valuable information that you are really interested in elicited by the questions and answers rather than the talk and I really prefer to talk from notes but I'm reminded of this in my thing that when a one time when people were calling his gay days in college and he says You remember they used to call me breezy and she says no as I recall it they called you windy. So I thought I'd better write a note and kind of to hold myself down to a reasonable time so you will have sometimes the questions and answers and there are some afterthoughts I'm not going to use all of this either because most of you know I'm not really interested.

You have your individual problems and you're not too interested in the mix of how we get to these allocations but just enough to give me a rough idea. You know we are at the present time currently engaged in a revision of our allocation plan for UHF television and this was brought about because back in 1961 the NAACP your organization conducted a nationwide study to assess the needs of educational television for the next five to ten years. And they came up with an answer that indicated that you would need four times as many channels reserved for this purpose. You know if you had done an out table of assignment at the same time we were engaged in a program of trying to force the expanded use of television of the UHF television channel so that we could have a truly nationwide competitive system. Of commercial television stations and to determine how

these expanded needs of the educators would best fit into this overall program we had to make some assessment as to the total capacity of the UHF band. There are not any real mathematical laws that you can apply in making in an allocation plan because ideally if you wanted to get the most assignments out of the 70 channels you would lay out a triangular lattice grid so that every spot on there was exactly the same spacing the minimum spacing from other spots and then you would put as many channels as possible on each one of those points but unfortunately when the people settled this country they were more interested in transportation and access to all the communities and they were in television so they didn't ideally locate these communities and consequently our ideal plan has to be modified by economics in the case of commercial television and to some extent Educational Television other words we have to put the stations where the people are.

But we wanted to get a sort of a rough estimate of this capacity based on these modifying factors so we took exist then existing allocation and other projects internal information we saturated that is we took the list of places where the educators indicated they wanted channel assignments and added as many as possible because our then current plan was not saturated and then we juggle some other assignments just a few and we came up with it came up with the conclusion that we could for the most part meet the expanded needs. But the plan that we study we made was never intended really to be an assignment plan because there is a much better way of putting these channels together in various places and by simply speculating a plan that did not include these places. I might say here that it takes two engineers working experienced at this kind of thing working with maps and doing it manually approximately three

months to do a national assignment for the 70 UHF channels. And so we had spent a few months in this initial study and then we ran back and decided we had to stop and scratch and attempt to do a complete assignment plan using various approaches one to start with just the existing framework of stations and start from scratch another one would have been to even disregard the existing framework of stations assuming that we could if it became necessary asked them to change channels. We don't think this is a very good idea because it may cost as much as a hundred thousand dollars to change television channels and the commercial television stations operating at UHF would have difficulty and in making this additional investment and the educated groups would not. We would not want to put that sort of a financial burden on them. They have enough difficulty in convincing the holders of the

purse strings that. The initial investment is worthwhile but while we were engaged in the study the Congress enacted the legislation that made federal funds available for educational institutions and consequently there was suddenly a surge of interest in educational television and the commission and when I speak of the commission here I mean the seven commissioners put us under great pressure to come up quickly with an assignment. This is something that can't be done quickly but we felt that if we could get a proceeding underway where we could get meaningful comments from the people that were really interested in the NABJ original study was a birth there or a thing the availability of federal funds among other things I'd change the thinking somewhat. And by opening a proceeding we could get comments that would indicate to us how we could best approached the revised

idea of the station's channel should go in that connection I might say that we can talk in terms of we can yes put hundred thousand additional education reservations in the country but to pin it down exactly how are we going to do this we have to know the cities and communities where these channels should go. So to get this thing on the way we took a saturation study we made a little weighing a fair and a proposal realizing that it was not a particularly good assignment plan from an AC engineering standpoint but it would start appreciating it which interested people. And so I did have that effect as one of the things that came out of this was to organization again and contract with the Atlanta research people. I started a computer study of this approach to assignment plans and they work together with us closely and

setting up the criteria of the things that would be considered in in the places that you wanted to make this assignment. They worked out the computer plans themselves. We indicated to them to some extent the sort of priorities that would be given to these but out of the whole thing they did come up with a computer derived plan plan that came out and it was through our fault as much as they had weaknesses in it because they had chosen. In addition to the cities in which we speak in the commercial cities now and addition to the cities that we know that they will need to build television stations I want to build television stations. Some other smaller communities that have that came in already. I will say by accident and to explain what I mean by that is when we when we derive a national assignment plan we select certain of the communities both commercial and educational. We know there will be a need for television channels or

desired television channels and where an assignment is likely to be viable and after having satisfied those places on a channel by channel basis if you go back over this channel you'll find that there are areas in which another assignment is technically feasible. That is it'll meet the minimum separations but we haven't. There's no no community in that that that was on our original list as one of the most places so we examined that area and see if there is a community of any size. There are no people that would be served from a community in this area. To make it likely that at some time in the future the channel might be desired there. And if we do make an assignment in there that serves a dual purpose it does provide in effect a channel that held out in case there is an event and in a place where there may be a need but it also acts as a sort of a brace on the framework of assignment so that if you didn't have these braces it it's conceivable that the channels would

gravitate to the larger cities we might decide that New York City should have a total say of 10 assignments. And if we didn't put these braces around New York City then it might wind up with 12 13 or 14 assignments because somebody would want to build a station there like they would in some small town in New Jersey or Connecticut or the eastern part of New York. But the other thing that was a little disturbing about the computer plan was that before they had when they had done only one and by this planning was well conceived it didn't give us a real idea as to the capability of the computer because if it could have started with another planned set a different starting point marriage a criteria someone had thrown out the smaller cities then it might have come up with a better plan we can't hope to be able to go

originally was to have maybe a dozen different plans to choose from but the one planned it did show that the computer approach was a feasible one and furthermore an experiment that point so flaws in an approach may contribute as much as is just as valuable as an amount of thank is one that shows you that you were right in the first place. We found a couple of things that looked like we may have been on the wrong approach. Have been developed on the basis that if you have a city that needs a large number of assignments a large city then you should try to take care of that city first because this is going to be the most difficult place. The result of that approach often winds up that there may be a town that doesn't need very many assignments maybe only one but it's a very important one and you run out of assignments by taking taking care of the larger places first so you can find one

for that place again to just briefly explain the problem that's involved. Whenever we make an assignment to one community television channel particularly this has an impact on the availability of assignments in other communities. I say surrounding communities co-channel wise on the same channel. You were not able to duplicate this assignment from a hundred fifty five miles in what we call our zone one of the two hundred five miles an hour. That means that eliminates the chance in one community in all of the communities that are within these minimum distances on the same channel in addition to that we have what we call channels and these have to do primarily with the receiving equipment. Any mass produced receive is not as selective as it might be. There are certain problems with it if we could.

Television receivers like some of the military equipment on the contract you could solve these problems but very few people could afford to pay $20000 for television. So we have some 18 additional channels in addition to the channels that affect the availability of channel assignments in communities anywhere from 20 to 75 miles around. So this means that when you make assignments what we call availability is channels which might be assigned in other places are eliminated. We decided to explore the possibility of looking at this assignment plan and fundamentalist a new approach that is considered the most important places to take care of those talents are to be decided in advance needed in the assignment. But on the basis of the existing framework of assignments had only a few available assignments left and if we take care of those play places first then we will

assure that since we consider them important enough to warrant an assignment that we have done that before we provided the multiple channel assignments in the marketplaces. In this deciding whether the community is important and we are not overlooking the importance of your educational requirement. And it is in that area where your comments are most helpful if you if you have a statewide plan for example and you decide to stay quite covering can select specific locations to supply us. This is easier than picking a lot of locations where you may possibly want. But you may not in the final plans that you develop actually want to use all of these places because whenever we have this impact of one assignment affecting others it may make it

less possible for us to provide you with the channels that you need at the places we take care of. Important this blind approach of the computer and not being able to apply reasoning to these factors. In other words you tell a computer to do a certain thing and it will and has to be a yes or no answer. Sometimes we have and a manual assignment plan and we have certain criteria that says that it's a yes or no go and we have a special circumstance and we can mentally change. This is special we should not let the criteria in a computer. So we wanted to compete we wanted to take care of this priority of the assignments as we do manually by using

a computer and the way we were attacked by furnishing it will first determine all the places that we would like to have assignments educational and commercial and the number of assignments we want in those places. And then we'll break this list down into one two three four five part of the first part would be the places that we consider a must. We had these assignments run this through a computer and let it satisfy those places first and then take the second on a priority list and let it go through and do that sort of thing on a priority basis and maybe will not get all of the assignments we want on the second list. And when we go to the third unless we make it even fewer in approaching it that way we think that we can get you know the things that we call priorities and getting the places that we want to take care of first. We have having made this study of priorities and

this new approach to the computer plan we felt that this was the kind of thing that we could not. Do manually. I mentioned before that doing a conventional assignment plan with two engineers would take about three minutes nationwide if we go into it on this basis of one determining in advance which places have the fewest availabilities which means analyzing the potential available assignments at each place. In the beginning and determining how many channels are in that vailable for Simon each place and picking the one with the fewest and making that assignment and updating all of this information to cancel to eliminate assignments in other places it would be wiped out by the assignment we chose and then counting again to find out which place now has the fewest assignments. That's sort of the process would probably take two and a year to do just one assignment. We don't have that sort of time unfortunately.

Again your and your in a big experiment indicated the feasibility of using a computer and it can do things fast much faster than we can do most of our time is a matter of fact and plan is remember where Poland is on the map. We put it down and then we make the assortment than we assess the distance to all the other places around and we do something else and we come back. It was somewhere over here and we have to look. So I would venture to say a large part of that time is used in looking up places on the map with a computer as instantaneous recall on this type of thing. So we contacted the University people that we have a unified theory of commission and they developed a computer plan for US bases the approach we wanted and they developed a plan for where the computer can do it in five hours. The thing that it would take us a year to do two engineers working so that you know makes this approach feasible. One other part

of it I think that is in an important part of it and that is that when we find a city that has to fewest available assignments it may have more than one or five. The computer will then look at each one of these places and find out which of these has the least impact on other availabilities and then choose the assignment that leaves the most available assignments in other places and in this way we should always Each time we make an assignment leave as many as possible assignments for other places. That's one possible. Result of this may not be to the liking of individuals. Potential applicants commercial and education and that is maybe a community in which on a technical basis insofar spacing is concerned you could have a high chair but the computer by this calculating device will find out. I think my channel has a much smaller impact on other availabilities and it will choose that. And if we're going to try to strive for the

maximum efficiency then we would have to abide by the decision of the computer. There will be situations where there is very little to choose between and the computer will always choose the one that has the least impact even if it's just one out of 25 or 30 because it is a go no go type of thing. But in the case of this program we can manually override this we can ask the computer. What is the difference between the moment turn and tell us and well that's not important enough so we can pick a low channel under those circumstances. We don't pretend to be experts in your educational means but in the case of we are supposed to be experts in radio regulation and management of the spectrum and they're guided by that sort of thing. Those are the decisions we have to make overall. One of the difficulties we expect in this whole approach and this again is where you

could you can be help when you have it but that is in this election. The most important educational assignments I said we would make this first list the most important. There's no there's no unanimity of opinion among educators as to what is the most important use of educational television considered classroom instruction to be the most important role in terms of adult education. People in classrooms others believe that television stations education should provide cultural and Lightman programs that are not available from commercial broadcasting stations and then a great many think in terms of this is a solution to the growing shortage of classroom space and teachers. Some think in terms of state wide coverage another thing in terms of just local area coverage. It's in this area that we may have to assert this frequency management and regulation type of thing. That is a

function of the communications because actually in these channels were allocated for broadcasting purposes the UHF channels broadcasting defined by the communication technology transmissions intended for reception by the public at large in their homes. And when these channels for classroom instruction for example this is really a private circuit system it's not broadcasting as defined communications the channels that were made available for broadcasting were done so in the allocation proceedings in which the needs of all people who wanted to use radio or the police in the Abbey ation and the maritime laundry services taxi cabs and out of the expect the spectrum was carved up into blocks and each broadcasters were given. A certain portion of the spectrum to use and when this is used for some other purpose. And this

is not in accordance with the basic allocation and we have to consider that. We know that educational television has been developed as a sort of companion classroom instruction type of operation as well as broadcasting as a matter of fact it was the ability of using this tool for teaching the classroom instruction that made it possible for a great many of the stations to get started in the first place. You might not have been able to obtain the necessary funds for straight broadcasting operation and at the present time a large number rely on the service that they provide to provide the support that it needs to do the programming actual broadcasting for people and so we know that this is one of the facts of life and we have to live with it. But we did the Commission didn't realize the importance of television in the education classroom

instruction and it was for that reason we developed this twenty five hundred mega cycle service the instructional text television service we called it a fixed service broadcasting service in term in technical broadcasting not by definition but it operates from a central point and service receiving locations whereas the the classical service as defined is fixed because the transmitting and receiving point. It is defined in advance of selecting and in this case it's a multiple address type of picture in the in the instructional pics. You have one transmitting point in a number of specified a pre-selected receiving point but it has it has a lot of the aspects of broadcasting. And because it now banned which had been allocated to the fixed service that was a twenty five hundred twenty six ninety and in that band we were able to provide 31

television channels for the development of the service. So we hope that that will take place. The requests that showed up in the original study of multiple channels to individual locations so that you could could do a real good job of classroom instruction it's to use a single station and provide the kind of service that you need and that classroom instruction also would be impossible for us to provide enough channels. If every city that had a need or a local school system classroom instruction to provide them a three four five commercial broadcast broadcast channels they just choose to go around. They compromise it's usually made in as we have in the Washington area there's one transmitter one station that provides service to several jurisdictions around Washington. The problems of course because

scheduling problems because the different schools do not have the same course at the same time and in many cases because of the scheduling problem. The same program has to be transmitted several times and this redundancy makes this an inefficient use of the broadcast channels with the instructional service the private lease a privately operated system to suit the schedule of the system that you're serving now. Some of the educational groups I know have twenty five hundred mega pastors as a rival of educational broadcasting and we consider to be a supplement. When we develop the Service Act a combination which includes Yes I'm sorry I always mistrust these public address systems and. I've been an engineer started turning control to be an engineer. It's nothing working at all right now. I was relying upon this microphone

in work and I certainly will speak louder. I said I started to say that some educational groups have this new service as a rival to educational broadcasting and when we did when we created it we considered it to be a supplement and a combination which included an educational broadcasting station plus a closer get all private instructional system would be ideal because it can not only reach the children in the classroom but also reach the end also home both formal education and the classroom and Lightman type of programs. This association can contribute a lot to such a weighting of these services operators of instructional fix services would benefit from membership in and be because they are technically the operation is very similar to broadcasting and they could draw on the experience of your broadcasters.

It sounds like it's working. Broadcasters can profit from a similar association in that you would. You could kind of see that this service developed as a supplement rather than a rival to educational broadcasting. And it's not inconceivable to me that this twenty five hundred twenty six nineteen which is now considered to be microwaves but I don't want to admit it when I first went in radio everything above 30 mega cycles which is well below television channel 2 was considered to be microwaves in the future they had Benjamins in the state of the art. It's not inconceivable to me that inexpensive home type converters by twenty five hundred mega cycles will become as common as UHF converters are today and that if you did more to reach an adult audience through these through the service you could it could as a matter of fact.

Ultimately I suppose become what amounted to another educational Broadcasting System. Anyway it's worthy of your consideration one of the things that I learned just before we left in Washington. More interested in the operational fix type of thing that works in the business radio service what they call strictly kosher again and you know we had a procedure that would allow the operational fix in the business radio service to part time share a broadcasting station this problem comes about because some broadcasters in Texas have been ill if they operate a closed circuit system campus to campus and addition operate broadcasting stations and under our present rules the microwave that is used by the close circuit is not allowed to carry a program in here over broadcasting and the broadcast ancillaries studio transmitter links and pickups in the center relays are not allowed to carry material for close circuit use.

Separately they may simultaneously do that we inaugurated the rulemaking that would allow. A certain percentage of the time to be used for the other service if you had an operational fix for close circuit you could use it for certain percentage of the time to deliver a program to broadcasting. And if you operated broadcast exam or if you can use it for a certain percentage of the time to the level program was strictly closed circuit uses and originally we had proposed 20 percent of the time on the basis of the fermenter came in and it appeared that when the problem we were really trying to meet and that was to avoid the necessity of you having to have two seperate microwave systems that we can raise this to just the dominating Service determined which which likes what kind of license you have that is if it used 50 percent or more of the closed circuit and its license in the business radio service and it can be used less than 50 percent but up to forty nine point nine and I thought the delivering programs

broadcast station and Similarly if your principal use 50 percent of noise for broadcast engineer vs. in connection with a broadcasting station it will be licensed and the broadcasters in ribbons and then you can use it pull up to this 40 plus percent guessed on the 50 percent or close second operation. We had had to Arnold this percentage we had a number of discussions with the mirror that administers the business radio service and we finally reached an agreement just before I left Washington. Should come before the commission within the next couple of weeks so that we will have an answer for you I would expect very shortly in the final decision on that. I think that's about all I have to say thank you. Thank you very much. Thank you very much Mack I'm sure that Larry and Bob will agree to with me how important it is for anyone to communicate one's feelings to the commission because if you don't you'll be in a fix. And his wife had an argument and

he decided that after two weeks of starving it like to make up. So I was walking by a pet store and saw a sign that said for sale parrot speaks 12 languages but she has a great sense of humor he ordered the birds sent home and when he got home that night sure enough it had the desired effect. Walk in the door he was greeted with open arms had a candlelight silver dinner on the table. She brought out first course the soup and the fish and the salad and finally the guest resistance with his gorgeous bowl she brought on this bird. He looked out and said You don't mean to tell me that that's that bird I sent on this afternoon she said The course was nice and he said Why no you idiot that was a parrot spoke languages. She said Why didn't it say something. So if you don't want your parrot cook let the FCC know what you're thinking. Now the next. No one attended the University of Illinois but after a few losing football season that is customary he left for university of Miami where he earned a lot agree. There are two terms of one can apply to this gentleman the same word pronounced differently. He is a gentleman

and a gentle man. It was a pleasure for me to get acquainted with Mr. Samuel L. citing chief of the television applications branch of the Federal Communications Commission he processes all of your three forties or three old ones Sam. I know most of you have applications filed with this commission or are planning to file applications. I've heard that a lot of backlogs and. I've discussed with many of your fellow educators. The problem is in communicating with the Federal Communications Commission. We seem to run into the same problem. I'm going to talk about application process in generally our chief problems in the hopes that those of you who have filed applications and are waiting for you to hear from us may get some clue as to why you're being held up. And those of you who are planning to file applications may avoid certain

other problems which cause it. Under the Communications Act this Commission the Federal Communications Commission must make a finding that the applicant is legally technically financially and otherwise qualified and that his application will serve the public interest continues and assessing in the case of the educators. As a very strong presumption that there they will serve the public interest convenience and Ceci. But we run into the biggest problem making a finding as to the qualifications findings. Our chief problem has been in the past the financial problem this is easing up somewhat because of the AGW program today. But we still want a quite a few problems. Contrary to the situation with commercial broadcasters most of the educational broadcast applications

are considered by us to be cash transactions because this is what they provide for. Whether this is due to the fact that equipment suppliers have not seen fit to extend credit or whether because of internal problems credit is something that educators can choose. We can never blessed all our applications are cash transactions. And when discussing cash and liquidity I guess most of the Educate is fair to understand our problem. Cash is means cash. We consider as liquid assets. Government bonds. Certain insurance policies only educator's cases it doesn't really apply. But speculation as to what they will get from various school districts when and if the application is granted and the stations constructed are not considered can't be considered biased because under the Act we have to make that finding that you have this money available to you. And this is where our problems begin.

We've got a number of situations where. Enthusiastic and optimistic educators of the application form of this and then estimated they're going to get two or three hundred thousand dollars from the various school districts who will be joining us. And if they put this in the application we write to them to tell them why you haven't got any money they say we're more sure we'll get it from all these people on a per pupil basis and we have to keep telling them no on their application form says you must make this money available. It will show that it is available. This is being eased somewhat as I said because of the AGW problem. Another problem we run into with most educational institutions is the question of quote fund accounting because we get a very beautifully filled out application and refers to the funds to be used for make some sort of a fund they have a building fund some sort of restricted or unrestricted fund or general fund for educational purposes.

Again we can't rely on this because quite often we don't know that the institution has the power to utilize the particular phones mentioned. If it's a restricted fund you've got to show a specific authorization to use these restricted phones. This takes a bit of correspondence until we get these things down. Another area of problem is the proposed legislative appropriations and you all know the difficulty you have with legislative appropriations. We have the same difficulty. Whenever it is proposed to recommend that the legislature of a state take a certain type of action this does not mean that this is a Fed accompli and you've got the money. Many of our applications come in and say we've got three hundred forty thousand dollars we're going to make a recommendation to the state to appropriate this money for us and we don't actively application or

we write them a letter in a bit of a screening and we have to explain to you again that this is not considered available and that happens just as instances where. We were told that the money was effective able that the legislature had effectively taken action and it turned out said to me that they had never taken any action at all and were sort of caught in the middle having made a grant and made a finding that they are financially qualified. There was no money available. Another area of problem is this question of donations from financial institutions businesses large corporations in these large trusts. We we find that many of the donations are contingent upon the state or the county whatever the body of municipal body may be putting up matching funds. And that if there's a failure of the legislative appropriation of years of appropriation these donations failed and we run into the problem

quite often whether we have that they submitted complete detail information only donations show that the money is available and actual pledge but because of the area of the legislative appropriation you have to presume that these donations will also fail. This is an area where it seems to me that they could you could tighten up.