Let me make this clear - I feel pretty strongly about this next statement. When we are talking about earth-shattering matters such as where distance learning fits into an organizational structure, we must stop thinking in terms of technology. Distance learning is not about technology; it only uses technology. The typical DL director is no more of a technology guru than is the campus football coach or the registrar. Distance learning relies heavily on technologies, such as Blackboard and the internet, but does not necessarily require technology to function (correspondence courses for example). Yes, providing support to faculty and student who use distance learning technologies is typically a priority function among DL departments. However, so are advising, tutoring and evaluation of courses and programs - all academic functions. A big problem I've seen when DL is part of the campus technology umbrella, aside from programs and courses driven primarily by technology, is that DL administrators become more disconnected from the academic perspective, including the long-held higher education traditions and mores that quietly yet perpetually flow beneath the ivory towers. An effective DL administrator must not only know about these waters, but be willing to swim in them as well. A technology-based program tends to take us too far from this stream.
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