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Policy Forum

Regional vs. National Accreditation

Regional vs. National Accreditation

Posted By:   EDUCAUSE  (edupolicy@educause.edu)
Date: 5/14/2002 1:54:36 PM
Only "regionally accredited" institutions are currently eligible to receive .edu names. It has been proposed that this restriction be revised to include all post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies."


  • Posted By:  Horace Six-Means  (horace.means@ptsem.edu)
    Date:5/17/2002 12:05:01 PM

    I am on the faculty of Hood Theological Seminary in Salisbury, NC and I support the rapid implementation of the proposed change. Hood was formerly the graduate institution of Livingstone College and was dually accredited by SACS and ATS. Hood has become freestanding this year and is now an institution accredited by the Association of Theological Schools in the United States and Canada. It does not have, or need, regional accreditation except, it seems, to register an "edu" domain name. ATS, or any other such national accreditation, should be sufficient to qualify for an "edu" designation.

    Horace Six-Means
    Hood Theological Seminary
    800 W Thomas Street
    Salisbury NC, 28144

    • Posted by:   Ralph L. Meyer  (meyer@princeton.edu)
      Date: 7/6/2002 4:50:10 AM

      I am opposed to any expansion of the definition of the .edu domain. Having checked the list of `accepted accrediting institutions` it is clear many have no relation to institutions of higher education.
      I am particularly opposed to any legitimation of so-called theological schools for the use of the .edu domain designation. Theological schools are partisan propaganda institutions dedicated not to the advancement of science, medicine, or the humanities on the basis of empirically establishable facts and information, but propagate solely authoritarian and unfoundable conjectures. They are not educational institutions but institutions for the propagation of specific and non-empirically based authoritarian concepts, and are generally opposed to the sorts of checks and requirements true educational institutions are subject to for accreditation.

      • Posted by:   Robert Amell  (ramell@thompsoninstitute.org)
        Date: 7/24/2002 10:40:09 PM

        Its seems that you fear what you do not know, or have a personal affliction to religious organizations. That personal bias is no standard by which to judge the use of an internet domain to identify facilities of higher learning. I know many people who have attended Theological seminaries and should have the freedom to choose to do so via an easily accessible web site. You, as an esteemed member of the scientific community, should not fear competition from a seminary. The educational community is no place for isolationism.

      • Posted by:   Sharon Dowling  (PUNKERSAD@MSN.COM)
        Date: 8/4/2002 12:27:17 PM

        I support the new policy. I have taken courses from various educational institutions like Accis and CPCU. The courses provided are more detailed and more relevant to my business then the local Jr college that can use the edu extension.
        It is not as if the standards for accreditation is less for national recognition. Why limit access to different kinds of schools. Education is the word. Do these institutions not provide education?
        Even religious educational institutions provide meaningful education to the people who use them. Philosophy class, world religion class or other humanities class are required for an associate or bachelors degree. No class is totally without slant. The author of the books, the teachers of the class will always provide their interpretation of the subject matter.

      • Posted by:   Elaine Giuliano  (giuel@cccbus.com)
        Date: 8/9/2002 1:29:32 PM

        Mr. Meyer,
        Before you go too far off the deep end on "empirical evidence," can you please show me the empirical evidence for the existence of a point, line or plane? Everyone accepts these mathematical concepts on "faith."

      • Posted by:   Gordon Nolan  (Gn1Ln1@aol.com)
        Date: 8/11/2002 5:47:14 PM

        In rebuttal to your remarks Mr. Meyer, I feel that education is not to be confined towards a minority`s viewpoint. Education simply stated is learning! America gives us so many precious freedoms. The freedom of speech, privacy, and the pursuit of happiness are all bestowed, gifts earned through past generations of Americans quite willing to give up their life`s to keep such cherished freedoms.
        Now we limit what kinds of educational organizations, will teach to the masses? Who can decide to limit one`s type of learning, when that person only knows of another? It`s like trying to tell an accountant how to assess their balance sheet, when that person only knows how to work on an assembly line.
        Now to my main discussion, educause. I am currently a student with ACCIS.edu. I have a Bachelor of Science degree earned with Northwest Missouri State University in Finance. The courses at ACCIS are every bit as hard, time- intensive, comprehensive, and challenging as those I have taken at N.W.M.S.U.. If you take away ACCIS`s domain status of "edu", I will be deprived of higher education, less full course enrichment, lengthier grade completion times, narrower learning opportunities, at your expense!
        If the internet is the future today and into tomorrow, and you do believe this statement to be true. Then why construct roadblocks, especially when education is the main issue!

    • Posted by:   Bill Wall  (bwall@directap.com)
      Date: 8/3/2002 9:22:24 AM

      To state my opinion succinctly; all accredited institutions should be allowed to obtain the ".edu" designation. Imposing an arbitrary distinction between accrediting agencies would create an artificial difference between institutions. Since no difference exists between institutions in reality, as long as they are accredited they should be on equal footing in terms of acquiring the ".edu" domain suffix.

      Bill Wall

  • Posted by:   Abram Engler Anderson  (aengleranderson@hotmail.com)
    Date: 5/19/2002 10:03:50 AM

    I wholeheartedly concur with the proposal at hand to extend .edu domain registration eligibility to institutions of tertiary education accredited by federally recognized specialized accrediting agencies, such as the Association of Theological Schools (ATS), and the Association of Advanced Rabbinic and Talmudic Schools (AARTS).

    In the case of the Yeshivot -- traditional Talmudic seminaries that offer rigorous, advanced instruction in Talmud, Jewish sacred literature and Jewish ecclesiastical law ("halakhah") -- the present exclusion only serves to discriminate against the institutions, their students and their graduates, not to mention an entire faith community that seeks to preserve its traditional modes of scholarship and clerical training.

    The yeshiva curriculum consists of classical Jewish literature, studied almost entirely in the original languages (Hebrew, Aramaic), with the language of scholarly discourse for lectures being Yiddish as often as English. Accrediting such specialized institutions is, then, a specialized task that is ideally conducted by a specialized rather than generalized agency.

    Excluding recognized and nationally accredited institutions that choose to adhere to their sacred traditions of scholarship, pedogogy, organization and administration amount to nothing less, in my mind, than a form of cultural imperialism -- assimilate or perish, if you will.

    It also cannot be the mission of .edu domain name eligibility to serve as an additional form of accreditation that second guesses and supersedes what the U.S. Dept. of Education has already established, namely, the role and validity of the specialized agencies.

    I urge Educause to look toward the properly constituted public entity which authorizes the accreditors, the U.S. Department of Education, and give full credence to the accrediting agencies that it lawfully authorizes.

    Miami Beach, Florida
  • Posted by:   M.D. Groothuis  (growthis@aol.com)
    Date: 5/20/2002 4:20:04 PM

    All accreditors are subject to the same oversight and criteria as prescribed by the U.S. Department of Education if they wish to be listed and recognized by that body. Some accreditors have chosen not to comply due to the stringent requirements and complexities of the process. However, those accreditors which have chosen to undergo this rigorous process, and the institutions they accredit, should be afforded the same recognition and opportunities. I support a change and am, frankly, surprised there has not been a legal challenge to this practice.

  • Posted by:   Kathy Fox  (kathyfox@nor.herzing.edu)
    Date: 5/20/2002 4:45:08 PM

    This proposed change is appropriate and reflects other trends occurring in the higher education community regarding the equal treatment of regionally and nationally accredited colleges. Any nationally accredited college should be eligible to receive the .edu domain name.

  • Posted by:   M.D. Groothuis  (growthis@aol.com)
    Date: 5/20/2002 4:20:04 PM

    All accreditors are subject to the same oversight and criteria as prescribed by the U.S. Department of Education if they wish to be listed and recognized by that body. Some accreditors have chosen not to comply due to the stringent requirements and complexities of the process. However, those accreditors which have chosen to undergo this rigorous process, and the institutions they accredit, should be afforded the same recognition and opportunities. I support a change and am, frankly, surprised there has not been a legal challenge to this practice.

  • Posted by:   Elaine Giuliano  (giuel@cccbus.com)
    Date: 5/20/2002 8:13:37 PM

    I couldn`t agree more. Using regional accreditation only is arbitrary and contrary to the spirit of a free and open educational market. Not all education-seekers are looking for a degree. We already deal with the constant confusion of well-meaning counselors who think non-degree = non-accredited. The .edu myth compounds the issue. Since the domain-name issue is primarily a commercial one, free competition would seem to dictate that all schools should be able to compete equally.

    • Posted by:   Brenda Stuart  (jbstuart92@btopenworld.com)
      Date: 8/3/2002 2:38:18 AM

      Well said. I see no reason to have limits on the .edu domain names if those establishments using them are for education purposes. If the education offered will assist someone in their endeavor to gain knowledge then they should be entitled to use the .edu extension. Higher accreditation usually includes higher costs which many cannot afford, yet their education should not be considered any less valuable.

  • Posted by:   Joann Mulqueen, Ed.D.  (jmulqueen@wbi.org)
    Date: 5/21/2002 11:43:01 AM

    The Westchester Business Institute has been in existence for more than 85 years. As a degree granting institution, we have been guided by our Mission to offer quality education programs that enable our graduates to secure excellent career positions. We are nationally accredited by the Accrediting Council of Independent Colleges and Schools and we have achieved candidacy status from the Commission on Higher Education of the Middle States Association. Our evaluation visit is scheduled for October, 2002. It seems unreasonable that we cannot be granted an `edu` address since our Mission and our focus is education. I full support the proposal to include all higher education institutions that are accredited through nationally recognized agencies.

  • Posted by:   Karen J. Smith  (ksmith@wbi.org)
    Date: 5/21/2002 12:04:54 PM

    This rationale is appropriate and logical. Because the Department of Education is responsible for oversight of all accrediting agencies (regional & national), those agencies accredited members should have the right to use .edu as it most accurately reflects what they offer consumers. Additionally, the assumption must be made that the original restriction to regionally accredited colleges was meant to limit access by institutions posing to be post secondary institutions, not those recognized as such by the United States Department of Education. Our college has been a dues paying member of Educause for several years, we have gained much from Educause and I applaud their bringing this issue forward.

  • Posted by:   Alan P. Duesterhaus  (alan@duesterhaus.net)
    Date: 5/21/2002 3:01:01 PM

    It would also seem reasonable to include institutions authorized/approved by their State agency to grant degrees given that higher education is really a governance issue for the States.

  • Posted by:   Coleman Furr, EdD  (cfurr@coleman.edu)
    Date: 5/22/2002 11:05:00 AM

    The proposal is highly discriminatory. All accrediting agencies must conform to the standards established by the U.S.Department of Education(DE). The DE has established policy that no discrimination should be made against institutions accredited by any agency recognized by DE. Graduates of Nationally Accredited colleges have been the victims of discrimination for many years. That discrimination is wrong. Do not make further discrimination against those graduates and the excellent institutions that produced them.

    • Posted by:   Student  (runist@softhome.net)
      Date: 8/2/2002 9:19:59 PM

      This is so depressing. Schools who already have the edu should stay. they are already doing what is required to be .edu. hopefully this does not go through, but if it does only schools after the fact should have to conform to this. leave the .edu`s alone that are already. get a life people

  • Posted by:   Mark Millen  (mmillen@svcollege.com)
    Date: 5/22/2002 11:53:25 AM

    I support this proposal. This change would fairly treat all institutions of higher education and not discriminate against certain institutions based solely on their type of institutional accreditation. The US Department of Education (USDE) is the recognized expert on education issues. The USDE and Department of Commerce should use commone definitions and treat similar institutions in a similar manner. Current USDE regulations define all providers of education as "institutions of higher education" as long as they meet certain criteria and are accredited by an institutional accrediting agency recognized by the Secretary of Education. This policy of fair treatment of accredited schools is one that should be used consistently by government agencies and those agents acting on their behalf, such as EduCause.

    My initial letter and electronic submission in November 2001 on this issue are on file. I appreciate that my request for a public forum was considered and that this issue is being addressed. I hope that your group and the Department of Commerce adopt this proposal.

  • Posted by:   Michale S. McComis  (mccomis@accsct.org)
    Date: 5/22/2002 4:02:38 PM

    I am currently the Director of Accreditation for the Accrediting Commission of Career Schools and Colleges of Technology (ACCSCT), and I concur with the proposal to allow greater access to the use of a .edu domain name. The stipulation that only "regionally accredited" institutions are eligible to receive a .edu domain name is unfair and restrictive and I would recommend that Educause seriously consider a change to allow any institution accredited by a "United States Department of Education recognized regional or national accrediting agency" access to the .edu domain name. This would certainly create greater fairness and equability and provide greater information access for all students.

    ACCSCT is a private, nonprofit, independent accrediting agency whose goal is to maintain educational quality in the career schools and colleges it accredits by striving to assure academic excellence and ethical practices. ACCSCT is dedicated to the more than 360,000 students who annually pursue career education at its accredited institutions. As an accrediting agency, ACCSCT is responsible for assuring that its member institutions and their educational programs are capable of preparing students for their chosen careers. The accrediting process also assures students and the public that high standards of career education are being met. The U.S. Department of Education recognizes ACCSCT as a national accrediting agency for private, post-secondary institutions offering occupational vocational programs.

    At ACCSCT accredited schools, students learn the skills and careers that touch the daily lives of all citizens. ACCSCT member institutions teach programs related to many diverse vocational fields of study and help to ensure the strength of the American workforce. The strength of the American workforce is directly related to, and responsible for the United States' ability to effectively compete on a global scale. This is an endeavor, I am sure, that the Department of Commerce as well as other sectors of our nation"s government would be interesting in supporting, promoting and enhancing.

    ACCSCT accredited institutions are sound educational providers and should have the same opportunity for access to the student population as regionally accredited institutions. Given that so many students leave the secondary school level in need of further education for a successful transition to the world of work, it is socially responsible to ensure that all students are provided with appropriate access to information which will allow them to make the best and most fully informed decisions relative to their educational future. All educational institutions should have an equal opportunity to provide that information.

    Therefore, I would again like to state my agreement with the revised change and to allow any institution accredited by a "United States Department of Education recognized regional or national accrediting agency" access to the .edu domain name. I hope that you have found these comments to be helpful.

    Michale S. McComis
    Director of Accreditation
  • Posted by:   Wayne Fletcher  (wfletcher@westwood.edu)
    Date: 5/23/2002 9:30:14 AM

    I support the proposed policy change. If the DOE accepts an institution and its accreditation` it seems absurd that another agency should determine that the nationally accredited institution does not meet the criteria to utilize the .edu suffix. Many biases exist` preferring regionally accredited institutions over nationally accredited institutions.

    We must continue to break down the barriers between the two types of accrediting bodies` recognizing that they serve different functions` as do the institutions they represent. However` they both have a common objective - the education and preparation of our people to contribute to the growth and success of our society.

    "Business colleges originated in this country as a protest against the inefficiency of our system of education -- as a protest against the failure` the absolute failure` of our American schools and colleges to fit young men and women for the business of life. These business colleges furnish their graduates a better education for practical purposes than either Princeton` Harvard or Yale."

    James A. Garfield
    President` 1880-81
    Quoted in
    Penman's Art Journal
    May 1901
  • Posted by:   Jeff Arthur  (arthur@ecpi.edu)
    Date: 5/23/2002 12:22:43 PM

    I represent a regionally accredited degree granting institution, but I see no reason not to allow ANY institution that meets the U.S. Dept. of Education's definition of an institution of higher education the use of edu names.

    A policy that prohibits nationally accredited institutions of higher education from using .edu names seems to be discriminatory and vulnerable to legal challenge.

    It would also be clearer for the public to know that any college they are looking for on the internet is .edu rather than the various naming schemes currently in use.

  • Posted by:   Jennie Baran  (jbaran@collegeamerica.com)
    Date: 5/24/2002 11:33:13 AM

    In an effort to gain credibility and present the most accurate face to the public I think that the use of ".edu" should be afforded to both regionally and nationally accredited institutions of learning.

  • Posted by:   Luis Gonzalez  (lgonzalez@interboro.com)
    Date: 5/24/2002 7:02:11 PM

    I fully support revising the existing policy to include nationally accredited institutions. When I found out that Educause would be assuming the responsibility of administering the .edu domain, I was very excited. However, later I found out that the proposal would exclude smaller colleges by allowing only regionally accredited colleges to obtain the domain suffix. That was very shocking.


    "EDUCAUSE is a nonprofit association whose mission is to advance higher education by promoting the intelligent use of information technology. Membership is open to institutions of higher education, corporations serving the higher education information technology market, and other related associations and organizations."

    If Educause opens its membership to all institutions of higher education and etc., then why would its policies purposely exclude some of their very own members from obtaining the .edu status?

  • Posted by:   Rev. Mark Pranaitis, C.M.  (mpranaitis@careerchi.com)
    Date: 5/28/2002 7:54:33 AM

    The .edu domain signals to the average Internet user that the organization is a school. Preventing organizations that are legitimately schools from using .edu only serves to raise questions in the minds of users. Broaden the usage of .edu. It only makes sense.

  • Posted by:   David W. Robinson  (drobinson@pioneerpacificcollege.com)
    Date: 6/4/2002 3:08:31 PM To the Educational Policy Board at Educause:

    Educause.edu has recently been entrusted with the administration of the .edu domain database, and has opened allocation of those domains to 2 year accredited colleges. This was good news to those of us here at Pioneer Pacific College, as we are a 2 year degree-granting college authorized by the State of Oregon`s Office of Degree Authorization (ODA) and our national accrediting agency, ACICS which is in turn recognized by CHEA.

    Less pleasant was the discovery that your current policy discriminates against ACICS accredited degree-granting colleges who apply for a .edu domain name.

    We at Pioneer Pacific College would be interested in hearing the rationale for your exclusionary policy. ACICS is the only national accrediting agency recognized by the Department of Education and CHEA, and has status at the state and federal level fully co-equal with any regional accrediting agency. Why over 600 ACICS accredited colleges with over 350,000 students should be accorded second-class status is a mystery to us, and strikes us as a discriminatory practice. You will find Pioneer Pacific College listed in your American Council on Education (ACE)/CHEA Directory of Accredited Institutions; why should any college/accrediting agency authorized by CHEA be denied the right to register a .edu domain name?

    We are also very curious about the fact that there are a number of 2 year colleges which are NOT accredited by regional agencies, but who applied for .edu years ago and were grandfathered into the current database. Such inconsistencies, in conjunction with clear discrimination and what appears to be a de facto restraint of trade, are serious issues, and must be redressed. Given the importance that attaches to a .edu domain listing, we consider the matter to be of vital importance.

    We are therefore formally requesting that Educause revise its policy with respect to ACICS accredited degree-granting colleges and access to .edu domain names. As a nationally accredited college, we are asking for equal access to this important aspect of educational presence on the Internet, and are asking you to revise your policy.

    Be advised that we intend to pursue this matter most vigorously.

    On behalf of Pioneer Pacific College,

    David Robinson, BA, MAT
    Director of IT
    PCS Program Director
    Pioneer Pacific College http://www.pioneerpacificcollege.com
    The problem!
  • Posted by:   Russell G. Fitzgerald, Ed.D.  (tracs@lynchburg.net)
    Date: 6/6/2002 10:20:13 AM

    On behalf of the fifteen member Accreditation Commission and the member institutions of Transnational Association of Christian Colleges and Schools (TRACS), an institutional accrediting agency recognized by the U.S. Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA), I strongly request that the EDUCAUSE Policy Board extend to our member universities, colleges, and seminaries the privilege of registering for domain names ending in "edu."

    I thank you and look forward to a positive response that would allow TRACS institutions of higher education to be included on the approved listing along with those institutions that are regionally accredited.

    You may refer to the TRACS web site at www.tracs.org for further information, or contact me at tracs@lynchburg.net.

    Thank you in advance for your consideration.

    Russell G. Fitzgerald, Ed.D.
    Executive Director
    Transnational Association of Christian Colleges and Schools
    15935 Forest Road - PO Box 328
    Forest, VA 24551
    (804) 525 - 9539
    Fax: (804) 525 - 9538
    On the Web: www.tracs.org
    E-mail: tracs@lynchburg.net
  • Posted by:   John Peterson  (jpetc@jps.net)
    Date: 6/15/2002 3:09:52 PM

    I spoke with a staff member last week regarding eligibility requirements to receive and utilize an .edu domain name. On your Web site Q&A you specify that a degree granting institution must be accredited by one of the six US regional accrediting agencies. This being the case, that eliminates scores of degree granting institutions accredited by national accrediting agencies recognized by the US Department of Education. Prior to educause providing the .edu domain, many nationally accredited institutions and state approved institutions received permission to use "edu."

    I represent an institution recently accredited by the Distance Education Training Council (DETC). This institution has a desire to secure a .edu domain name. I am requesting that educause consider waiving the Regional accreditation requirement. DETC is recognized by the US Department of Education and the Council for Higher Education Accreditation. Your consideration for this waiver of current eligibility requirements would be appreciated.

    The institution requesting the waiver is the Babel University Professional School of Translation. This institution has been operating for 27 years with headquarters in Tokyo, Japan and a US operation in Honolulu, Hawaii.

    Your prompt response would be most helpful. I can be contacted via telephone at (916) 489-8954.

  • Posted by:   Jeff Myhre  (jmyhre@msbcollege.edu)
    Date: 6/17/2002 7:03:44 AM

    I'd like to propose adding the Accrediting Council for Independent Colleges and Schools - ACICS (www.acics.org) to the list of acceptable accrediting agencies for schools wanting a .edu domain name extension. If adding ACICS to your list of accrediting agencies isn't going to happen, I'd like to ask for an exception to Educause's policy regarding the accreditation of Globe College in Minnesota.

    The Minnesota School of Business (MSB) and Globe College are both accredited by ACICS. MSB received a .edu name extension when we applied last year (before Oct. 29, 2001) because we are a 4-year degree granting school. Globe College, which is affiliated by ownership, has the same educational programs and also grants 4-year degrees. We would like to apply for the .edu domain name extension for Globe College.

    MSB and Globe share the same web site and it is accessible at www.msbcollege.edu or www.globecollege.com. We would like to be able to have both schools use the .edu extension. MSB and Globe College have a long history in Minnesota (founded in 1877 and 1885, respectfully) and operate professionally and responsibly for the benefit of our students, employees, and communities.

    In addition to our national accreditation, we are licensed by the Minnesota Higher Education Services Office and have numerous memberships and partnerships with companies and organizations. The US Department of Education grants our students use of Federal Financial Aid money to go to school. We are also members of the Career College Association (and Minnesota Career College Association). For a list of all our accrediting agencies, associations, and partnerships, please see our web site at www.msbcollege.edu or www.globecollege.com.

    Please contact me with any questions regarding our request.

    Thank you,

    Jeff Myhre
    MSB and Globe College
    612-798-3748 (office)
    612-798-5548 (fax)
  • Posted by:   Dr. Randy Stein  (rstein@fvconline.com)
    Date: 6/17/2002 10:32:55 AM

    Dear Sirs,

    It seems that if a new college is licensed in a State and there is a one year wait prior to being allowed to be accredited by any recognized DOE accrediting body, that your policy has an adverse effect upon a New school, not being allowed a .edu web site. Also, some regional accrediting bodies do not fit the a particular type of College. The "other" accrediting bodies recognized by the DOE US Government should be allowed to have their member colleges & Universities have a .edu website. It seems, extremely limiting to only have regional accreditation agencies to be able to obtain an .edu, when accreditation agencies that are recognized by the DOE is the standard in the USA! I hope that you will also consider a new classification like .edu1 for new schools that will be pursuing accreditation within one year of their start up. Thank you

    Dr. R. Stein
    Florida Virtual College
  • Posted by:   Clive L. Grafton  (Clive@newport.edu)
    Date: 6/17/2002 10:47:23 PM

    I do not believe that a policy restricting edu domain names only to the six regional accrediting associations is totally fair. I believe that a better arrangement would be to include that usage for institutions that are accredited by any of the accrediting bodies recognized by the United States Department of Education. The standards of operations within the six regional accrediting bodies do vary widely and in some cases restrict institutions in one region from meeting requirements that would be acceptable in another region.

    This suggestion, of course, would cover only those postsecondary institutions meeting the basic requirements for application.

    Clive L. Grafton
    President, Newport University
  • Posted by:   Tony Palmieri  (tonyinboca@hotmail.com)
    Date: 6/18/2002 10:22:41 PM

    New colleges are especially negatively impacted by this policy, given the waiting period for accreditation. We have taken 1.5 years to plan, raise money and recruit our staff of lifetime educators to create a new college with the highest academic standards. We are about to earn our license with our state agency, and will submit for regional accreditation thereafter. However, we were denied a ".edu" by Network Solutions in June of 2001 because we were not yet established (we could not even reserve), and now we are once again unable to secure our ".edu" name. Solutions?

    1. Allow state-licensed schools and colleges to use the ".edu" domain. Another posted reply stated that even states can have rigorous qualification policies (ours does)!
    2. Allow state-licensed schools and colleges that submit for any accreditation to use ".edu" even if during the waiting period.
    Thank you,
    Tony Palmieri

  • Posted by:   Dr. Henry Klopp  (hklopp@igsmin.com)

    Our institution, The International Graduate School of Ministry, is a new, religious non-profit 501(c)3, distance education institution, with satellite facilities in North America and several other nations. We applied to you for an .EDU domain name and were refused because we did not meet your requirement that we be accredited by one of the regional accrediting agencies. We would recommend you reconsider your criteria for issuing .EDU domain names for the following reasons.

    1. I assume that you are aware that most religious schools do not have regional accreditation. Your policy limits domain name approval only to schools listed with the 6 regional accrediting agencies, yet both the U.S. Department of Education and the Council on Higher Education (CHEA) clearly recognize additional accrediting agencies. I think, as a very minimum, you will find that you will need to revise your policies to accept schools from these other recognized accrediting agencies.
    2. In fact, when we contacted the regional agency here in our local area, we were told that because of our religious status, they would defer to these agencies and we had to gain accreditation through one of them BEFORE we could apply with the regional agency.

    3. Every state has a Higher Education Board of some kind that oversees all schools operating in that state. Since we are operating with extension sites in several states we have had to go through several of these boards to get permission to operate in those states. The majority of states allow exemptions for religious schools, meaning we do not have to meet the same requirements as the other schools, although they do require a thorough review of the schools documentation to make sure the school is truly religious in nature and meets certain standards. If the states allow for religious schools to operate as schools without accreditation, why should you not consider the same option in allowing religious schools to operate with an .EDU extension? You could simply require schools applying for the .EDU extension to show proof that they have been approved to operate in their state. If you did not want to issue a blanket approval, there are additional criteria you could use to determine that the school was indeed a valid institution, however this seems unnecessary to us.
    4. As you are aware, accreditation cannot be pursued until a school has been offering classes for 2-3 years, depending on the various accrediting agencies and the whole process can easily take 5-7 years. Why should new schools not be allowed to use the .EDU extension? New businesses do not have to meet different requirements than existing businesses to get an .ORG or .COM domain name. Why should it be different for schools?

    We ask that you reconsider your present policies and expand the options for schools such as ourselves to obtain the .EDU extension.

    Dr. Henry Klopp, President
    International Graduate School of Ministry

  • Posted by:   John F. Teer, Ph.D.  (john@swracpe.edu)
    Date: 6/23/2002 8:26:34 AM

    The present policies for higher education EDU domain names is too narrow. Not all educational institutions are accredited by one of the six accredditing agencies, but are accredited by another accrediting agency. The Association for Clinical Pastoral Education is such an agency.

    The Association for Clinical Pastoral Education (ACPE) is nationally recognized as an accrediting agency in the field of Clinical Pastoral education by the U.S. Secretary of Education through the U.S. Department of Education. Accredited institutions are located throughout the United States in nine geographical regions. The U.S. Department of Education sets very high standards and reviews the accrediting activities of the ACPE to ensure that United States Department of Education (DOE)requirements for higher education are met. The ACPE should be added as a recognized accrediting agency for higher education. Verification of the status of The Association for Clinical Pastoral Education as an accrediting agency may be made by contacting:

    United States Department of Education
    Accreditation and State Liaison Division
    Office of Postsecondary Education
    1900 K Street, # 7105
    Washington, D.C. 2006-8509
    Fax: (202) 219-7005

    If the Department of Commerce and EDUCAUSE for some reason chooses to not be consistent with the Department of Education and recognize the Association for Clinical Pastoral Education as an accrediting agency, then we suggest that EDUCAUSE at least recognize Regions and institutions accredited by the Association for Clinical Pastoral Education as eligible for EDU domain names.

    I, and many others, strongly believe that the present rules (which began as only a proposal) that were adopted by Network Solutions as "law" until the advent of EDUCAUSE are so narrowly defined that a monopoly has been created that excludes other legitimate US Department of Education recognized institutions/organization of higher education. Two significant changes could be made in the present policy that would benefit and govern the issuances of EDU domain name extensions: (1) Is the institution or organization a Non-Profit or Not-For Profit entity, and (2) Is it recognized by the Department of Education as an accrediting agency or institution/organization of higher learning? This certainly, as in the case of the ACPE and its Regions, would guarantee that only legitmate higher education entities received the EDU domain name extension.

    Respectfully Submitted,

    John F. Teer, Ph.D.
    Administrative and Technical Contact
    email: john@swracpe.edu
    (956) 389-6750

  • Posted by:   Thomas More College of Liberal Arts  (tmc@thomasmorecollege.edu)
    Date: 6/25/2002 1:49:13 PM

    I would like to add my voice in favor of the expansion of the policy that requires an institution to be regionally accredited in order to obtain an .edu internet address to include all institutions accredited by associations appearing on the U.S. Department of Education's list of nationally recognized Accreditation Agencies.

  • Posted by:   Lowell Frame  (lframe@earthlink.net)
    Date: 6/28/2002 9:47:46 PM

    I am in full agreement with the proposed change. Schools recognized by the U.S. Department of Education must all meet the same criteria to maintain their status. This change provides for equal treatment of all these fine institutions, and insures equal access for students researching opportunities to obtain an education and improve their chances for a better life. We must always remember to make decisions and develop policy to benefit our students, which will enhance those opportunities.

  • Posted by:   G. Gordon Apple, PhD  (ga@ed4u.com)
    Date: 7/1/2002 1:47:51 AM

    The current restriction of new "edu" domains is far too exclusionary both in scope and in developmental stage. While recognizing the desirability of excluding diploma mills and "life experience" pseudo-institutions, new technologies can result in totally new types of educational institutions being established to deliver potentially superior education using radically different techniques or education models. Such is the case with many new "virtual" universities, including our own satellite/computer based real-time interactive multimedia approach. Accreditation of a new institution takes time, at a minimum that required to traverse and entire degree program.

    At the very least, the policy should accept the US Dept. of Education's Nationally Recognized Accrediting Agencies. It should also accept pre-accreditation status. We would further recommend in this current time of educational innovation and enterprise that the "edu" domain be made available to educational entities upon specific and considered request from appropriate governing bodies such as US Dept. of Education, US Dept. of Commerce, US Dept. of Defense, and State entities such as a Governors office or a State Dept. of Higher Education. This would allow a procedural path for legitimate higher-educational organizations to establish their intended web presence while still pursuing operational funding in the formative stages. Often, such presence is essential to procuring their necessary funding.

    Thank you for the opportunity to comment on this policy.

    G. Gordon Apple, PhD
    722 S. Broadway #30
    Redondo Beach, CA 90277

    800-579-Ed4U (3348)
    310-418-Ed4U (3348) (cell)
    www.ed4u.edu (we wish)

  • Posted by:   Dr. Marcy Tanter  (tanter@tarleton.edu)
    Date: 7/5/2002 7:40:48 AM

    I think that if the Dept. of Ed gives its approval to an accrediting agency, we then have to trust that the schools it approves are legitimate institutions. I'm not sure that the purpose of the .edu suffix has been fully explained--Educause has it in its email address and it's not a postsecondary school. If it's meant to denote a postsecondary school, then the suffix should be available to any legitimate school. If it's meant to be reserved for only certain types of schools, then caution should be used. Is it for all institutions, are those schools that award degrees mostly or solely through the Internet equated with schools that offer face-to-face interaction? What does the .edu designation really mean?

  • Posted by:   Michael Sparks  (msparks@lsu.edu)
    Date: 7/6/2002 11:42:02 PM

    I favor returning to a less strict requrement for .edu status, as existed under Network Solutions' tenure as .edu administrator. As Computing Services Director for the Paul M Hebert Law Center, a separate campus of the Louisiana State Univeristy System, I have recently tried to register lsulaw.edu as a move to distinguish us from the LSU Baton Rouge campus, but found it is not possible. As a "freestanding" law school, we do not issue undergraduate degrees and as such could not be separately recognized by any of the accrediting agencies Educause currently recognizes. However, several other LSU System campuses which do not grant undergraduate degrees and thus would not qualify for .edu domains if they were to apply at this time already have .edu domains, including the LSU Medical Center in New Orleans ( lsumc.edu ) and the Pennington Biomedical Research Center ( pbrc.edu ), which does not grant degrees of any sort. Each of these LSU System campuses, including the Law Center, are distinct institutions of higher education and reasearch, free-standing from any university, but since the Law Center applied after Educause took over Network Solutions' role as .edu administrator and took a different interpreatation to the elegibility rules, we find ourselves unable to register a .edu domain. I have waited patiently for a year now, knowing that this situation would not stand for long, and now I only hope that the discussion is short and that common sense wins out.

    Michael Sparks
    Director, Computing Services
    LSU Paul M Hebert Law Center

  • Posted by:   David G. Whitaker, Ph.D  (dwhitaker@prairiestate.edu)
    Date: 7/8/2002 7:26:53 AM

    I support the current policy regarding the .edu designation. It is sufficiently broad to include virtually all non-profit public and private institutions of higher education, as well as the most stable of the proprietary schools.

    One of the other commentors said that this is a commercial issue and spoke to the "free and open market needs" of those wishing to do business as educators. Where I initially wanted to reject this argument, upon reflection, I now undrstand that she has hit upon the right issue. This is about a free and open educational marketplace --- for students.

    The .edu designation should be reserved for those institutions who are willing to undergo the rigors of regional accreditation. Students and parents should have confidence that the .edu suffix on an institution's address indicates that it has been in existence for longer than the time it takes to file incorporation papers in the a given state. They should have confidence that the school in question is engaged in processes that attempt to study and enhance the learning of its students. They should know that, however flawed, these institutions are operating in the public interest, not just their own narrow self-interest. And they are willing to demonstrate their sense of purpose by participating in the regional accreditation process.

  • Posted by:   Mike O'Donnell  (modonnell@chubbinstitute.com)
    Date: 7/8/2002 8:12:12 AM

    I wholeheartedly endorse the proposed revision. As President of the Chubb Institute, a well respected, post-secondary school accredited by ACICS, ACCSCT and ACCET, I believe the government has already indicated those accrediting bodies that are indicative of quality schools and EDUCAUSE should use the same guidelines. Currently, the government uses a number of approved accrediting agencies to determine whether or not a institution is entitled to receive Title IV funding, but that institution still may not be eligible to use the .edu suffix. Current limitations requiring institutions to be "regionally accredited" seems to imply that a determination was made that these institutions should be viewed as separate and distinct from the rest of the accredited post-secondary institutions. For many, many students, there are a number of quality post-secondary institutions that are not regionally accredited that are the right answer to their education needs. Such institutions should be treated appropriately and allowed to use .edu Thank you for your support of this revision!

    Michael O'Donnell
    President, Chubb Institute

    • Posted by:   armand seguin  (armand.seguin@emporia.edu)
      Date: 7/8/2002 10:26:45 AM

      I do NOT support the proposal to expand the requirements for the "edu" domain.

      While "other" schools are surely legitimate, reserving "edu" for only those institutions that are regionally accredited is the simplest and most effective way to separate "diploma mills" from genuine institutions of higher education. There is far too much capability for abuse if "edu" can go to any organization who may only have a local business license.

      If the "other" schools cannot meet the requirements for regional accreditation, they do not deserve the "edu" domain.

      Armand Seguin
      Chair and Professor
      Instructional Design & Technology
      Emporia State University (Kansas)

      • Posted by:   Linda Welch - Webmaster Education America  (lwelch@edamerica.com)
        Date: 7/8/2002 12:32:42 PM

        Grandfathered in with 3 .edu names. But, old provisions only allowed our colleges (18 presently) that offered 4 year degrees to qualify. When Educause took over the administration of these names, our 3 .edu names were allowed to continue. But, the way the regulations were written, we could not acquire additional .edu names due to our accrediting being with ACICS or ACCSCT and not one of the "approved" accrediting agencies. The campuses we represent with 4 year degrees could no longer apply for .edu names. And, then community colleges became eligible, but we were no longer eligible. Another problem arises because we have a new division offering Bachelor and higher level degrees online. This campus does not offer Associate level programs or courses. How does this campus qualify? To be fair to all schools, the rules should allow all accredited (as recognized by Department of Education) colleges to qualify. The rules seemed arbitrary when enacted and unless change is made to include colleges like Education America campuses, we will continue to object.

      • Posted by:   Robert Amell  (ramell@thompsoninstitute.org)
        Date: 7/25/2002 10:16:46 PM

        As everyone one who has posted in this forum knows and I think that Educause can read between the lines, is that there is a great distaste of postsecondary proprietary schools (ignorantly called diploma mills) among some (not all by any means) traditional 4-year college educators. The monopolization of the .edu domain is just another tool of self preservation. The truth is the proprietary school industry has consistantly provided excellent skilled workers for the U.S. workforce. It is a great alternative to those who don't choose a 4-year education. I am a product of proprietary skills-based education and continued to get degrees as I pursued employer funded education. This way I avoided the $50,000+ cost!

        Want the empirical evidence? Try these links/books:

        An non-biased article written on the subject by the U.S. Department of Education: http://www.ed.gov/pubs/CollegeForAll/intro.html

        "Other Ways to Win" written by Gray and Herr, both of The Pennsylvania State University. http://scholar.lib.vt.edu/ejournals/JITE/v33n1/jackson.html

        U.S. Department of Labor Bureau of Labor Statisticsstest growing occupations, 2000-2010 (Less than 1/2 require greater that an Associates Degree!) http://stats.bls.gov/emp/emptab3.htm

        • Posted by:   Bertha B Gumbs  (berthagumbs@hotmail.com)
          Date: 8/5/2002 9:11:04 AM

          I write to support that DOT EDU domains be designated to ANY institution that is recognized by the US Education Dept.

          I have been searching for TWO years for an accredited on-line school. My current job requires a higher level of learning. My employer supports the American College of Computers and Information Sciences as the institution for my training.

          Having a family and a full time job at the Department of Social Security in my country, I cannot leave my country to be trained. This is my only HOPE for a college education.

          I urge the EDUCAUSE Policy Board to allow DOT EDU eligibility to all schools that are accredited by an accrediting agency and IS recognized by the Dept. of Education.


      • Posted by:   Randy Harris  (randyharris@ameritech.net)
        Date: 8/3/2002 3:21:48 PM

        Professor Seguin, I must disagree with your statement, characterizing all institutions of higher education as being either regionally accredited or diploma mill. There are a great many organizations that fall between the two. There is indeed a potential for abuse, but the solution is not to exclude all "other" institutions. Such a policy would ultimately diminish, not enhance, the validity of the .edu extension. A different criteria must be chosen.

  • Posted by:   Michael R Gettes  (gettes@georgetown.edu)
    Date: 7/8/2002 12:37:45 PM

    Sometimes policies restrict other needs and capabilities. There needs to be a provision for services to the Education community to have domain names that make sense for the service. For example, a directory service to unite Education may want to have the domain directory.edu or certain projects that span educational institutions like shibboleth.edu for the Internet2 Shibboleth project. I have no issue with extending the name space as suggested, but I think we need to consider other needs of education as well.
    (slightly off point and trying to make a point)

    • Posted by:   Joseph Georges  (jgeorges@cvc.edu)
      Date: 7/14/2002 1:21:22 PM

      Speaking as a participant in a project that does span educational institutions, I could not agree more. Our project involves five centers serving 108 California community colleges.
      Joseph Georges
      California Virtual Campus Professional Development Center

  • Posted by:   Rose C. McCallin, Ph.D.  (Rose.McCallin@dora.state.co.us)
    Date: 7/8/2002 1:49:08 PM

    I am opposed to the proposal that the *.edu suffix be broadened to include all post-secondary institutions that are institutionally accredited by "recognized" accrediting agencies. Regional accreditors accredit institutions based on a myriad of criteria aimed at ensuring that students may at the very least expect opportunities to pursue "higher education", not merely post-secondary training via primarily for-profit companies and/or secular not-for-profits propogating narrow-minded, oragnized/disorganized POVs.

    When the public visits *.edu URLs, we should have some basic assurance that the school is more likely to afford us opportunities for a true higher education experience via multiple schools of thought, than say, for-proit *.com training entities and/or theological *.ORGs.

    Many of the "other recognized" post secondary accreditors exist because they are more than willing to collect $s to accredit institutions the regional accreditors (singly or as a consortium) "reject" and/or because they don't require the strict adherence the regionals demand as far as the basic tenets of quality higher education.

    To open the *.edu domain to profiteers and/or narrow-miinded secular organizations would change significantly the meaning of the suffix---to me, it would no longer be of much value. In fact, what role would EDUCAUSE even have as the oversight agency when it would be relatively a slam-dunk to attain the *.edu suffix and it's obvious most of the newcomers would really be *.COMs in disguise. To date, the regionals (and/or regional consortiums) at least have made their for-profit &/or relgious schools buck-up to embrace at some level the higher education construct.

    Thank you for this opportunity to comment.

  • Posted by:   Randall E. Bell  (rebell@aabc.org)
    Date: 7/12/2002 11:38:38 AM

    I am in full agreement with the proposal to broaden eligibility for inclusion of all institutions accredited by recognized agencies in the edu. domain. Given that such agencies are required to comply with all the requirements of USDE and/or CHEA and given that such accreditation is structured appropriately for the types of institutions accredited, exclusion of such quality institutions of higher education from the domain amounts to unfair discrimination. It creates a public perception that such institutions are second class or inferior in some way. They are treated as though they are not legitimate members of the higher education community. The reality is that our culture would be greatly improverished by the loss of these high quality members of the higher education community. I note that most of the AABC accredited institutions enjoy the .edu designation. Apparently, they were given membership in the domain before the current policy went into effect.

    • Posted by:   Samuel K. Bruce  (drsambruce@aol.com)
      Date: 7/15/2002 3:56:27 PM

      I am in full agreement with, and strongly urge the adoption of the proposal to broaden eligibility for inclusion in the .edu domain of all institutions accredited by agencies that recognized by USDE and/or CHEA. It would be unfair discrimination to exclude such quality institutions of higher education from the domain since all of the agencies and institutions are required to comply with all the requirements of USDE and/or CHEA, and since accreditation is structured appropriately for the types of institutions accredited. – Samuel K. Bruce, President, Wesley College, Florence, Mississippi

  • Posted by:   Dr. Churchill  (drcwc@aol.com)
    Date: 7/12/2002 10:02:02 PM

    I applaud this proposal from EDUCASE. The proposal represents a greater degree of fairness for all post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies."

  • Posted by:   Dr. Bruce Moyer  (bruce.moyer@vennard.edu)
    Date: 7/15/2002 6:36:57 AM

    I fully support the use of ".edu" by all institutions accredited by an agency approved by CHEA. These agencies are meeting common standards which are held high. Therefore we should be working together, not trying to separate ourselves.

  • Posted by:   Dr. Charles Dyer  (charles.dyer@moody.edu)
    Date: 7/15/2002 7:36:26 AM

    I support the proposed change and encourage you to expand the use of the .edu domain name beyond schools with regional accreditation to include those accredited by other nationally recognized professional accrediting bodies. To limit the domain name only to those with regional accreditation unfairly marginalizes and stigmatizes many schools with professional accreditation who, for various reasons, have not sought regional accreditation. They are legitimate schools of higher education and should have access to the .edu domain name.

  • Posted by:   Robert W. Cash  (bcash@mnbc.edu)
    Date: 7/15/2002 8:57:40 AM

    I defintely favor the revision that would allow all institutions who are accredited by the accrediting bodies recognized by USDE and CHEA to use the .edu domain. These agencies are reliable authorities concerning the quality of education or training offered by the institutions of higher education or higher education programs they accredit. To do otherwise is discriminatory.

  • Posted by:   Ruth Moyer  (ruth.moyer@vennard.edu)
    Date: 7/15/2002 3:51:48 PM

    I am in favor of this proposal!

  • Posted by:   Dr. Anne Gervasi  (agervasi@mail.dal.devry.edu)
    Date: 7/15/2002 9:48:03 PM

    I teach at a proprietary school that works very hard to maintain its regional accreditation. We know that our degree has merit and rigor because of accreditation; thus, I believe that any institution that uses the .edu domain name should also continue to qualify for regional accreditation. With the growth of distance learning and the cheapness of domain names, it would appear to the outside world that higher education cannot police itself. This would be dreadful.

    Although my primary responsibility is teaching, I also evaluate faculty credentials, and I am appalled by the "degrees" that some people attempt to use. I am also dismayed by the problems with higher education in other countries. Some of these institutions offer nothing like an American college course, but placement officials cannot seem to tell the difference. Whether a college uses .edu or some other designation would help with both student placement and hiring adjuncts.

  • Posted by:   Ralph Enlow  (renlow@ciu.edu)
    Date: 7/16/2002 6:36:43 AM

    As a former executive director of a national accrediting association (AABC), former chair of it's commission on accreditation, active participant in CHEA activities and discussions, first hand observer of the review activities of the USDE National Advisory Committee, and experienced peer evaluator in regional and national accreditation, I heartily support the EDUCAUSE board's proposal to grant access to the "EDU" domain suffix to all institutions accredited by a USDE-recognized agency. The "recognition" function for accrediting agencies is the proper domain of USDE and the Council for Higher Education Accreditation (CHEA). Each of these entities has clear, well-established, and widely-supported recognition criteria and thorough review processes. There is no reason for EDUCAUSE or any other organization to impose an arbitrary "de facto" recognition system which does not have a foundation in its own unique and well-substantiated criteria for such recognition.

    I commend the EDUCAUSE board for this reasonable and responsible proposed course of action.

    Ralph E. Enlow, Jr., Provost
    Columbia International University

  • Posted by:   Kenneth E. Mellendorf, Ph.D.  (kmellendorf@icc.edu)
    Date: 7/16/2002 7:55:31 AM

    Before deciding who gets ".edu", decide what ".edu" means. It currently refers to schools that are part of general sequences in higher education, sequences that do not limit a student to one narrow zone of careers. This is my impression of degrees and regional accreditation. Such institutions allow a student to significantly and repeatedly adjust his/her goals without having to start over. If this is what ".edu" is supposed to mean, then don't change it. If ".edu" is supposed to mean only "higher education", then do change it.

    Dr. Ken Mellendorf
    Math, Science, and Engineering
    Illinois Central College

  • Posted by:   Michael Murphy  (mike.murphy@pcmail.maricopa.edu)
    Date: 7/16/2002 9:42:58 AM

    I am strongly opposed to granting these other non-regionally accredited institutions access to the .edu domain name. Students have enough difficulty distinguishing between traditional colleges and universities and the suddenly-everywhere proprietary schools. To blur the line even further in the online world will only serve to heighten this confusion. Students may choose to attend a proprietary school for their higher education needs. But they should do so with full knowledge of the important differences between these organizations and their fully-accredited college and university counterparts. Colleges and universities undergo tremendous scrutiny by accreditation boards, government entities and the public to ensure our programs and practices meet the highest educational standards and ethics. For proprietary institutions to forego this rigorous scrutiny, then seek the same benefits as colleges who have passed it successfully, is not fair to colleges or the public they seek to educate.

  • Posted by:   Brenda S. Zicha  (bzicha@mcc.edu)
    Date: 7/16/2002 11:56:16 AM

    I am opposed to any expansion of the definition for the .edu URL. Students, researchers, and the public have come to know that the .edu domain means an institution is non-secular, non-profit, empirically based and accredited according to well known regional standards. To suggest that various religious, training or for-profit schools' accrediting agencies are on par with the well-known public regional accrediting bodies is to lower the bar so far as to make the .edu domain just another .com or .org for all intents and purposes. The USDOE should use a looser definition than EDUCAUSE when recognizing accrediting agencies as religious, training and for-profit institutions of higher learning have their place in a democratic society. However, many of the nationally accredited training schools do not even grant degrees, yet under this new proposal, they would be entitled to an .edu domain. Using this proposal as a standard, can their opposite, diploma mills, be far behind? Perhaps a new domain, such as .sch might solve this dilema?

  • Posted by:   Roger R. Hock  (rhock@pacific.net)
    Date: 7/16/2002 12:06:41 PM

    This is an excellent, long-over-due idea, especially as it pertains to the nation's community college systems, for the following reasons:

    1. Community colleges long ago ceased their sole function as "trade schools."
    2. Today, most community college systems' primary function is to provide high-quality, rigorous, lower division college courses that map onto 4-year college and university programs and offerings.
    3. It is clearly time to do whatever we can to reduce and eliminate any lingering perception that a community college is somehow separate from other institutions of higher learning, and to endorse the correct notion two-year college are an integral part of it.
    4. Some community colleges are making inroads into offering 4-year BA degrees in subject areas for which no programs exist in their geographical area.
    5. A small, but significant number of community colleges in California and elsewhere already have the .edu domain (apparently snagged before current policies were in place?). Approving it's use for all would proactively eliminate this seemingly unfair practice.
    6. Assuming all institutions approved for the .edu domain are accredited as proposed, what possible harm could this do?? Higher education should be for everyone, and we all must do everything we can to avoid the appearance of elitism.

  • Posted by:   Roger Hock  (rhock@pacific.net)
    Date: 7/16/2002 12:10:12 PM

    Just a question: Why is this discussion taking place in mid-summer when many faculty members are unavailable for comment? Won't this create an unrepresentative, and potentially biased sample of responses?

  • Posted by:   Dr. Ray Bromley  (ray.bromley@pcmail.maricopa.edu)
    Date: 7/16/2002 12:25:23 PM

    I favor the proposed change, since I think that most people would consider the edu suffix to denote that the purpose of the institution is education. This information is valuable in itself. A .com or .org implies the purpose is something other than education, and for a school to have it is confusing. I do not agree with those who see a .edu suffix as any sort of certification of quality, any more than a .com is taken by consumers as a certification of a high-quality business.

  • Posted by:   Robert W. Tucker  (robert.tucker@InterEd.com)
    Date: 7/16/2002 12:50:13 PM

    The proposed revision is appropriate. The current policy rests on presuppositions which are not defensible on empirical or, possibly, legal grounds. Similarly, concerns advanced against the proposed change appear to come from those who want to manage to a very small downside risk at the cost of de-legitimizing the very institutions that make the most important (albeit to some, the less glamorous) contributions to our economy and society (i.e., career schools, technical schools, professional schools). The marginal contribution to society of these schools is surely as great as or greater than than that of institutions currently approved for '.EDU'

    Robert W. Tucker, Ph.D.
    InterEd, Inc.
    208-938-5003 (fax)

  • Posted by:   Neil Thompson  (thone@barclaycollege.edu)
    Date: 7/16/2002 1:17:05 PM

    Barclay College in Haviland, Kansas supports the proposed revision to the restriction. We are accredited by AABC, an accrediting agency recognized by the USDE. We have also recently been accepted for initial candidacy by the HLC-NCA regional accrediting body.

  • Posted by:   Geoff Slipher  (slipherg@hotmail.com)
    Date: 7/18/2002 10:01:06 AM

    Cautiously optimistic: While I support your effort to change the method of determining eligibility for the '.edu' suffix, I also take issue with your methodology.

    A move from regional accreditation of whole institutions to more specialized accreditation of individual programs is necessary. After all, it seems that general regional considerations would be less able to determine the quality of a program than a body specializing in accreditation of that particular program area. Such a move should be accompanied by a great deal of forethought with regard to potential repercussions resulting from the change, and so this dialogue is both welcome and necessary.

    I side with many of the previous respondents in their view that not all accrediting bodies on the USDOE list seem appropriate for the ‘.edu' designation, but perhaps I am being too traditional.

    I have identified one concretely undesirable result that would arise under your current methodology:

    The USDOE list does not include the Accreditation Board for Engineering and Technology (ABET, www.abet.org), which is the main accreditation body for engineering, computer science and technology programs nation-wide. Nor does the Department of Education list include ANY accrediting agency for engineering programs. If not rectified, the current methodology would have the consequence of excluding schools of engineering from eligibility for the '.edu' suffix.

    To rectify this you should also include accrediting agencies that are approved by the Council for Higher Education Accreditation (CHEA, www.chea.org). CHEA has an additional 47 specialized accrediting bodies--see the list at (http://www.chea.org/Directories/special.cfm).

    How many other types of programs are excluded by your criteria other than engineering programs nationwide, and how to rectify?

    Also, just a question to ponder: what would the consequences be if one or more programs within an institution are not approved or are revoked from eligibility for ‘.edu' suffix—technical considerations (IT), reputation of institution at stake?...a possibility one must consider with this methodology.

  • Posted by:   M  (stevensm@boisebible.edu)
    Date: 7/19/2002 11:17:23 AM

    Boise Bible College is in total agreement with the proposed change. While we agree that we need to guard against granting equal status to "diploma mills," to suggest that only regionally accredited instituions are worthy of recognition is absurd. Our experience is that our academic standards are superior in many ways to those of many (if not most) State Colleges/Univeristies.

    We are recognized by the U.S. Department of Education, we meet the rigorous standards of AABC (our Accrediting Association) and we should be allowed to enjoy the use of the .edu URL.

    • Posted by:   John G. Di Liberto  (johng@islanddrafting.com)
      Date: 7/22/2002 7:07:59 AM

      We wholeheartedly endorse the proposed change. "Regionally accredited" as opposed to "Nationally accredited" is essentially a difference without distinction. Surely recognition by the U.S. Department of Education is sufficent to preserve the stature of .edu names, for all users.

  • Posted by:   Robert Amell  (ramell@thompsoninstitute.org)
    Date: 7/24/2002 10:30:58 PM

    This change is way overdue. I have fought this since the NSF originally had its grips on the .edu domain registration policy. This is common sense. If a web surfer is looking for an educational institution, shouldn't they have a .edu domain? National accreditation is as important as regional accrediation as this nation looks to hire employees with skills-based training. Many regionally accredited schools do not want this change since they have monopolized many areas of the educational process. When we have a monopoly, quality suffers do to lack of competition. The supreme court recently upheld voucher legislation proving that discrimination is not legal between the private and public education sectors. This .edu policy change follows in the steps of this landmark legal decision.

  • Posted by:   Roger J. Williams  (rjwilliams@accet.org)
    Date: 7/25/2002 7:28:52 AM

    Council of Recognized National Accrediting Agencies

    July 23, 2002

    Dr. Mark Luker, Vice President
    1150 18th Street, N.W., # 1 0
    Washington, DC 20036

    Dear Mr. Luker:
    The undersigned representatives of the Council of Recognized National Accrediting Agencies (CRNAA) strongly support the proposal to adopt the U.S. Secretary of Education's list of "Nationally Recognized Accrediting Agencies" as the eligibility criterion for postsecondary education institutions to be included in the .edu domain. The seven nationally recognized accrediting agencies that constitute the CRNAA presently accredit 3198 postsecondary institutions with total annual enrollments estimated at over 4 million students, in both degree and non-degree studies. We believe EDUCAUSE stands at the threshold of a great opportunity to embrace the full diversity of our community of postsecondary institutions, whose accredited status through agencies recognized by the U.S. Department of Education (USDE) provides a validated measure of quality.

    Discussions and correspondence between representatives of CRNAA, beginning last November, have provided a better understanding by all parties of the historical roots and current dynamics in the postsecondary education market- place. That marketplace demands a progressive, viable policy which is defensible, not merely in a court of law but, more importantly, in the public interest.

    The current restriction to regionally accredited institutions, formerly four-year degree and recently expanded to allow community colleges and other two-year degree institutions, is discriminatory and arbitrary, based on preference and convenience rather than necessity or intrinsic value. We hold our colleagues at the regional agencies in high regard, not in awe; and by any objective contemporary standards, most certainly including the recognition criteria (34CFR Part 602) utilized by the USDE for evaluating both regional and national accrediting agencies, we stand on equal footing as legitimate and credible agencies. In the face of such circumstances, it would be a challenge to defend the current policy of exclusion.

    Those issues aside, we wish to affirm the positive aspects to be served by EDUCAUSE's adoption of the proposed U.S. Secretary of Education's list of recognized accrediting agencies. In that regard, it is noteworthy that the recent website posting of CHEA's Database of Institutions Accredited by Recognized United States Accrediting Organizations, includes "approximately 6,500 institutions that are accredited by the 19 institutional acreditors recognized by CHEA or the U.S. Department of Education," of which 3198 are accredited by the seven CRNAA member agencies included in the database. In similar fashion, the American Council on Education's recently published its directory of Accredited Institutions of Post- secondary Education (AIPE) has, for the first time, included all the postsecondary institutions accredited by USDE recognized agencies, welcome nod to the common bond held with this important segment of the higher education community. Such databases enhance public awareness of educational resources on the internet, the search mechanism of choice for today's students, and, more important, readily assist the consumer in identifying credible postsecondary institutions. This benefit would be enhanced, and even expanded, with the rich diversity of offerings proposed for inclusion of the.edu domain name by agencies recognized by the USDE. At a time when "diploma mills" are proliferating and preying on the lack of public awareness about the distinguishing characteristics of a formally recognized accreditation process, we are all better served by proactive efforts to offer insight and information in the public's best interest.

    For these reasons we urge our colleagues at EDUCAUSE to take the necessary action in adopting the proposed policy-change suggestion identified in the Policy Comment Forum. Thank you for your consideration.

    Roger J. Williams
    Executive Director, ACCET
    Chair, CRNAA

    Carol A. Moneymaker, Executive Director, ABHES
    Harry L. Bowman, Executive Director, COE
    Elsie Scanlon, Executive Director, ACCSCT
    Michael P. Lambert, Executive Director, DETC
    Steve A. Eggland, Executive Director, ACICS
    Mark C. Gross, Chief Executive Officer, NACCAS

    • Posted by:   June Kirkpatrick  (june.kirkpatrick@jacobs.com)
      Date: 7/29/2002 12:05:47 PM

      It makes logical sense to accept this proposal. Providing a method/communication tool (by designating edu) will enable the user to more quickly and easily research schools/institutions. All people, whether in an education setting or corporate organization are using the internet for many multiple uses and a primary usage is research for the best information.

      There are many methods and types of education and anyone should recognize and understand the need for all types.

  • Posted by:   D. Finuf  (dfinuf@amedcts.com)
    Date: 7/26/2002 1:31:17 PM

    I find it amazing how traditional educators determine "academic quality". To assume that quality only exists in institutions that are regionally accredited is false and narrow minded.

    I have been part of one of the few institutions that have been accredited by a regional and national accrediting body at the same time. I can attest that quality is as much a bases for accreditation with a national accrediting body as it is with a regional accrediting body. Before bringing judgment against national accreditation you should become familiar with their purpose and their standards.

    I have much respect for institutions that are regionally accredited as well as those that are nationally accredited. This is not a competition! Both fit the needs of the students differently.

    Many comments listed prior have not read fully your proposal. "It should be revised to include all post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of Nationally Recognized Accrediting Agencies."

    This change would be welcomed.

  • Posted by:   Betty Howell  (bhowell@accis.edu)
    Date: 7/29/2002 10:29:26 AM

    On behalf of the over 9,000 students, graduates, faculty and staff of American College of Computer and Information Sciences (ACCIS), nationally accredited by the Accrediting Commission of the Distance Education and Training Council, I support the expansion of the eligibility criteria for DOT EDU domain names to include any institution accredited by any agency approved by the U.S. Department of Education.

    To restrict DOT EDU domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in the accrediting standards of regional and national agencies. The consequences resulting from this implied inferiority would be borne by the students and graduates of nationally accredited colleges as employers fail to recognize the legitimacy of a school because it doesn't have a DOT EDU domain name.

    EDUCAUSE is an excellent organization that provides many worthwhile services, but it is the U.S. Department of Education that is charged by Congress with regulating accrediting practices of both national and regional agencies. I urge the EDUCAUSE Policy Board to accept the determination of this legally designated department and to allow DOT EDU eligibility to all schools accredited by an accrediting agency recognized by the DOE.

    Betty J. Howell

    • Posted by:   Diane Johnson  (djhoock@earthlink.net)
      Date: 8/2/2002 8:33:42 PM

      As a student of the American College of Computer and Information Sciences (ACCIS), the restriction of DOT EDU domain names for nationally accredited schools, that are not regionally accredited, places a label on the students who choose distance learning.

      Institutions accredited by an agency recognized by the Department of Education should be eligible to use the DOT EDU extension. To limit the usage of DOT EDU indicates that not all institutions are equal in education. Can the quality of our education be judged solely on regional accreditation?

      I strongly implore the EDUCAUSE Policy Board to support the usage of the domain extension DOT EDU by all educational institutions accredited by an accrediting agency of the Department of Education, whether they have regional recognition or not.

      Diane Johnson
      Assoc. of Applied Science in Computer Programming
      Candidate for BA in IS
      Vice-Chair ACCIS Student Chapter of ACM
      Member Delta Epsilon Tau Intl. Honor Society
      Member IEEE

    • Posted by:   Lael Davis  (lael.davis@owenscorning.com)
      Date: 8/3/2002 11:26:27 AM

      The .edu domain should be given to nationally accredited learning institutions that establish the same or better educational standards and policies for their students. To suggest that a distance learning institution is less than a more traditional environment really is a conclusion made based on a lack of knowledge or understanding of that institution's educational practices. The only other possible reason for not including nationally accredited institutions that provide the same or better educational standards and policies as traditional enviroments would seem purely bias in nature. The reason for such bias could only come from an interest outside of the quality of education provided to students.

    • Posted by:   Joan M. Ford  (coedjoan@mindspring.com)
      Date: 8/3/2002 12:38:51 PM

      I, too, am a student at ACCIS. Were it not for distance learning, I would be unable to pursue a higher education.

      Although I was extremely skeptical of enrolling in a distance learning program, the .edu extension played a major role in my decision to do so. I have not been disappointed; my initial skepticism has been replaced by admiration for the professionalism of the staff and faculty, as well as for the relevancy and challenge level of the courses. I can state unequivocally that I would NOT have enrolled in a distance learning institution with a .com or a .biz, or even a .org extension.

      The .edu extension is invaluable to those of us whose only hope of furthering their education rests upon distance learning. Had I not enrolled prior to the restriction of the .edu extension to mere regionally accredited institutions, I would have been denied my opportunity to pursue an education, at a truly awesome institution, in my chosen career. To deny the .edu extension to nationally accredited institutions is tantamount to denying continuing education to countless potential students. I strongly urge EDUCAUSE to adopt the proposal to expand the .edu extension to nationally accredited learning institutions.

      • Posted by:   Jodi Perron  (loujodi@bellsouth.net)
        Date: 8/3/2002 7:44:20 PM

        I totally agree, Joan. I am also an ACCIS student. Without the .EDU extension, an accredited educational institution will not be seen as a legitimate school. With so many diploma mills out there, distance education tends to not get the respect it deserves. Actually, though, the course work is more challenging than any I've had in a traditional college. I know that I am getting the best possible education at ACCIS, and I am proud of my decision to enroll there. The .EDU extension should be available to nationally and regionally accredited institutions. If the school has earned their accredidation, why withhold the .EDU?

    • Posted by:   Russell L. Westbrook  (westruss@pacbell.net)
      Date: 8/3/2002 10:00:13 PM

      I concur wholeheartedly to Betty Howell's comments below. I support the expansion of the eligibility criteria for DOT EDU domain names to include any institution accredited by any agency approved by the U.S. Department of Education.

      Global communication is dramatically changing global education, opening new doors and opportunities, and removing the barriers of time and distance that impede educational opportunities for many. The very fact that we have a .edu domain in a world where none existed two decades ago is evidence of the Internet's growing importance in delivering quality education.

      Limiting .edu domains to regionally accredited institutions would be stifling to the evolutionary processes of our most important means of delivering of education. At best, such a move is stodgy and backward, based on outdated thinking. At worst, it is perhaps territorial and monopolistic. ~~

      Russell L. Westbrook
      Computer Science Student

      • Posted by:   Tina Alta-Greenlee  (altagret@hq.21tsc.army.mil)
        Date: 8/5/2002 12:00:33 AM

        I also agree 100% with Betty Howell's comments. I work for the military in Europe and have a very demanding, ever changing schedule. If it was not for the flexibility of ACCIS I would not be able to work towards my Bachelors Degree.

        I have taken classes over the years in a class room setting and have not truly been challenged in any way. ACCIS coursework is harder and actually more demanding of me as a student than the normal Class-Room environment.

        The eligibility criteria for DOT EDU domain names to include any institution accredited by any agency approved by the U.S. Department of Education should be approved.

        ACCIS, which would be effected by this is just as good, if not better than normal Regionally accredited institutions. If the VA will accept them to train their soldiers for life after the military (or to improve their current job performance) shouldn't your organization at it's least let them maintain a DOT EDU domain name?

        Tina Alta-Greenlee
        Computer Science Student

    • Posted by:   Tim Hagen  (teh1@accis.edu)
      Date: 8/5/2002 12:17:49 PM

      This change is most positively necessary. As a student of ACCIS I ask that this additional obstacle placed in the path of distance-educated students be taken away. I can personally vouch for the credibility of the college I attend, if it were not up to par I would certainly not be into my third year. Recognization of both government accreditations is vital in supporting the schools that uphold higher standards in teaching and accountability.
      Tim Hagen.

    • Posted by:   Jigar Patel  (jigar@usa.net)
      Date: 8/10/2002 4:13:40 PM

      As one of the students of ACCIS, I feel that any exclusion of nationally accredited educational institutions from using the DOT EDU domain is totally unfair and should not be allowed to happen.

      There is no proper basis to not allow nationally accredited schools, in fact, the education from these schools has been as good as regionally accredited institutions and in many cases far better from my personal experiences.

      Please do the right thing and support the edu domains for all accredited schools.

      Jigar Patel
    • Posted by:   John Colarusso  (jaysea_1@yahoo.com)
      Date: 8/11/2002 12:06:16 PM

      I support the proposal! Since enrolling in ACCIS I have found that the courses are more demanding than courses I have taken in the regionally accredited state schools I've attended in Florida. This form of on-line education gives educational opportunity to many that would have none. As long as standards are kept high (as in any educational institution) and accreditation is maintained (Regional or DOE), I see no legitimate reason for exclusion of .edu domain names.

  • Posted by:   Dick Kruger  (dkruger@pcdi.com)
    Date: 7/29/2002 11:15:17 AM

    I wish to voice my strong support for the expansion of the DOT EDU domain name eligibility criteria to include any institution, secondary or postsecondary, that is "accredited by an accrediting agency recognized by the U.S. Secretary of Education." This minimal expansion would sharply reduce the unfairness and confusion of the current eligibility criteria.

    Ironically, unless eligibility is expanded as suggested above, some non-accredited institutions will be allowed to use the DOT EDU domain name through grandfathering, while some accredited institutions will be precluded from using the DOT EDU domain name. Among those shut out from use of this identifying domain name would be accredited institutions that are focused on distance education, the delivery system that is synonymous with the Internet. Education consumers search the Internet to identify institutions that are appropriate to their diverse education needs. The current domain name eligibility criteria limits those consumers' access to nationally accredited schools. Access to the DOT EDU domain should not be based on issues of national versus regional accreditation, but rather based on whether an institution, secondary or postsecondary, is accredited by an accrediting agency recognized by the U.S. Secretary of Education.

    Students often tell us they do not understand why some accredited schools do not have the DOT EDU domain name. This exclusive designation, by virtue of its exclusions, confuses the very audience it was created to help. When a school is nationally accredited by an agency recognized by the U.S. Secretary of Education, to arbitrarily exclude that school from using the DOT EDU domain name seems in opposition to the goals of the U.S. Department of Commerce. I understand that only about half of the postsecondary institutions are regionally accredited. If the eligibility criteria were changed to include, rather than exclude, nationally accredited institutions, the result would be a more accurate and useful designation for the education consumer.

    Richard A. Kruger
    Professional Career Development Institute

  • Posted by:   Dr. Albert L. Reyes, Hispanic Baptist Theological School  (alreyes@hbts.edu)
    Date: 7/29/2002 11:20:36 AM

    I am in agreement to revise the policy to expand availability of edu web addresses to nationally or regionally accredited institutions. As a member of the Accrediting Association of Bible Colleges, which falls under the supervision of CHEA and DOE, we are also part of the higher education family of institutions in the United States.

  • Posted by:   Martin S. Cohen  (cohenms@jevs.org)
    Date: 7/30/2002 9:36:33 AM

    As a representative of a non-profit post-secondary school accredited by the ACCSCT (Accrediting Commission Career Schools and Colleges of Technology), I feel strongly that there is no basis to distinguish regional from national educational institutions with regard to the use of the .edu domain name. Congress itself, in the Higher Education Act and in the Department of Education regulations does not employ the regional/national distinction. In addition, the Commerce Department has stressed that domain name managers must be responsive to the entire community they serve; to use .edu so restrictively is contrary to that policy. Our consumers and users are confused by the restrictive criteria and assume that .edu is only used by legitimate educational institutions when, in fact, many of such institutions are precluded from the use of .edu. We feel that our school has been disadvantaged by its lack of access to the .edu domain name since many of our applicants for admission have questioned us regarding this point. It is our hope that EDUCAUSE will support schools like ours by enabling us to access the .edu domain name. Martin S. Cohen
    Director of Student Sersvices
    Orleans Technical Institute
    Philadelphia, PA 19111-2899

  • Posted by:   Jon R. Cline  (jon@rsiaz.org)
    Date: 7/30/2002 3:30:59 PM

    Without question, this policy should be revised as proposed. Such an expansion not only serves students better, it also will eliminate discrimination present in the current usage and more closely conform to the direction and policy of the Commerce Department, which has ultimate responsibility for the decision.

    Please consider that the Department of Education uses the same set of recognition criteria regardless of whether an accrediting agency is regional or national in nature. While this does not equalize the value of accreditation in the minds of all who wish to espouse an opinion, it offers insight to this issue from the only authority available at this time. The fact is, the Department of Education has established criteria by which to judge all accrediting agencies. We should use their expertise accordingly.

    As a policy matter, the Commerce Department was clear in stressing to domain name managers that the entire community be served, not just segments of the community. It is ludicrous to assume that "higher education" encompasses only regionally accredited schools. While the missions of nationally and regionally accredited schools may not be identical, they are certainly complimentary, and the students served are from identical demographic cohorts.

    This brings us to the issue of students. At the heart of this matter, it is the students who should be served by the system, not schools. Students should have the confidence that when they need to contact the institution of their choice, they can logically enter the name of the school with the .edu extension and get where they want to go. In essence, it is not my institution that will benefit from a .edu domain name, it is the students who will find the system more user friendly and logical.

    Finally, by virtue of the current discriminatory policy, it can be argued that EDUCAUSE is unduly subjecting itself to claims of restraint of trade. In spite of the claims made by some that "true" higher education institutions are not involved in commerce, all institutions are reaching out to the same segment of the population in their marketing efforts. A quick review of the broadcast commercials, brochures and direct mail pieces demonstrates that regardless of profit motive or control, all institutions are involved in fundamental commercial activities. Restraint of these activities should be carefully considered for negative responses.

    Thank you for the opportunity to comment on this issue. Your efforts are appreciated.

  • Posted by:   Wendy Grogan  (info@abdill.com)
    Date: 7/30/2002 6:22:33 PM

    We, Abdill Career College, are currently in the Application and SER process in hopes of becoming accredited. After reading the information regarding the .edu top level domain policy, I feel that the restriction placed on career colleges would damage our ability to operate as an accredited school. The accreditation boards determine the elegibility, and once deemed worthy, the accredited school should have access to this top level domain.

  • Posted by:   Susan Curilla  (scurilla@computerquest.com)
    Date: 7/31/2002 9:21:04 AM

    As the Director of Administration for Computer Quest Technical Institute and a colleague of ACCET (Accrediting Council for Continuing Education & Training), our school concurs that eligiblity for regionally accredited institutions to receive an .edu domain name be expanded to include institutions accredited by the United States Department of Education recognized regionally or nationally as an accrediting agency. We believe this to be sound and reasonable.

    This should not be a discussion of religious beliefs, personal prejudices or marketing issues. This is a domain name, for goodness sake, and time, money and efforts should not be wasted at a government level over this subject when there are so many more important educational issues needing to be addressed.

    Our most important goal and your most important commitment should be the opportunity to freely offer the public the choice of education in whatever field they so desire.

    Therefore, I would agree that a school accredited by a nationally or regionally recognized accrediting agency which is recognized by the United States Department of Education should be entitled to obtain an .edu website.

    Susan Curilla
  • Posted by:   Roseanna M. Dodson  (rdodson@daymarcollege.com)
    Date: 7/31/2002 2:38:25 PM

    Daymar College is a two-year, degree granting, career college. Our Mission Statement affirms that we provide a warm, friendly, nurturing, atmosphere where students can learn the skills required, to obtain the jobs they need, to have the lives they want. As a degree granting institution, we have been guided by our Mission to offer quality educational programs that enable our graduates to secure excellent career positions. We are nationally accredited by the Accrediting Council of Independent Colleges and Schools (ACICS). Additionally, we are a Microsoft IT Academy, Prometric and MOUS testing sites, and our Paralegal Studies program is approved by the American Bar Association (ABA). It seems unreasonable that we cannot be granted an 'edu' address since our Mission and our focus is education. I fully support the proposal to include post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies" to be eligible to receive .edu names.

    Roseanna M. Dodson
    Executive Director
    Daymar College
    3361 Buckland Square
    Owensboro, Kentucky 42301
    Phone: (270) 926-4040
    FAX: (270) 685-4090
    email: rdodson@daymarcollege.com
  • Posted by:   James Mader, Ph.D.  (boxjmm@piainfo.org)
    Date: 8/1/2002 7:18:36 AM

    The current policy is discriminatory in nature, and tends to give an unfair recruiting advantage to institutions awarded the .edu domain. Any postsecondary institution accredited by a federally-recognized commission should be accorded the same level of regard from a domain name manager that is granted by the Congress of the United States and the U.S.Department of Education. I question whether the current policy would be able to withstand a strong legal challenge, especially when U.S. Commerce Department tenets are examined.

  • Posted by:   Dr. Mike Toben  (mtoben@pscc.edu)
    Date: 8/1/2002 4:52:16 PM

    I concur with the proposal. It would only lead to confusion to have some accredited institutions designated as .edu and others as not. This has implications for those searching the net for educational institutions and for those who know we are an educational institution and wondering why we don't carry the extension as other educational institutions. KISS.

  • Posted by:   Nancy Toner Weinberger  (medmass@bellsouth.net)
    Date: 8/2/2002 11:18:33 AM

    I am the Director of the Medical Arts Massage School in Raleigh, NC. We are accredited by ACCET, and are a Title IV school. A high school diploma is required for admittance into the program, although many of our students hold college degrees. We hold to rigorous educational standards, and in my opion, should be permitted to use the .edu domain suffix for our website.
    Thank you.

    • Posted by:   Joseph Davis  (jldavis@netins.net)
      Date: 8/2/2002 10:05:36 PM

      At American College of Computer and Information Sciences, the quality of education I am receiving is better than the state funded university courses I have attended. The subject material is comparable with the subject material authored by professors from top level schools such as Princeton. I would not sacrifice the quality of education received for the sake of a specific "accreditation" or .edu extension but I believe that the .edu extension should be extended to schools such as ACCIS no matter who recognizes the accreditation.

    • Posted by:   Darcie Schoenfeldt  (darcies@stargate.net)
      Date: 8/2/2002 7:44:47 PM

      This proposed change would go a great dis-service to you and to all of those enrolled in institutions affected by this change. I am currently enrolled at the American College for Computer and Information Sciences (ACCIS).

      The work I complete is the same as the work I would complete at any other college. The only difference is that I am self-taught and do not have any on-campus requirements. Other institutions offer the same option, online classes, or distance learning.

      The degree(s) I will receive when I graduate is precisely the same as one I would receive at any other 4-year college. I have all the same requirements for graduation and a strict grading scale.

      For these reasons alone, I do not believe your change is worthwhile. In fact, I think it is very unfair and injust.

      Thank you.

    • Posted by:   Mark Wenham  (markwenham@cfl.rr.com)
      Date: 8/2/2002 8:21:49 PM

      If the US Department of Education recognizes an institute's regional or national accreditation then it would be unjust and inequitable not to allow that institution to use a .edu domain name extension.
      Please accept the current proposal.

    • Posted by:   Leslie Johnson  (leslijoh@nmsu.edu)
      Date: 8/2/2002 9:20:24 PM

      Do you realize the disservice that you are doing to students who take part in distance learning programs? By excluding schools that are not regionally accredited, you are closing the doors of opportunity to a great many people. By taking away their right to the .edu domain, what else will they register themselves under. Why .com of course! This is an *insult* to the higher education system. My mother is finishing her bachelor's degree through distance learning, and I am working on my master's at a traditional state university. However, after examining the course work, programs, and faculty interaction in her distance learning program, I can not help but feel that she is at the true educational institution, while I am being farmed through a company where I am nothing but an account number. If you insist on toying with the .edu domain name, I say make it all or nothing. Either allow all recognized educational institutions their right to a .edu domain or change everyone to .com. After all, from the highest ivy leagues to the lowliest state colleges, aren't they all just selling a piece of paper that grants you a higher salary in the workplace?

    • Posted by:   Kevin Queen  (k@kdqueen.com)
      Date: 8/2/2002 9:22:44 PM

      I think it is imperative that national accreditation be the litmus test for .edu domain registration.

      Our nation's educational needs exceed the narrow, and at times self-serving, scope of the regional accreditation boards. The nature of educational needs in American society is not bound to traditional academic institutions as supported and defined by the regional boards. This domain needs to serve the national good by acting as harbor for the multitude of quality educational opportunities represented by our nationally accredited institutions.

      I have both a bachelor's and a master's degree from regionally accredited institutions, as well as a bachelor's from a nationally accredited institution. There is absolutely no doubt in my mind that the long-term benefits of both are comparable. The greater value though was clearly the program that accommodated mine and my employer's needs by providing a focused curriculum in an environment that centered less on late adolescent growing up and life as a full time student, and more on the knowledge, understanding, and skills critical to my success throughout my career. Expecting regional accreditation boards to encompass both approaches is not realistic, and excluding nationally accredited institutions is a national disservice.

      By all means, include nationally accredited institutions in those qualified to apply for .edu domain registration.

      • Posted by:   Kevin Poindexter  (kpoindexter@selcva.org)
        Date: 8/5/2002 10:46:14 AM

        Very well said. I echo your sentiment whole-heartedly. As a student of both national and regional education I can say the experience I gained at the nationally accredited institution has been much more beneficial to my career pursuit, more challenging, and unquestionably more focused.

        Limiting your accreditation standards to regional accrediting bodies definitely draws an unwarranted line of inferiority. The current policy needs to be changed to incorporate all institutions recognized by the Dept. of Education. Not doing so is a true disservice to a nation of prospective students, card-carrying national institution graduates, and legitimate schools.

    • Posted by:   Dan Svoboda  (deslizam@hotmail.com)
      Date: 8/2/2002 9:52:37 PM

      Being a student at a distance education institution accredited by the DETC, I find it strange and unfair that nationally-accredited schools are not currently allowed to apply for .edu domains. I wholeheartedly agree with the new policy suggestion and believe it will grant greater legitimacy to institutions that educate people and yet, for one reason or another, are not regionally accredited.

      Many critics will argue that all we are talking about is a domain name! However, I believe many potential students of otherwise great schools will hesistate to apply to those schools in the future if their web addresses do not sport the "socially accepted" .edu internet address. I can imagine students who are about to enroll at a good, nationally-accredited institution suddenly changing their minds because the internet address of their school ends in .org or .com. That would be a shame, and would not happen if the proposed policy change is passed.

      Last, but not least, the situation overseas should be considered. In many other countries, some with remarkably different accreditation schemes, any government-recognized school can apply for and use either a .edu or .ac.XX address. The University of South Africa, for example, is a huge, distance-ed only school. Their internet address is unisa.ac.za. Why shouldn't American distance-ed only schools be seen as equally legitimate?

    • Posted by:   ofer  (oferlaor@hotmail.com)
      Date: 8/2/2002 11:50:59 PM

      .EDU should not be restricted in such a manner. Regionally accredited institutions, as well as locally accredited ones should all be eligable for .EDU domain extension.

      By limiting .edu to nationally/regionally accredited schools - local institutions are automatically "downgraded" to second class, although their educational merits may compete with the bigger nationally accredited schools.

      There is no reason to create a class system in the .EDU domain and it should provide full access to ALL accredited institutions, both regional and local.

    • Posted by:   Burt Anthony Bialozynski  (burtdayt@bellsouth.net)
      Date: 8/3/2002 1:48:23 AM

      Dear Educause,
      I have never been as Intellectually Challenged as I am now, being currently enrolled as a student at www.accis.edu. This is a Nationally Accredited Institution that is grandfathered in, and is included in this policy of permission to use and .edu address, because it has a current and active .edu address.

      Not allowing future post-secondary schools to receive a .edu address because they are nationally accredited, and not regionally accredited, would severely cripple the credibility of the degree I will someday EARN from my college. I am Earning that degree step-by-step with a Great Deal of Toil and Sweat.

      My God, man... this material is so compressed and intense that the only metaphor that I can give for the Grit and Determination mustered to move forward to the next level of comprehension is that it is "like swimming in pea soup".
      I have to take 'baby steps'.

      I have attended State-Funded Public University lectures. Being a mere dot in a 500-seat-auditorium filled to near capacity made it difficult, if not impossible, to get the professor to explain a salient point in a different way that would allow that 'magic' light bulb to pop on in my mind as an indication of the satisfaction and joy of my comprehension of the material suddenly flooding my being.

      I have the option of several professors who are but a phone call away.

      And That Professor who is referenced in the above experience, who does not even know me as a person, let alone as a human being; who did not remember my name, who could not possibly have the slightest inclination of what I know or do not know, CURRENTLY HAS THE POWER AND THE AUTHORITY TO TELL THE WORLD WHAT I HAVE OR HAVE NOT MASTERED IN MY STUDIES WITH THE FINALITY OF HIS SEAL OF APPROVAL OR DIS-APPROVAL GIVEN TO HIM BY THIS CURRENT POLICY.

      I AM RESOLUTLY AND UNEQUIVOCALLY -- F O R T H E P R O P O S A L -- OF REVISING THE CURRENT POLICY -- to include all post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies."

      The way that the current policy stands is akin to this scenario: That of the individual states of this Beloved United States of America DICTATING the validity or invalidity of the Sacredly Held and FEDERALLY Implemented Constitutional Law of The Land.

      If this policy remains as it is, for the rest of my life, my contemporaries will view me with an incredulous eye as to the mastery of my skill.

      Wherever I go, and whatever I do, I will continually be questioned as to my competence; sneered at, jeered at, and double-guessed.

      I cannot live like this.
      Please change this policy.
      Thank You,
      Burt A. Bialozynski,
      American College of Computer and Information Sciences

    • Posted by:   Jim Null  (info@jimnull.com)
      Date: 8/3/2002 5:54:19 AM

      I do not support this agenda. I see it as another form of social engineering and manipulative control where organizations are attempting to create unfounded regulatory standards. I support inclusion rather than exclusion on this topic.

    • Posted by:   Axel Pantelmnann  
      Date: 8/3/2002 6:13:27 AM

      I believe that as long as Regional and National education standards are high and well regulated, that the .EDU domain should be open to all institutions. The focus for all institutions should be to obtain the highest level of education possible for all students by whatever means necessary; that also means meeting local accreditation as well as national accreditation standards of education.

    • Posted by:   Mickey Park  (mpark@comcast.net)
      Date: 8/3/2002 7:04:56 AM

      I would like to see schools grandfathered in that already have the edu domain status. Some distance learning programs like ACCIS that offer online studies have had this status, and it would be a hardship burden costly and otherwise to be forced to change now.

    • Posted by:   Kevin C. Potter  (kcpttr@bellsouth.net)
      Date: 8/3/2002 7:09:05 AM

      I am currently a student at ACCIS and they have recieved their accreditation from DETC. They had to meet the standards that DETC requires in order to qualify. Whether the accreditation is regional or national shouldn't be the issue. If the accrediting agency is legitimate, then I think the .edu domain should be assigned.
      Kevin C. Potter
      ACCIS Student - Bachelor of Science in Information Systems Program.

      • Posted by:   Keith Humphrey  (wayimp@yahoo.com)
        Date: 8/3/2002 10:42:02 AM

        I am also a student at ACCIS. I have also attended regionally accredited colleges, and I think the issue comes down to this: Regionally accredited institutions are subsidized by government money (Title IV grants) and this impedes their incentive to innovate and pursue excellence in education. Students are brought to them by financially necessity (they cannot pay their tuition otherwise), and the desire of the student for a better education is less of a factor. Why should they trim administrative fat and serve the students better if Uncle Sam is underwriting the whole thing as it is? Regionally accredited bodies are intimidated by the prospect of having to compete with other schools on the basis of academics alone. They know schools that are driven by the needs of the marketplace can beat them hands down. They also know that students who pay their own way are more motivated to choose a school on the basis of quality of education, and this will leave them far behind. In order to maintain the status quo, and continue to fatten themselves at the expense of taxpayers, regionally accredited institutions have resorted to political means to marginalize alternative schools that they rightly perceive as a threat to their corrupt practices. As long as they are allowed to do this, it hurts only students and taxpayers, and helps only well-paid educrats.

        • Posted by:   John Colarusso  (jaysea_1@yahoo.com)
          Date: 8/11/2002 12:18:28 PM

          Well said! I am also a student at ACCIS and I also have attended regionally accredited state schools. For the most part, I see no emphasis on improving courses in these schools, in fact, some of the courses they are teaching obsolete, or nearly obsolete in the IT field. Schools such as ACCIS that don't get Title IV welfare must stay on the cutting edge to survive thereby giving outstanding educational opportunities. :)

    • Posted by:   Peter Thomas  
      Date: 8/3/2002 7:37:38 AM

      The current policy hurts nationaly accredited schools. I just started school online. These are all real classes. Not some pay and get your degree that is hurting the market today. The current policy hurts these "real" schools.

    • Posted by:   Frank Nash  (edu@nashes.net)
      Date: 8/3/2002 7:38:52 AM

      The proposed attempt to restrict the .edu handle is exclusionary. Many regional institutions provide quality educational products without having been enrolled on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies."

      This attempted exclusion is unfair. All regional and nationally accredited institutions should be allowed to register as a ".edu". Anything else would be unjust. Let the people (/students) decide. I strongly suggest that ALL universities, colleges, seminaries and higher educational institutions be allowed to register for domain names ending in ".edu."

      This exclusionary tactic was obviously devised to restrict all others and protect financial interests of traditional 4-year colleges. I would again like to state my agreement with the revised change and to allow ANY institution accredited by a "United Sates Department of Education recognized regional OR national accrediting agency" access to the .edu domain name.

      I sincerely hope that my comments are beneficial.

    • Posted by:   Timothy W. Wilshire  (tim_wilshire@hill-rom.com)
      Date: 8/3/2002 7:43:41 AM

      I believe that the restricting of Nationally Accredited institutions from the use of the .edu domain is wrong! Times have changed since regional accreditation was accepted as the "gold standard". With the advent of the internet and the World Wide Web, education is reaching many individuals who would have otherwise been unable to receive an education. Nationally accredited institutions have been seeking out these individuals and providing training and knowledge to them. I have received an AS degree from an accredited college where a structured class format was the norm. I have attended Florida State, Old Dominion, Northern Ky University in a "normal" classroom-instructed surrounding. I now take Computer Science courses in pursuit of a BS degree in Computer Science. I am receiving this education via the internet. I have found that the time and effort required to perform these studies are just as demanding,if not more so, than programs I have attended in the past at regionally accredited institutions. I just feel that limiting the policy to just regionally accredited institutions is limiting the future evolution of higher education.

    • Posted by:   Gary C. Infinger  (GInfinger@attbi.com)
      Date: 8/3/2002 8:13:41 AM

      Restricting the use of ".edu" domain names to only regionally accredited colleges implies that nationally accredited colleges are inferior to those with regional accreditation.

      I have attended school at both regionally and nationally accredited schools and have found that both were challenging and I learned a great deal at both schools.

      The US Department of Education establishes the criteria for accrediting agencies. Therefore, it is this department that is actually accrediting.

      The answer to your question is fairly clear. All accredited colleges that have accreditation from an accrediting agency, approved by the US Department of Education, should be allowed the use of ".edu" domain.

      • Posted by:   Mel F. Bailey  (mel@centralus.com)
        Date: 8/3/2002 10:30:28 AM

        As an internet user, I want the domain suffix to indicate the type of site I am visiting (.edu). I am the best person to judge the content offering I browse at that site, not you, NEVER, EVER!

        If an organization says they are educational then they should have a www.domain.edu named site. Everyone in this whole wide world knows to "Let the buyer beware". Why should it be any different for domain names?


        • Posted by:   Chuck Johnson  (DrChuck35@aol.com)
          Date: 8/12/2002 12:48:49 AM

          What if they say they're educational, but in fact they're a gaming casino or a furniture factory?

    • Posted by:   David P. Babcock  (dbabcock46@hotmail.com)
      Date: 8/3/2002 8:25:54 AM

      I support the proposal. To restrict the .edu domain to regionally-accredited institutions is to let the tail wag the dog. "Accreditation", if it is to remain an important benchmark in evaluating educational institutions, must keep abreast of newer learning modalities. The U.S. Department of Education, in its recognition of agencies that accredit distance-learning schools, realizes this. EDUCAUSE will be doing the sensible thing if it aligns its application of the .edu domain with the DOE view of what is and what is not education. This view may not be perfect, but where it fails, the failures should be addressed at the level of DOE's recognition of specific accrediting groups, or at the level of the accreditation of a specific institution--not by setting the assignment of .edu domains at odds with DOE's long-standing view of what is and what is not education. EDUCAUSE is wise to seek to correct a policy that no doubt was well-intentioned, but is very seriously flawed.
      David P. Babcock MSCS candidate, American College of Computer & Information Sciences

    • Posted by:   George Glen  (gglen5@comcast.net)
      Date: 8/3/2002 9:36:26 AM

      I believe it is very important that this policy change be adopted. Here is why: To restrict ".edu" domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in accrediting standards of regional and national agencies. I believe that a restriction of this type would restrict the ability of adult learners to benefit from further education due to schedule and job restrictions. I believe that such studies are as demanding, if not more so, than programs that I have attended in the past at regionally accredited institutions. The implication that you worked less hard to receive your degree credits is unfair, unfounded, and damages the integrity of an individual's education.

    • Posted by:   Ron Braley  (braley@aero.und.edu)
      Date: 8/3/2002 10:17:11 AM

      I certainly support this!

    • Posted by:   jack donn  (jdonnsprint@earthlink.net)
      Date: 8/3/2002 11:06:54 AM

      To restrict ".edu" domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in accrediting standards of regional and national agencies.

    • Posted by:   Ken Stewart  (stewarts@t-online.de)
      Date: 8/3/2002 11:24:49 AM

      This is silly. Stringent guidelines are set forth for an institution to become accredited, either regionally or nationally, therefore, these bodies have developed strong programs to provide what is the foundation of making a better nation ... education. To say one is more worthy than the other is unfounded and very biased. I'm completing an Info Systems degree through correspondence because that is all I can do with my job schedule. My school is nationally accredited and after attending traditional colleges, one major university and one two-year university, I find the correspondence to be just as demanding for some and even more demanding on most courses. The very few studies that have been conducted where correspondence students and traditional students were compared showed the educational advantage to the correspondence students. Bottom line: Amend this policy to include all accredited institutions meeting the approval of the US Dept of Education.
      Ken Stewart

    • Posted by:   Diane Schreiber  (dschreibe@yahoo.com)
      Date: 8/3/2002 12:01:31 PM

      I am a student, working on a degree for the third time in my life. I am in support of this change to allow all accredited post-secondary institutions. Having the .edu name makes it easier for someone like me to find schools. Having it restricted to only certain accreditations can easily cause potential students to miss some great opportunities.

    • Posted by:   Randy Harris  (randyharris@ameritech.net)
      Date: randyharris@ameritech.net

      I urge Educause to immediately adopt the proposed expansion of eligibility for .edu names. The restriction to regionally accredited institutions is entirely arbitrary. The criteria for eligibility should be be academic quality alone. Since no empiric measure of such quality exists the closest substitute is requirement of adherence to standards set forth by accreditors approved by the US Dept of Education. Expanding the eligibility to include all appropriately qualified institutions and only such institutions is the most effective means of minimizing the harm caused by organizations inappropriately using the .edu extension today.

    • Posted by:   Joel Botwinick  (nynexjo@optonline.net)
      Date: 8/3/2002 6:22:55 PM

      First let me state that the only expertise I have in these matters is related to my twenty odd years of pursuing knowledge in a wide spectrum of disciplines, using various platforms. Curiosity and the hunger for that knowledge are the only criteria I use in determining whether an institution can help me reach those goals.

      This whole business about accredation seems to be nothing more than a beauracratic rubber stamp. I have attended schools which were both regionally and nationally accredited and found their offerings outdated, their methods unintuitive and their fees disproportionate to the quality of heir faculty and administrative staff. Conversely, I have attended schools having no accredation and found them to be marvelous vehicles of learning and discourse.

      I would like to see an organization similar to Consumer Reports, handle the evaluation of educational platforms. The Department of Education is a political beast controlled by special interest groups and stymied by tons of pork barrel legislation.

      As to what criteria is used in determining whether an organization is eligible for one domain or another, should not even be an issue of quality. The true issue should be, is the organization's main thrust appropriate to that domain. The rest is a matter of consumerism.

      As an end user, when I search for schools on the internet, I just want to be certain that what I find are schools, not porn sites. I long ago learned that accredation does not a good school make.

    • Posted by:   Robert Slap  (rslap@attbi.com)
      Date: rslap@attbi.com

      I Support this proposal to include both regional and national accredidation agencies. Education methodology is changing to meet the demands of a modern workforce. Adult as well as traditional students need alternative methods to receive additional educational opportunities in addition to the traditional university model.

    • Posted by:   Shyamasundara Dasa  (shyam@BhaktivedantaCollege.org)
      Date: shyam@BhaktivedantaCollege.org

      We are glad that Educause is reconsidering its present position, it indicates to us that it is sensitive to the needs of those it serves and flexible enough to make appropriate changes. Having said that, the current proposal to expand the eligibility to those institutions appearing on the DOE list is STILL TOO RESTRICTIVE.

      I propose that it should go back to the previous system where a school approved by the State, in which it operates, to grant degrees and appearing on the State's list of Colleges and Universities be qualified for the EDU domain.

      In November 2000 our school (Bhaktivedanta College) made inquiries from Network Solutions to get an EDU domain name for our college. They gave us instructions what to do to fulfill the conditions. It took some time but recently we got our letter of approval from the North Carolina regulating body. This would then have qualified us to get the EDU domain name. However, when I recently contacted Network Solutions to continue where we had left off I was informed of the present changes.

      Our school, the Bhaktivedanta College, a seminary for training Vaisnava priests (a Hindu sect) could never be accredited by a regional accrediting body because they are by definition averse to theological schools. I detailed this and other concerns in our letter to you dated April 11, 2002. It should still be on file.

      The proposed policy change of awarding the EDU domain to schools on the DOE list would not be a solution for us. Since we are one of only two schools of its kind in the country we do not have an accrediting body of our own what to speak of one listed with the DOE as do those of the Christian and Jewish faith. Hence we propose a return to the previous system. Or, that Educause, being sensitive to the facts, make provision for our unique position.
      I would now like to make a few comments based on reading ALL the previous postings to this forum:

      Are COM domains only awarded to Fortune 500 companies? No they are not. Let any entity operating as a school use the EDU domain. If a person surfing the web cannot tell the difference between MIT or Princeton and the "Paducha Flats Business College" they should be ejected from the gene pool.

      Educause should not have to be in the position of policing the standards of education, as some would have you. Let the appropriate bodies at State level determine if an entity is qualified to operate as a college or university. If the school meets State standards let them have the EDU domain name. Let the State worry about "diploma mills" that is their business not yours. Simplicity has its virtues.

      The accusation that "for profit" schools should not be allowed to have an EDU domain seemed rather odd considering that a year's tuition at an Ivy League school could easily surpass the income of 5 average families in Jackson County, North Carolina, where the Bhaktivedanta College is located. Our school, on the other hand, doesn't charge any tuition from its students, but strictly following the codes of our ancient traditions, depends only on donations.

      The premise that currently the EDU domain guaranteed to the consumer only a certain type of educational experience is clearly faulty. There are plenty of Bible Schools with EDU domain names to attest to that. In order to get the kind of "academic cleansing" by those who desire a monopoly then all those who already have the EDU domain name would have to be re-certified to see if they fit that standard. This will never happen. Such out right discrimination against theological schools would never be tolerated in the USA, especially after 9-11. Serious legal action would be a certainty. Returning to my point, the EDU domain name as distributed today cannot guarantee any type of educational experience; hence any argument to do so is flawed.

      Related to the above, the premise that schools with EDU domain should be reserved for "empiric" schools was rather galling. This "religious opinion" of the "born again materialists" fails to consider that if it is appropriate to study the creation why not also study the Creator? It also fails to recognize that almost every great university in the world today was originally a school of Theology; one need only read the history of schools like Oxford or the Sorbonne to attest to this fact.
      Thank you for the opportunity to comment on this issue. I beg to remain...

      Yours faithfully
      Shyamasundara Dasa President, Bhaktivedanta College

    • Posted by:   M Grill  (mgrill@vistatech.net)
      Date: 8/4/2002 6:03:15 AM

      I currently work in a regionally accredited community college, where I also obtained an A.A.S. degree. I have almost completed a B.S. degree from a nationally accredited college. I have found no difference in the quality of education from either.

      "Accreditation is an integral part of our system of higher education. Our system consists of both public and private institutions with a wide range of types of missions, from national research universities and regional comprehensive institutions to liberal arts colleges and very small faith-related colleges to community colleges and vocational institutions. The genius of this system is that, unlike other countries, we do not have mandatory national curricula for colleges; we do not have a national ministry of education that regulates academic standards; and students are free to choose what type of education they pursue depending on their ability, financial resources, and educational goals. Because it developed from this diverse set of institutions, accreditation is a flexible and adaptive process. Institutions that seek accreditation can do so from a wide range of accrediting organizations ? from national bodies that are oriented to a particular type of institution, to regional organizations that encompass a wide range of types of institutions, to specialized organizations that focus on a single discipline or profession". (CHEA accreditation defined)

      What makes regionally accredited institutions any better than nationally accredited ones? Nothing, from my experience. "Accreditation aims to assure academic quality and accountability, and to encourage improvement." (CHEA)
      So why differentiate between the two accreditations. Both should be allowed to use .edu names.

    • Posted by:   Terence McCann  (terence@ptdprolog.net)
      Date: 8/4/2002 7:30:03 AM

      I believe that a little common sense should prevail here. If an institution of higher learning is good enough to be accredited by an agency that is itself recognized by the US Dept of Education, that it should be assumed that that institution is on par with schools that happen to be regionally accredited. Doesn't the US Dept of Education apply the same criteria to all accrediting agencies when evaluating thier ability to accredit schools? Therefore, why would nationally accredited schools be considered inferior to regionally accredited schools? It seems to me that regionally accredited schools are trying to protect their "turf" by making themselves appear superior by having the sole use of ".edu" in their domain names.

    • Posted by:   Terence McCann  (terence@ptdprolog.net)
      Date: 8/4/2002 7:30:03 AM

      I believe that a little common sense should prevail here. If an institution of higher learning is good enough to be accredited by an agency that is itself recognized by the US Dept of Education, that it should be assumed that that institution is on par with schools that happen to be regionally accredited. Doesn't the US Dept of Education apply the same criteria to all accrediting agencies when evaluating thier ability to accredit schools? Therefore, why would nationally accredited schools be considered inferior to regionally accredited schools? It seems to me that regionally accredited schools are trying to protect their "turf" by making themselves appear superior by having the sole use of ".edu" in their domain names.

    • Posted by:   James Bovitz II  (jbovitz@frontiernet.net)
      Date: 8/4/2002 8:40:29 AM

      I agree wholeheartedly with the proposed changes. I see no good reason to have limits on the .edu domain name as long as organizations using the domain are engaged in the business of education.

      Please do not de-value the effort of many students who attend non-regionally accredited schools by leaving the current system in place.

    • Posted by:   James K. Bigelow  (jkbigelow@charter.net)
      Date: 8/4/2002 10:49:09 AM

      To the extent that .edu carries with it a connotation of an 'acceptable' institution, I believe that the restriction should be revised as proposed.

      My place of employment reimburses tuition to 'acceptable' institutions. If the current policy had the effect of restricting my selection of an institution for employment education, that would be an injustus to me as I live in a remote area with limit access to traditional 'brick and mortar' schools.

      I see no reason only regional versus regional and national certification boards should be a criteria for determining .edu designations.

    • Posted by:   Benton H. Borum  (HBorum@aol.com)
      Date: 8/4/2002 7:10:07 PM

      Why would any entity/firm that was recognized by the US Department of Education as an institution of higher education not be worthy of possessing an .edu web address? Will the continually expanding internet permit or limit the growth of "distance learning?" Only persons/organizations desiring to create, maintain or increase monopolist advantages would oppose this proposal.

    • Posted by:   Erik Callesen  (callesen@hotmail.com)
      Date: 8/5/2002 12:55:27 AM

      I cannot begin to understand the constant witch-hunt against National accreditation. I recently switched from a regionally accredited institution to a nationally accredited college due to costs and availability. I can say there has not been a difference in the quality of the education that I'm currently receiving.

      The United States Department of Education recognizes National Accreditation. So why would EDUCASE not recognize an educational intuition that the US Department of Education does?

    • Posted by:   Christina Bucko  (cje2@cornell.edu)
      Date: 8/5/2002 6:03:03 AM

      I think "regionally or nationally accredited" institutions should both be allowed to use the edu domain. To restrict ".edu" domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in accrediting standards of regional and national agencies.

    • Posted by:   Paul Diaz  (bewildered32@hotmail.com)
      Date: 8/5/2002 6:06:06 AM

      I think that only accredited institutions should be designated with the .edu naming convention. There must be a "checks & balances" system to help individuals differentiate between accredited and non accredited institutions and the .edu designation will facilitate this. Please DO NOT allow non accredited institutions to use the .edu naming.

    • Posted by:   James Elliott  (tymber*no spam*@comcast.net)
      Date: 8/5/2002 7:04:40 AM

      I DO believe that this restriction should be revised to include all post-secondary institutions that are institutionally accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies." If not, that would mean that college I am currently getting my degree, is basically NOT considered worthy of being called an educator. Thats just not right, Im learning the same if not More, from where I am going now. Please rethink this!

    • Posted by:   Tracy Stewart  (tst2p@allstate.com)
      Date: 8/5/2002 7:24:31 AM

      I have a Bachelors degree from a regionally accredited college and a Master from a nationally accredited college. It terms of the time and effort to obtain bachelor, 4 years full time and the Master's, 3 year's part time. Were it not for the format of the Masters program I would not been able to afford or find time to obtain this degree.

      While I am aware of the need to diffrential between true institutes of higher learning and "diploma mills", I think that limiting the .edu domain to only regionally accredited institution would only serve to undermine the hard work that people such as myself have accomplished by placing nationally accredited institutions in the "diploma mill" category.

      For the sake of many like myself who have invested both time and money to better themselves at nationally accredited institutions, DO NOT limit the .edu domain to only regionally accredited institutions.

    • Posted by:   Chuck Hawks  (policy@hawksnest.com)
      Date: 8/5/2002 8:31:49 AM

      As most Internet users & students are most likely to search for an educational institution using a "edu" domain identifier; and since using the power of the Internet has created the "distance learning" paradigm for educational institutions, I see no reason to restrict the assignment of the domain to regional accredited organizations. If the accrediting body is recognized by the Federal Board of Education, shouldn't that be enough?

      I understand your quandry in that you do not wish to corrupt the .edu domain with non-educational comapnies or scams hiding behind an educational facade; however, you must consider the majority of organizations who are not only valid, but have survived the rigors of state and federal criteria to become accredited. At some point, their goal of delivering quality education will be clouded by simply preparing for and surviving the multiple accrediting bodies to which they will be forced to answer. This currently happens in healthcare. Some hospitals spend more time and resources on passing accrediting bodies (JCAHO, etc.) inspections and regulations than they do on actual patient care.

      Who suffers in this situation? In this case, it will be the students. I request that you broaden the scope for whom you will assign ".edu" to include nationally (Federally recognized) accredited institutions.

      Thanks, Chuck Hawks

    • Posted by:   Brad Neufeld  (BradNeufeld@MyRealBox.com)
      Date: 8/5/2002 8:35:12 AM

      There does not seem to be any benefit in regionalising the .edu domain and the consequences of doing so are likely to be a loss of value. If the only institutions that are allowed in the .edu domain are those that are accredited by a handful of regions in the US then it will exclude all international schools, all national schools and all non-profit educational institutes. This would seem to imply that the majority of quality schools world-wide would not actually qualify for the designation. Such a decision, while satisfying a handful of special interests, will not do anything for increasing the value or respect of the .edu domain. Brad

    • Posted by:   mechweb  (mechweb@yahoo.com)
      Date: 8/5/2002 8:55:42 AM

      I fully support the revision to include nationally accredited schools.

    • Posted by:   Dean Mailhiot
      Date: 8/5/2002 9:40:39 AM

      I completely agree with recognizing ALL accredited post-secondary higher educational institutions. The individual needs to determine the quality of the education received and achived. After all, it's life and corporate society that sorts out the achievers from the non-achievers.

    • Posted by:   Jeff Johnson  (jeffrey.johnson@wix.net)
      Date: 8/5/2002 11:01:15 AM

      Not only do I attend a college that is nationally accredited but I also have worked at one for the last ten years. We go through the same rigorous accreditation visits and are required to perform at even a higher standard in certain circumstsances. To discount these institutions would be a slap in the face to thousands of individuals who have sacrificed many hours to futher their education and improve their quality of life.

      • Posted by:   Jim Roscovius  (roscojim@cableone.net)
        Date: 8/5/2002 1:32:37 PM

        Well said, Jeff. Isn't it amazing that most of the people who are opposed to implementing this suggestion are Ph.D holders who were able to go to those very institutions they are "defending"?

        I too have attended, and currently attend, a nationally accredited distance college. They have met the federal criteria, why shouldn't they be allowed an .edu extension?

        Besides, my education from the distance college has far exceeded the education received from the traditional college I attended. Should Educause take its .edu extension away? That suggestion is just as ludicrous as the current policy.

        • Posted by:   Calisto MF Moniz  (abappl6@chevrontexaco.com)
          Date: 8/6/2002 12:36:49 AM

          I Think that if both Regional and National accredited institutions require tremendous efforts to complete their program, in order to be honored with a certificate, a degree or a diploma, then they must be treated equally. They all pay the same role of educating our people, based on today's world requirements or development.

          Their programs have be evaluated by a legal department responsible for granting accreditation to all institutions meeting educational requirements. Once it meets the standard requirements and become an accredited institution, it can use the edu domain, without any discriminatory act.
          Thanks, Calisto

    • Posted by:   Micah A. Hall  (11ListPostings@micahwave.com)
      Date: 8/5/2002 12:52:50 PM

      Is it just me or does this just not make sense? I have a degree from a traditionally accredited college. I am also currently attending a distance education school, and to be perfectly honest, the distance education curriculum is more difficult! I realize this may not be the case in all circumstances, but if an organization is recognized by a governmental agency like the DETC ( Distance Education Training Council ), that should definitely be good enough.
      Micah A. Hall 11ListPostings@micahwave.com

    • Posted by:   Barry Harrell  (barry_harrell@hotmail.com)
      Date: 8/5/2002 4:08:30 PM

      I do not think it is a good idea to restrict the .edu designation to only regionally accredited school. I have attended and graduated from both regionally accredited and nationally accredited schools. Both schools did an excellent job and were challenging and appropriate.

    • Posted by:   Joseph E. Brown  (BrownJE@usfk.korea.army.mil)
      Date: 8/5/2002 4:21:41 PM

      As a student of the American College of Computer and Information Sciences (ACCIS), nationally accredited by the Accrediting Commission of the Distance Education and Training Council, I support the expansion of the eligibility criteria for DOT EDU domain names to include any institution accredited by any agency approved by the U.S. Department of Education.

      To restrict DOT EDU domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in the accrediting standards of regional and national agencies. The consequences resulting from this implied inferiority would be borne by the students and graduates of nationally accredited colleges as employers fail to recognize the legitimacy of a school because it doesn't have a DOT EDU domain name.

      Joseph E. Brown

    • Posted by:   Brad Hudson  (hudsonb5@charter.net)
      Date: 8/5/2002 4:28:27 PM

      I am of the opinion that ALL institutions accredited by ANY of the accrediting agencies which are recognized by the U.S. Dept. of Edu. should be permitted to receive domain names in the form of .edu. After all, it is the responsibility of the U.S. Dept. of Edu. to track, monitor, allow, & deny accreditation to institutions which desire this privelege. Allowing one form of accrediting agency to obtain the .edu domain names & not another is absurd. There are various levels of documentation & requirements that all of the accrediting agencies must meet in order to award an educational instituion such a privelege.

      Aside, I would also like to see higher educational institutions be forced to accept both Bacclaurette & Master's degrees from ALL institutions accredited through a recognized accrediting agency of the U.S. Dept. of Edu.

      Brad Hudson
      Student of www.accis.edu

    • Posted by:   David Ehrensperger  (chopin9@hotmail.com)
      Date: 8/6/2002 2:50:30 AM

      As a librarian, I have reservations. I have read many postings here, and most of them seem to be from individuals who have an interest in having the .edu domain expanded. Their institutions would benefit from any revision. Viable opinions? Yes. Unbiased? No.

      The comments have mainly focused on the dilemma of accreditation, but this is only the spoken part of the issue at hand. One of the unspoken issues is content on the Web and how institutions appear to the virtual world.

      One rule-of-thumb has been that institutions with .edu names could *generally* be trusted as a source of unbiased information. Too, with a .edu name, value-added content has been associated with the names.

      Currently, many accredited institutions without the .edu name have virtual presences with no content other than information about the institution. To the virtual world, little value is added. It is that concern which, beyond the accreditation question, needs to be addressed.

      For my part, I would support the revision if some stipulation were made for value-added content. That would be a win-win situation for everyone. Institutions would gain the prestige of the .edu name, and students at those institutions would gain a valuable tool in wading through the chaos that is the online world.

    • Posted by:   Carolyn Houston  (carolyn@mti-tex.com)
      Date: 8/6/2002 8:21:34 AM

      The opportunity to use the .edu designation should be available to all accredited (by recognized agencies) ppostsecondary insitutions This is just one more piece of the elitist structure that needs to be removed. What evidence that is there to show that an agency that accredites regionally is some how better than a national accrediting agency? Further, how does the area an accrediting agency covers impact the use of thes .edu designation. This issue should be a no brainer. Surly there are greater issues we can disagree on.

    • Posted by:   Tosha  (tosha@tssva.com)
      Date: 8/6/2002 8:57:20 AM

      As an adult college student, attending American College of Computer and Information Science, I fell that as long as the college is accredited from by an accrediting agency, the use of the .edu should be warranted. TS,
      Virginia Beach, VA

    • Posted by:   M.D. (Butch) Groothuis  (growthis@aol.com)
      Date: 8/6/2002 12:35:45 PM

      Legally, there is no case to be made for restricting .edu to regionally accredited institutions. There is, however, much legal precedence and substantive evidence for a case to be brought concerning restraint of trade if the policy were to remain restricting access to only regionally accredited institutions.

      The present policy serves to confuse users of the Internet. Educational institutions recognized by the U.S. Department of Education via approved institutional accreditors, both regional and national, have undergone the same scrutiny.

      The .edu domain is promoted as designating educational institutions, but at this time is not accurate as it excludes sectors which are recognized as equal by the federal government.

      There are already a number of exceptions to the policy which could not be defended in a court of law.

      Domain names are like yellow page listings that group like things together for the convenience of the reader. Restricting the .edu designation to only a portion of a group is discriminatory with no rational or defensible basis.

      The policy harms students at nationally accredited schools as it denies them access to certain databases.

      Consumers shop around on the web before enrolling, and since .edu has been promoted as applying to educational institutions, those searching the internet frequently only search the .edu listings. This unfairly restricts trade of nationally accredited schools and places them at a competitive disadvantage.

    • Posted by:   Rhonda Jones  (rjones@snowcrest.net)
      Date: 8/6/2002 12:46:12 PM

      I am in support of a policy of inclusion rather than exclusion. I have attended a 4-year university and also, currently, a distance-learning college (American College of Computer & Information Science). My courses are much tougher from the distance learning college than those I have taken at other universities. I feel strongly that it would be unfair to students, passing judgement on the eduction received, and discriminatory toward specific types of colleges if all are not included this policy.

      I am working extremely hard for my degree. Please do not "cheapen" my efforts by promoting the idea that only certain types of accreditation are recognized as valid colleges and deserving of an .edu extension. It is important to me that my degree be fully recognized by our society.

    • Posted by:   Gene Grzywacz  (hope44more@hotmail.com)
      Date: 8/6/2002 6:59:49 PM

      If a school is accredited by a legitimate government-recognized accreditation agency (e.g. DETC) then they should recieve the .edu.
      Gene Grzywacz

    • Posted by:   Brian Haver  (bphaver@aol.com)
      Date: 8/7/2002 10:21:58 AM

      Regional vs National Accreditation I believe it is very important that this policy change be adopted. I believe my studies at ACCIS are as demanding, if not more so, than programs I have attended in the past at regionally accredited institutions.

      • Posted by:   Michael D. Bleacher  (mbleacherjtw@yahoo.com)
        Date: 8/8/2002 2:32:19 PM

        Interesting to read all the input. Haven't seen too much on non-accredited schools. It seems that there is an unfair practice designed to keep new schools from starting up. We are approved to grant degrees by our state, but are not allowed to have a .edu address until we go through monopolistic accreditation processes that may be cost prohibitive. We charge no tuition at our institution, so how could we afford a regional review? It certainly does the public and our student population no good to keep a .edu domain type from us. I would hope that my colleagues on the policy board would welcome my input on this obvious cunundrum. Our population is mostly homeless, and there is no money available to start new programs, though they are desparately needed. What am I to tell the students when they ask how to get out of the cycle of being homeless? Rev. Mike Bleacher
        Clifton Service Learning Institute
        Denver, CO

    • Posted by:   Mark Lotspaih  (mlot@accis.edu)
      Date: 8/9/2002 11:28:27 AM

      To restrict ".edu" domain names to only regionally accredited colleges implies an inferiority to educational programs at nationally accredited colleges, when in fact, no such evidence exists that one type of accredited program is better than the other, nor that there are significant differences in accrediting standards of regional and national agencies.
      Mark Lotspaih

    • Posted by:   Elaine M. Giuliano  (giuel@cccbus.com)
      Date: 8/9/2002 1:27:38 PM

      I agree with the proposed revision. I am very tired of the term "accredited" being used to mean only "regionally accredited." There are numerous accrediting agencies recognized by the Department of Education - if the U.S. Government recognizes them, it seems logical that everyone else should, as well. A better term, if necessary to distinguish between regional and other accreditations, might be degree-granting. But this division could easily be made within the .edu domain.

      Having 2 (or more, since for-profit schools can't be .org's either) domains where schools exist is harmful on several levels:

      1. It gives regionally accredited schools an unfair advantage by implying that .edu is inclusive of all educational enterprises.
      2. It is confusing to school-seekers who often confuse non-degree-granting with "unaccredited."
      3. It stigmatizes institutions which are not regionally accredited.

      I have had heated arguments with other education professionals about whether we were "really" accredited - and yet if you compare the accreditation requirements of ACCET or ABHES to those of WASC, for example, you do not find less rigor, just emphasis on different areas. One very small example deals with outcomes - we are required to make available to all prospective students not only our completion data, but our placement data as well. Vocational schools are held to identical standards for Financial Aid, and in some cases seem to merit more attention. In California, we as a private postsecondary institution, are subject to an entire set of regulations and laws under the Dept. of Consumer Affairs.

      The .edu domain should belong to all educational institutions. We are not all the same, but the differences among accredited schools and the diversity of opportunities they create should be fairly represented in the electronic marketplace.

      • Posted by:   Maggie Layne  (mlayne@ttinst.com)
        Date: 8/14/2002 3:05:23 PM

        Thank you for stating your view point in a succinct and direct manner. If The DOE recognizes national accrediting bodies and institutions that are nationally accredited, why shouldn" everybody else. This is just a political football.

        I am not opposed to everyone being a .com or .org, but by allowing some educational institutions to be .ed and not others implies that some are "better" than others.

        When I logged onto this web-site I entered educause.com not knowing if it was a .com or .org, I was surprised to find that it was a .ed!! Is this a regionally accredited school?

        The .ed would lead one to believe that it is and if there is any reason for educause to have a .ed domain then it seems quite appropo that nationally accredited educational institutions should be granted the same privileges if that is what it is. If not, then everyone can be a .com and that way students will not be confused as to what the

    • Posted by:   Mark LaPierre  (marklapier@aol.com)
      Date: 8/9/2002 10:10:01 PM

      I am in favor of revising the policy on .edu names in accordance with the EDUCASE policy statement of 5/14/2002. If the USDE recognizes an accrediting agency as qualified to accredit then schools accredited by that agency should be allowed the use of the .edu URL extension.

    • Posted by:   Jan Senior  (ian.senior@emiratesacademy.edu)
      Date: 8/10/2002 6:03:19 AM

      To an outsider (outside of the USA that is) it appears that if you do not have the confidence in "Nationally Recognised Accrediting Agencies" to widen the distribution of the .edu domain then that is surely a serious indictment of the system. If the system is sound then widen distribution, if the system is not sound then should you not tackle that problem and put your house in order?

    • Posted by:   Rhoda Dersh  (redpaceset@aol.com)
      Date: 8/11/2002 3:16:57 PM

      Our students enrolled for occupational associate degrees have described the difficulty they had in obtaining information on assocuite degrees from technical and business colleges and schools on the web because many are not identified by various search engines because they do not carry the .edu identification. Certainly enabling prospective students to easily access information about both nationally accredited and regionally accredited institutions would appear to reflect well on proponents of full consumer disclosure. It would facilitate the search of prospective workers for training in fields that need post secondary training but not necessarily four year or academic degrees.

    • Posted by:   Daniel J Gallagher Jr  (danielg@carr.org)
      Date: 8/11/2002 9:41:55 PM

      A policy that allows organizations that are nationally accredited to gain access to ".edu" names makes more sense to me. These organizations have to pass fairly stringent standards set by the Dept of Education.

      I have attended schools that are regionally and nationally accredited and I can say for certain that there are really no differences between the two, except for the cost in time of attending a class held at a location that is 45 minutes from my house.

      Thanks for the opportunity to post this comment.

    • Posted by:   Career College Association  (nancyb@career.org)
      Date: 8/12/2002 9:38:16 AM

      The Career College Association, on behalf of its 1,067 members, supports the proposal to extend use of the ".edu" domain name to all institutions accredited by an agency recognized by the United States Department of Education. The current practice of limiting ".edu" designations to only those degree-granting institutions accredited by regional accrediting agencies unfairly discriminates against nationally accredited institutions without reasonable policy or legal basis. More and more students use the Internet to research institutions of higher education prior to applying to postsecondary schools, institutes, colleges, and universities; not having a ".edu" designation puts institutions at a disadvantage because potential students incorrectly associate this designation as the one for "better" educational institutions.

      National accreditors that are recognized by the U.S. Department of Education have demonstrated that they hold their schools and colleges to the same rigorous requirements as regional accreditors. The Department of Education undertakes a comprehensive review of the accreditors before granting recognition for purposes of allowing schools and colleges to participate in Title IV financial aid programs.

      We wholeheartedly support the proposal to extend ".edu" designations to all regionally and nationally accredited postsecondary institutions.

      • Posted by:   Robert E. Patterson, Ph.D.  (rob@acics.org)
        Date: 8/15/2002 11:28:21 AM

        It is interesting to me that we are having a policy forum to defend an educational process that is woven into the fabric of our U.S. educational culture. The current policy and practice of limiting the .edu domain exclusively to institutions that are regionally accredited seems unreasonable, especially given the context in which such bias is occuring. The context to which I refer is our open, decentralized system of higher and postsecondary eduction.

        The U.S. system is respected because of its diversity. It is not a track system. It is not a centralized system. It is a system that reflects the system of government that makes our country unique. It is not a system grounded in a particular religious tradition. It is an open system that accomodates many subsystems, adding breadth and opportunity. The very fact that many of us in this forum and other fora have to defend the right to use the domain is awkward at best and absurd at worst. Where in the bowels of creating the .edu domain did ".edu" or EDUCAUSE become synonymous with regionally accredited? Was such a decision made in public fora or was it consummated within a secret society? Personally, my spirits are bouyed somewhat, because, a close reading of our national history reveals that we usually render reasonable public decisions when hidden agendas manifest in undisciplined ways.

        Recognition from our U.S. Department of Education and CHEA and their reviews and standards are meaningless if EDUCAUSE, under the auspices of another governmental agency, is enabled to continue to restrict access and information about the opportunities that exist in our open system. More and more students base their decisions for products, services, and now educational options, on information retrieved on the Internet. This is one lane on the information superhighway that should be open to the public.

        Robert E. Patterson, Ph.D.
        Associate Executive Director
        Accrediting Council for Independent Colleges and Schools

    • Posted by:   Abraham I. Pallas  (apallas@mcminnville.tec.tn.us)
      Date: 8/12/2002 2:22:25 PM

      I agree with the proposed revision to include all post-secondary institutions that are institutionally accredited. In many cases, the issue of regional accreditation vs. other accreditation is based solely on the restrictions of the accrediting agency. For example, in Tennessee, there are 26 "Tennessee Technology Centers", public post-secondary institutions which are accredited by the Council on Educational Education. These institutions offer diplomas and certificates, some of which are 2 years in length. The state of Tennessee does not permit these institutions to offer the associate degree, and, as a result, they do not fall under SACS criteria. These are still viable institutions, and deserve to be allowed to use ".edu".

      • Posted by:   Ken Neevel  (ken@westernsem.org)
        Date: 8/13/2002 9:58:23 AM

        I too agree with the proposed revision. The level of accreditation (regional vs. national) should not having a bearing. National accreditation is certainly valid and should be used accordingly.

    • Posted by:   Elise Scanlon  (escanlon@accsct.org)
      Date: 8/12/2002 3:13:14 PM

      August 13, 2002
      Dr. Mark Luker
      1150 18th Street, N.W.
      Suite 1010
      Washington, D.C. 20036
      Re: Proposed Policy Change -- .edu
      Dear Dr. Luker:

      I am responding on behalf of the Accrediting Commission of Career Schools and Colleges of Technology ("ACCSCT" or the "Commission") to the proposed change in policy on the educational institutions that may use the .edu domain name. EDUCAUSE's Policy Board announced earlier this year that it would address this suggested change and asked for comments by August 15, 2002.

      ACCSCT is a non-profit agency that accredits private postsecondary career schools and colleges. It has been recognized by the Secretary of Education and his predecessors since 1967. The Commission itself consists of 13 individuals – seven from the institutions that the Commission accredits and six who represent the public and have experience in business, government and other segments of postsecondary education. It is supported by a staff of 35 located at offices in Arlington, VA. Institutions accredited by the Commission offer baccalaureate and associate degrees and certificates and diplomas for successful completion of programs in, among other subjects, accounting, computer programming, graphic arts, allied health, culinary arts, hotel and restaurant management, motion picture, TV and video production, and merchandising. These 767 institutions are located throughout the United States and Puerto Rico. They educate and train approximately 340,000 students annually. The average completion rates of these students have consistently been about 70 percent, and their average placement rates have been about 86 percent.

      ACCSCT strongly urges EDUCAUSE and its Policy Board to change the criteria so that all postsecondary educational institutions that have been accredited by an agency recognized by the Secretary of Education may use the .edu domain name. The current restriction has never had a legitimate educational rationale, and its perpetuation will only confuse students and the public. Moreover, we must respectfully point out that the restrictive policy is unjustifiably discriminatory, violates public policy and is highly suspect under laws protecting competition.

      We have reviewed the development of domain name policies for the Internet and find no well-considered analysis that would justify restricting the use of .edu to colleges and universities accredited by regional accrediting agencies. A private entity, the Internet Assigned Numbers Authority (IANA), and a Dr. Jon Postel and other academics appear to have made a number of decisions about the domain name system in the Internet's infancy that live on to this day. The .edu name was initially open to all educational institutions, organizations and consortia, but was then restricted in 1994. It was at about this time that the growth of the Internet was overwhelming Dr. Postel and IANA, and the National Science Foundation, the Commerce Department, and several other private corporations succeeded to the management of the domain name system. We can find no intelligible or legitimate rationale for a distinction based upon regional accreditation.

      Congress has not confined the definition of an "institution of higher education" to only those institutions that are regionally accredited. Rather, an institution meets the definition if, as pertinent here, it is accredited by an agency recognized by the Secretary. (20 U.S.C. §1001). Congress and the Department of Education have established the criteria that an accrediting agency must meet in order to be recognized, and again no distinction is made between regional or other accrediting agencies. (20 U.S.C. §1099b; 34 C.F.R. §602). All recognized agencies, whether regional, national or programmatic, must meet the same criteria to be a gatekeeper to the crucially important federal student financial assistance programs. ACCSCT, which in its last accreditation review was found in full compliance with the recognition requirements and granted a full five-year term of recognition, is recognized just as North Central, Middle States, SACS, Western, New England and Northwest are recognized. The institutions accredited by national as well as regional accrediting agencies have been deemed qualitatively worthy to participate in the public funding programs that support higher education.

      We recognize that, in assuming responsibility for the .edu domain, EDUCAUSE has eased the original restriction somewhat by making .edu available to associate-degree institutions that are accredited by a regional agency recognized by CHEA. This step is inadequate and even misguided. Since the management of the domain name system is clearly a matter affecting the public interest, as evidenced by the Commerce Department's ongoing retention of authority over it, it makes no sense to rely upon the recognition accorded by CHEA, a private body, to determine which accredited institutions may make use of the .edu name. This is underscored by the avowedly restrictive policies that CHEA adopted at its outset on the agencies that it would even consider for recognition. While we respect and enjoy cordial professional relations with CHEA, it does not represent all of postsecondary accreditation, and nor has it claimed to. (Resolution of CHEA Board of Directors, December 9, 1998; Statement of Judith Eaton before National Advisory Committee on Institutional Quality and Integrity, June 17, 1997). To rely upon this private and narrowly self-defined body would violate the policy established by the Commerce Department that domain name managers must be responsive to the entire community they serve and not just segments of that community. (White Paper on the Management of Internet Names and Addresses, 63 Fed. Reg. 31,741 (1998)). The higher education community is clearly broader than two- and four-year regionally accredited institutions, CHEA recognized or not. The restrictive policy on the .edu domain name has real consequences. We understand that many educational data bases reserved for scholarly inquiries require .edu for entry. This blocks research by students at ACCSCT-accredited schools. In addition, search engines for education will screen out web sites of institutions that do not have .edu in their name. This excludes ACCSCT-accredited schools from an increasingly important source of access to students. More broadly, we believe it likely that the public understands that educational institutions are identified with the .edu domain name and that non-educational, commercial organizations employ .com or .org. The restrictive policy on .edu thus fosters misconceptions and confusion.

      The lack of a legitimate educational rationale and the harmful consequences of the restrictive .edu policy raise yet another reason why the suggested policy change should be adopted. The restriction, if carried forward and enforced by EDUCAUSE, will be a practice in restraint of trade violative of Section 1 of the Sherman Act. (15 U.S.C. §1). As EDUCAUSE itself acknowledged in the answers it provided to Frequently Asked Questions on its proposal to manage the .edu domain, it is a private organization consisting of the members of the .edu domain. As such it must be careful that any restrictions it imposes on access to what is clearly an important competitive resource not unreasonably benefit its members and harm their competitors. Otherwise, the restrictions would, we are confident, be deemed a group boycott by the courts. (See, e.g, Federal Trade Commission v. Indiana Federation of Dentists, 476 U.S. 447 (1986)). Given the lack of a plausible educational rationale, the restrictions would fail to meet the rule of reason test and might well be treated as a per se violation of Section 1.

      We raise this latter point not because the Commission or its accredited schools seek confrontation with EDUCAUSE, but to underscore the seriousness of the issue before the Policy Board. We hope to engage EDUCAUSE in a collegial and professional manner on this and other issues that affect the increasingly important subject of information technology in education. We urge the Policy Board to rectify the flaws we have identified as soon as possible.

      Elise Scanlon Executive Director

    • Posted by:    ()

      Chase College STRONGLY supports the use of .edu by all accredited postsecondary institutions.

      We support this change for the following reasons:

      1. The restrictive criteria runs contrary to the policy of the Commerce Department which has clearly articulated responsiveness to a broad community.
      2. There is no basis for distinction between regional and national accrediting organizations ... eg Harvard University and Chase College are both exceptional accredited schools, however possess different missions.
      3. Students are confused as to why we use a .com rather than an .edu domain.

      We urge your reconsideration.

    • Posted by:   Janet Bonsall  (jbonsall@bradfordschools.com)
      Date: 8/13/2002 9:42:39 AM

      I strongly advocate that the .edu domain be available to all postsecondary institutions that are institutionally accredited by an accrediting agency appearing on the Department of Education's list of nationally recognized accrediting agencies. Limiting this domain to only those institutions accredited by regional accrediting bodies is arbitrary and discriminatory. It is the responsibility of the Department to evaluate the credibility of an accrediting body and, subsequently, recognize the quality of the institutions it accredits. The Department has not delegated this responsibility solely to the regional accrediting bodies, neither should EDUCAUSE. The majority of aspiring students use the Internet to locate information concerning their options for furthering their education, relying on the .edu domain to help them locate possibilities. Since the Department of Commerce has awarded EDUCAUSE the right to manage the .edu domain, EDUCAUSE should recognize its responsibility to act without bias as it facilitates student exploration of the various options available to them.

    • Posted by:   John Tidner  (johnnybrad@aol.com)
      Date: 8/13/2002 10:10:32 AM

      Yes, I agree with the change. I recognize the concern of some who feel theological schools are really not "educational" institutions, but I believe that is not a major issue. No one should assume the .edu on a website implies only that everything on the website is true, or even meaningful. At best, it is a broad guide to what the owner thinks of itself; nothing more.

    • Posted by:   Jon Knudsen  (knudsenj@saic.com)
      Date: 8/13/2002 11:55:17 AM

      This proposal only makes sense. To do otherwise, would sya that the Department of Education's accrediting process is a joke. I'm sure that's not the case. I am a hiring manager for a major IT firm in the Northern Virginia area, and would trust a "Nationally Accredited" institution over a "Regionally Accredited" instuttion. I would like to think that the standards at the Department of Education are a lot higher than the standards at whichever board makes up a different accrediting agency. Anyone in this country can start an accrediting agency, but if it's not on the DoE list, its pretty much worthless. I think if the DoE took the time to verify the credentials of the nationally accredited institutions, then there is no choice , but to give them a .edu domain. To do otherwise would be a farce.

    • Posted by:   Colleen Cunningham  (colleen.cunningham@comairacademy.com)
      Date: 8/13/2002 12:54:36 PM

      Since regional and national accrediting agencies are governed by the same recognition criteria, there is no basis to distinguish between the two. Institutions become eligible to participate in student financial assistance programs if they are accredited by a recognized agency. The restrictive criteria are contrary to the policy of the Commerce Department, which retains ultimate responsibility for .edu domain name management.

    • Posted by:   Duane Kramer  (dkramer@uticorp.com)
      Date: 8/13/2002 2:25:43 PM

      We believe that schools that are approved by the standards of the U.S. Department of Education meet the intent for use of the "edu" name. It is within the spirit and intent of our rules to manage this isue.

    • Posted by:   Bob Johnson  (BobKatClan@Juno.Com)
      Date: 8/13/2002 4:39:24 PM

      I fully support this proposal. If the institution is recognised by the Department of Education and the Department of Commerce then further restrictions are discriminatory and counter-productive. The .edu domain should be available to ALL schools that meet the criteria of any accrediting agency recognised by these authorities.

    • Posted by:   Irv Becker  (irv.becker@mail.dss.mil)
      Date: 8/14/2002 8:10:26 AM

      We support this proposal. If an educational institution is recognized by the Department of Education and the Department of Commerce then further restrictions are discriminatory and invalid. The .edu domain should be available to every school that meets the criteria of any recognized accrediting agency. The Defense Security Service Academy fully supports ACCSCT's position and believes it's in the best interest of our Academy to be able to use the .edu Domain name. Further, having the .edu restriction creates a situation that requires us to use a Domain identifier that does not adequately identify us as an educational institution.

    • Posted by:   Thomas D. Treacy, Ed.D  (Pres@antonelli.org)
      Date: 8/14/2002 8:23:29 AM

      August 14, 2002
      To: Educause
      I would like to comment on the proposed EDUCAUSE policy change regarding the .edu web site designation.

      My institution is a two-year Associate Degree granting institution founded in 1938 and licensed by the Department of Education, Commonwealth of Pennsylvania and nationally accredited. Our course offerings are in the visual arts.

      For over four years I have attempted to obtain the edu. designation only to be rebuffed with a variety of reasons among which was our accreditation. National accreditation apparently in the eyes of those who established policy guidelines was deemed to be a lesser form of accreditation. The continued implementation of this restrictive policy is discriminatory, a restraint of trade and harmful to the educational consumer.

      Over the years the .edu designation has become an imprimatur in higher education. It gives the impression to educational consumers that only schools with the .edu designation are legitimate schools when, in fact, it many schools are restricted from its use.

      Our institution has received numerous inquiries from prospective students and their parents questioning why we use the .org designation. Although we can attempt to explain the restrictive policies of the of the IANA, the Department of Commerce and others there often remains a nagging doubt that our school provides a lesser form of education. And all too often this doubt is factored into the school selection process.

      Institutions of higher education, not for profit, for profit, public, private, state supported or otherwise are all in the business of education. We may not like to admit it but it is true. We compete amongst each other for students and academic offerings. The process makes all a little bit better. All we are seeking is a level playing field. Allowing the use of the .edu designation by institutions nationally accredited by an agency recognized by the U.S. Department of Education would be in all our best interests.

      Thomas D. Treacy, Ed.D.
      Antonelli Institute
      Erdenheim, PA

    • Posted by:   Robert Valdez Sr.  (info@manhattanhairstylingacademy.com)
      Date: 8/14/2002 11:42:05 AM

      As President of a Nationally Accredited Post Secondary Institution, we strongly agree with NACCAS that any institution accredited and approved by the US Department of Education should be able to utilize the .edu suffix for domain names.

      It is a shame that although we meet and exceed many of the same completion and placement criteria as well as adhere to the same regulations that 2 year or greater degree granting institution do, our needs are continually overlooked. We would appreciate your consideration in this matter.

      Robert Valdez
      President of Manhattan Hairstyling Academy
      President of Florida Cosmetology Schools Association

    • Posted by:   Sal V Milazzo  (asm60@bellsouth.net)
      Date: 8/14/2002 11:59:53 AM

      Subject: exclusion of non-granting degree institutions from .edu domain names
      Members of the educase board:

      Our institution stand on the matter of excluding non-degree institution from participating in the .edu domain names is totally immoral and unethical. At this time where everyone is working against discrimination, you decide to implement a policy that discriminate against all institutions based on size and income. Your policy is meant to satisfy the desires of big income, big school run and operated by big money. Smaller institutions, if they are accredited, should not be discriminate against them, because they are doing a great service to the communities and the economy. In addition, smaller institutions are helping people become a productive part of society where if they have to go to a larger school they may not have the same opportunities due to financial situation or simply the capacity to learn at a college level. Not allowing these institutions utilize the .edu domain names you are not only infringing on the students freedom to choose but also, on the freedom of enterprising as guaranteed by the Constitution on the U.S.A.

      Thank you for allowing us express our thoughts and for your time.
      Sal V Milazzo
      School Director
      ASM Beauty World Academy

    • Posted by:   Thomas Emory  (ubia@fast.net)
      Date: 8/14/2002 12:24:30 PM

      I am the Director/coordinator of the Upper Bucks Institute of Aeronautics in Quakertown, PA. As a post secondary institution with articulation agreements with the local community college we believe that the use of the .edu domain would add credibility and legitimacy to our organization. As a part of the family of institutions accredited by the Council on Occupational Educational, we are eligible to participate in federal student financial assistance programs and see no reason why we should be discriminated against by having to use the .org domain.

      Please consider this request for a change in the rules regarding the .edu domains.

      Thank you
      Tom Emory
    • Posted by:   Randy Runkles  (Manager@nic.mil)
      Date: 8/14/2002 1:45:37 PM

      I run the G-Root server that are answer request to .EDU and sit on the DNS root server advisory committee board. I am deeply concerned over your policy of only granting .EDU to your regionally accredited organizations rather than nationally recognized organizations. I strongly request that the verbiage be in the context and understanding "any school accredited by an agency recognized by the U.S. Department of Education is eligible for an .edu URL." Your current idealism would lead some to think that some higher education institutions give less valued education than those on your six regionally accredited lists. I believe as many others do that nationally recognized accreditation holds a much stronger value than regional.

    • Posted by:   Jim Durbin  (jdurb@foundationcollege.com)
      Date: 8/15/2002 8:39:39 AM

      The unavailability of the .edu suffix has been harmful to our organization in San Diego CA in two ways. First, it has had a negative impact on our ability to interest local companies in our extended studies programs. We have a number of business training courses (some of which are offered through contracts with the state of California) designed to assist businesses in maintaining and increasing their competitive positions. Representatives from these companies frequently wonder why we do not have .edu in our web site and email addresses. They do not see us as being as legitimate an institution if we are not allowed to use the .edu suffix. This has had a negative effect on our ability to provide our courses to the business world.

      The second negative impact is to our graduates. Our graduates receive an excellent technical education. The credentials of these graduates is sometimes considered suspect by potential employers, and other institutions of higher learning based upon our website and email addresses. The inability to use the .edu suffix works against the best interests of our graduates.

      Jim Durbin
      Foundation College San Diego
      5353 Mission Center Road Suite 100
      San Diego, CA 92108
      Tel: (619) 683-3273
      Fax: (619) 683-3224

      • Posted by:   Kathleen Prince, Ph.D.  (kprince@acics.org)
        Date: 8/15/2002 10:26:38 AM

        The U.S. Department of Education and the Council for Higher Education Accreditation (CHEA) are in the business of assuring the quality of regional and national accrediting agencies. Many potential students access the internet to learn of educational opportunities before making an enrollment decision. The current practice of EDUCAUSE to limit .edu designations to regionally accredited institutions limits consumer choices to higher education.

        EDUCAUSE should revise its current practices to include all post secondary institutions that are institutionally accredited by agencies recognized by either the USDE or CHEA.

    • Posted by:   Leman Uyuklu  (leman@calcc.org)
      Date: 8/15/2002 11:34:05 AM

      I am the Vice President and Dean of International Studies at California College of Communications, a Private Postsecondary Vocational School, nationally accredited and specializes in high-tech certificates like Web Master, Networking, Programming, etc. Our courses are just as challenging as any college course and our faculty is qualified to teach at any college or university in the area, the quality of education is comparable to highly recognized four year universities in the Bay Area. We have articulation agreements with local area colleges to transfer courses to their programs. In short, we do educate as well as any other institution that has a .edu domain. Why should we be denied to have a .edu domain name? We are not asking to change the level of certificate we issue or give bachelor or masters degrees, or to represent something we are not accredited for; this is to have a voice on the Internet under a domain name that fits our line of work best, which is EDUCATION.
      Leman Uyuklu

    • Posted by:   Claudette Hymel  (ClaudetteH@BlueCliffCollege.com)
      Date: 8/15/2002 1:56:55 PM

      We at Blue Cliff College would like to support the extension of the use of the .edu domain name to all postsecondary institutions accredited by an agency recognized by the U.S. Department of Education.

      We think the exclusion of those postsecondary institutions not accredited by regional accrediting agencies from the use of the .edu domain name is discriminatory and has no basis except exclusivity. Postsecondary institutions accredited by national accrediting agencies must undergo examinations and reviews as rigorous as those administered by regional agencies. Further, this discrimination seems to be contrary to law and policy set forth by agencies of the federal government.

      It is time to level the playing field for all accredited postsecondary institutions that have achieved accreditation after review by an agency recognized by the U.S. Department of Education. These educational institutions should be afforded the same respect as other recognized institutions. Use of the .edu domain name would contribute to these ends.

      • Posted by:   Eileen M. Brennan  (ebrennan@acics.org)
        Date: 8/15/2002 2:17:26 PM

        I support the Board's proposal. By permitting all educational institutions accredited by any of the agencies recognized by the U.S. Department of Education(ED)to use edu, the U.S. Department of Commerce rightly affirms the role of ED as a reliable authority in the area of postsecondary education and rightly fulfills its own responsibility to ensure fair trade. Most importantly, allowing edu to be used by institutions accredited by all agencies recognized by ED, the Board will provide the public with more complete and accurate information concerning learning opportunities at educational institutions.

    • Posted by:   Dr. Judy Dresser  (judy@pianotuningschool.org)
      Date: 8/15/2002 2:23:08 PM

      This letter is in support of the proposed change to allow the use of the .edu domain name by all postsecondary institutions accredited by the U.S. Department of Education.

      Emil Fries School of Piano Tuning and Technology is a small non-profit postsecondary technical school founded in 1949 to teach piano tuning and repair to people who are visually impaired and blind. We also serve some sighted students. Our teachers are blind. The School is accredited by the Accrediting Commission of Career Schools and Colleges of Technology (ACCSCT) and approved for Federal Student Financial Aid.

      The Internet is the primary information source for individuals who are blind. Use of the Internet has opened the world to them. Currently potential students contact our school through an .org domain. This may cause them to question the legitimacy of the school's training, whereas an .edu domain would give this school equity with other postsecondary schools and colleges as students consider their educational options.

      Although I have worked at this school for just over one year, my professional background includes 25 years as an upper-level community college administrator. I can attest that this private school technical program accredited by ACCSCT is on a par with technical programs accredited by both North Central Association (NCA) and the Northwest Association of Schools and Colleges (NASC).

      I urge you to change the restrictive criteria to allow use of the .edu domain name by all postsecondary institutions accredited by an agency recognized by the U.S. Department of Education.

      Sincerely yours,
      Judy K. Dresser, Ed.D.
      Emil Fries School of Piano Tuning and Technology
      2510 East Evergreen Boulevard
      Vancouver, WA 98661
      (360) 693-1511

    • Posted by:   James S Dean  (jsdtech@earthlink.net)
      Date: 8/15/2002 2:47:07 PM

      I am writing on behalf of several of our students who have expressed the difficulties which they experienced in easily accessing our school's website. It appears that a clear and just resolution to these problems could be brought about by the opening of use of the .edu web suffix to all legitimate educational institutions which are accredited by national as well as regional accrediting agencies. After all, both types of agencies are governed by the same recognition criteria and are recognized by the Secretary only if they meet those criteria. Moreover, as early as 1998, the Commerce Department charged all internet domain name managers with the obligation to be responsive to the entire community they serve and not just segments of that community. Discriminatory or restrictive policies are not only confusing to consumers, but without legitimate educational rationale constitute a prime facie violation of antitrust law and prohibitions on restraint of trade. As a private association of the institutions favored by such discriminatory policies, EDUCAUSE should guard against claims that its perpetuation and enforcement of those policies violate laws protecting competition. Administrative policy change now, before involvement of the judicial or legislative branches of government, is clearly the proper and just remedy to this matter. Thank you for your attention to these comments.

    • Posted by:   Bill Holbrook  (bill_holbrook@msn.com)
      Date: 8/15/2002 2:48:32 PM

      I fully support the proposed policy revision to extend the eligibility for the .edu domain name to nationally accredited educational institutions. I have a bachelor’s degree and three masters degrees from regionally accredited institutions and now, due to work and home life schedules, need to use distance education opportunities to purse additional education. My experience with this form of learning has been excellent. Currently I am updating my Computer Science training from the ACCIS, which is fully accredited by an agency listed by the U.S. Department of education. I find the education being offered by the ACCIS to be as rigorous and demanding as my other on campus educational experiences. Clearly, nationally accredited educational institutions have earned our respect and deserve the right to use the .edu name.

      Bill Holbrook, P.E.
      Principal Systems Engineer
      System/Software Engineering
      Rockwell Collins

    • Posted by:   Guy Euliano  (geuliano@tsbi.org)
      Date: 8/15/2002 2:54:08 PM

      I believe the edu. domain should be available to all postsecondary schools that are accredited by an accrediting agency (regional or national) which is recognized by the U.S. Dept. of Education. Anything other than this definition would be discriminatory and harmful to the non-regionally accredited institutions.

    • Posted by:   Stephen Garland  (s801land@qwest.net)
      Date: 8/15/2002 3:12:17 PM

      I support the use of .edu by all institutions that hold either Regional or National Accreditation. The US congress has validated the education of students in Regionally Accredited Institutions on an equal basis with Nationally Accredited Institutions. The real difference is that Nationally Accredited Schools do a much more efficient and cost effective job of utilizing Title IV funds with a much higher degree of documented success and accountability. The permission to use .edu by only regionally accredited institutions denotes an elitism perspective that contradicts the intent of congress to create a level playing field in education.

    • Posted by:   Dr. Jim Hutton  (jdh@vc.edu)
      Date: 8/15/2002 3:28:25 PM

      I cannot understand how this is even an issue for discussion. Your contract is with the Commerce Department to administer part of the public domain, in my opinion. If the contract does restrict availability of .edu, which I doubt it does, what would make the Department of Commerce more qualified than the United States Department of Education or the various State Licensing agencies to evaluate institutions for use of the .edu. The Internet is part of the public domain more similar to the Yellow Pages than to some arbitrary "list of approved suppliers." If a college was licensed by their state and accredited by an agency recognized by the Secretary of Education, I doubt very seriously whether the Yellow Pages would deny their ad under colleges. My question is more than just the fairness and reasonableness of the issue. My question is what gives Educause legal authority to regulate the internet and thus restrict fair trade? I would like to see the contract with the Department of Commerce. Perhaps the complaints should be against them and not Educause.

    • Posted by:   David Luce  (dluce@itt-tech.edu)
      Date: 8/15/2002 3:30:55 PM

      I urge you to reconsider your initial position to only allow "regionally accredited" institutions to receive the .edu designation. Limiting the .edu domain to only regionally accredited institutions is discriminatory, arbitrary and possibly a restraint of trade. The Department of Education has delegated the responsibility of determining the quality of educational institutions to regional, national and specialty accrediting agences, not the Department of Commerce or EDUCAUSE. Many individuals now utilize the Internet to locate educational instititons and the .edu domain is held by only a small part of the accredited institution universe. Credible institutions denied access to the domain are likely to be viewed as substandard educational institution as a result of this discrinination. EDUCAUSE would, therefore, serve the public interest best by allowing all institutions accredited by agencies recognized by the Department of Education access to this domain.

    • Posted by:   Michael T.  (mike-t@attbi.com)
      Date: 8/15/2002 3:41:35 PM

      I agree that nationally accredited as well as regionally accredited schools meeting the guidelines of the U.S. Department of Education should be afforded the same under the guidelines of who can receive a .edu name. There are many fine schools out there that are accredited by an accrediting agency appearing on the U.S. Department of Education's list of "Nationally Recognized Accrediting Agencies", why would they not have access to .edu names.

    • Posted by:   Stan A. Mortensen  (smortens@cci.edu)
      Date: 8/15/2002 4:37:53 PM

      August 15, 2002 Dr. Mark Luker
      1150 18th Street, N.W.
      Suite 1010
      Washington, D.C. 20036

      RE: .edu Domain Policy Suggestion

      I am writing on behalf of Corinthian Colleges, Inc. (¡§Corinthian¡¨) to express support for the proposed policy suggestion regarding which educational institutions are allowed to utilize the ¡§.edu¡¨ domain name.

      Corinthian currently operates 63 colleges in 21 states, and, as of June 30, 2002, had a total student population of over 34,000. Corinthian offers a variety of master¡¦s, bachelor¡¦s, associate¡¦s degrees and diploma programs with curricula focussed primarily in the healthcare, business, crimimal justice, electronics and technology fields (including automotive and diesel technology).

      Corinthian¡¦s higher education institutions are accredited by both "national" and "regional" accrediting agencies, including: the Accrediting Council for Independent Colleges and Schools (¡§ACICS¡¨); the Accrediting Commission of Career Schools and Colleges of Technology (¡§ACCSCT¡¨); the Accrediting Bureau of Health Education Schools (¡§ABHES¡¨); the Accrediting Council for Continuing Education and Training (¡§ACCET¡¨); and the Higher Learning Commission of the North Central Association of Colleges and Schools (¡§NCA¡¨).

      We support the proposed policy change being considered by EDUCAUSE that would allow all post-secondary institutions that are institutionally accredited by an accrediting agency recognized by the U.S. Department of Education to utilize the .edu domain name. We endorse this change for the following reasons:

      Allowing access by all institutions accredited by an agency recognized by the Department of Education is consistent with both the Higher Education Act and Department of Education (the "Department") regulation. A college meets the definition of an ¡§institution of higher education¡¨ if it is accredited by an agency recognized by the Secretary of the Department. As both Congress and the Department have established criteria that accrediting agencies must adhere to for recognition, there has been no distinction made between regional and national agencies -- all recognized agencies must meet Department criteria. Furthermore, the institutions accredited by both "national" and "regional" accrediting agencies have met the standards set forth by their respective accreditor in order to participate in Title IV funds.

      This policy change could eliminate confusion by Internet users and potential customers. Many users may assume that the .edu domain is only used by ¡§legitimate¡¨ educational institutions when that is currently not the case. A wide variety of accredited institutions do not have access to this domain. In addition, some search engines utilized by prospective students when seeking out educational opportunities may screen out web sites that do not include the .edu extension. Educational institutions at all levels are receiving an increasing number of inquires via the Internet and, in the highly competitive higher education market, this confusion by the public could be damaging to some institutions.

      The lack of access to the .edu domain by nationally accredited institutions hurts prospective students by making it more difficult for them to find and research "nationally accredited" schools, making it appear that these providers are somehow not accredited or not quality organizations. This may cause both parents and students to feel undue concern about the quality of their potential choices. As many community college systems and public and private schools are operating at capacity (the state of California, for example, turns away close to 500,000 students a year from the state system) it is crucial that students have the ability to research and become informed on the wide array of educational opportunities available to them.

      In summary, we urge the EDUCAUSE Policy Board to adopt the proposed policy suggestion as posted on its web site. We appreciate the opportunity to comment on this important issue.

      Stan Mortensen
      Vice President and General Counsel
      Corinthian Colleges, Inc.

    • Posted by:   Glenn Sullivan  (gds@sullivan.edu)
      Date: 8/16/2002 8:02:10 AM

      Dear Educause,

      I am writing to express my opinion, and to strongly advocate that the .edu domain be made available to all postsecondary institutions that are accredited by accrediting agencies recognized by the Dept. of Education. Limiting use of the .edu designation solely to regionally-accredited institutions is arbitrary, and unfairly discriminates against institutions with national accreditation. Educause is not a regulatory agency in possession of the authority to evaluate either regional or national accrediting bodies. This responsibility lies with the Dept. of Education and the accrediting bodies it recognizes, that do have the responsibility and authority to evaluate and properly recognize postsecondary institutions of learning. The school group I represent, the Sullivan Colleges System, has schools accredited by both the Accrediting Comission of Independent Colleges and Schools (ACICS) and the Southern Association of Colleges and Schools (SACS). Educause itself, by its own definition, should not be using the .edu domain. Please end this unfair policy of discrimination against these nationally-accredited schools.

      Glenn Sullivan,
      executive vice president
      Sullivan Colleges System
      Louisville, KY
    • Posted by:   Ray Testa  (eachair@aol.com)
      Date: 8/16/2002 10:36:54 AM

      To Whom It May Concern:

      I am writing on behalf of four individual cosmetology schools in New Jersey which are under the management of my company as well as more than twenty accredited schools in New Jersey which are members of our State Association. I currently serve as President of that association and have am a Past President of the American Association of Cosmetology Schools which has over 475 members of which more than 85% are accredited by NACCAS.

      On behalf of all of our schools I am recommending that schools accredited by national accrediting agencies which are recognized by the US Department of Education be eligible for the .edu domain name. Exclusion of these fine institutions is both discriminatory and arbitrary and excludes access to important choices that should be available to all perspective students. IN the interest of fairness and increased opportunity for all students I urge EDUCAUSE to amend its policy to include our institutions as eligible.

      Thank you for the opportunity to submit these comments.
      Ray Testa
      Natural Motion Member Schools, V.P.
      Association of Cosmetology Schools NJ, Inc., President
      American Association of Cosmetology

    • Posted by:   Gary Trottier  (Trot@turbont.net)
      Date: 8/16/2002 7:07:26 PM

      I support the position of the Council of Recognized National Accredited Agencies (CRNAA), an organization that consists of the executive directors from each of the national accrediting agencies. I recommend that the criteria for eligibility for an edu. domain name be expanded to include the reliance on recognition by any agency nationally recognized by the Department of Education.

      I understand that the use of the .edu domain name will allow access to professional development programs, information resources, professional communities and networks, and policy initiatives. All educational institutions will benefit from access to these resources. The exclusion of any accredited institution or class of institutions is a detriment to that institution as well as to the education community as a whole.

      Please include all accredited institutions.
      Best Regards
      Gary Trottier, President
      New England School of Hair Design Inc
      12 Interchange drive West Lebanon NH
      Tri State Cosmetology School Owners Association (Vermont, New Hampshire and Maine

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