[Libs-Or] INFORMATION: E-rate: 900 questions and several late nights later

Diedre Conkling diedre08 at gmail.com
Thu Aug 15 12:46:31 PDT 2013


E-rate: 900 questions and several late nights later
Posted on August 13, 2013 by Marijke Visser

Yes, it's true. With this post, we now have a verifiable E-rate streak
established in our District Dispatches
if you'd like to play along).

The Federal Communications Commission's (FCC) Notice of Proposed Rulemaking
is the most significant one for E-rate since the program's inception. It
involves every aspect of the program, asking over 900 questions--ranging
from radical restructuring of the program to the most modest of tweaks.
This wide-ranging examination and possible re-engineering of the E-rate
program represents a great opportunity and some risk for the library and
school communities. Hence, this will not be the last blog post you see
related to E-rate!

Since the release of the
July 23, ALA staff and members have spent several hundred hours
discussing, analyzing and prioritizing the work ahead.  Many more hundreds
of hours stretch in front of us for drafting, additional analysis and
engaging with FCC staff and other stakeholders. At this point in the
process, we want to share an early look at some of the priority issues on
which we expect to submit comments. This is certainly not comprehensive
with respect to all of these issues and, of course, priorities may evolve
as our analysis proceeds, and we receive input from the library community.

It is important to start with a review of the motivating political context
for this NPRM. President Obama announced the
in June. Central to ConnectED is the proposition that students
must have access to high-capacity broadband as the underlying force on
which critical digital learning takes place. ConnectED calls for 99 percent
of K12 students to have access to high-speed broadband within five years
and the E-rate program as the primary mechanism to achieve this goal. One
political manifestation of the use and dependence on E-rate occurred in
last month's hearing<http://www.districtdispatch.org/2013/07/senate-e-rate-hearing-to-feature-maine-state-librarian/>at
the Senate Commerce Committee, at which Maine State Librarian Linda

While the NPRM is responsive to the ConnectED initiative, the FCC is using
this opportunity to review and possibly modify virtually every aspect of
the E-rate program. The FCC states three overarching goals for the program
and structures its questions and proposals within these purposes (a bit
more detail may be found in the FCC fact

   1. Ensuring schools and libraries have affordable access to 21st century
   broadband that supports digital learning; (this is the goal directly
   related to ConnectED)
   2. Maximizing the cost-effectiveness of the E-rate program;
   3. Streamlining the administration of the E-rate program.

Priority Issues

Funding issues appear in the NPRM in a number of guises. Several questions
relate to how E-rate discounts are allocated to libraries and schools. For
example, should the funding priority levels be eliminated or expanded? How
should the discount matrix be revised--should the definitions of rurality or
poverty be adjusted and how, and what are the proper levels for the
applicant match?

Larger funding allocation issues also are on the table. Current discounts
are based on levels of poverty and the actual cost of E-rate eligible
services. The FCC asks whether funding should be based on a general
parameter such as the population of the service area, number of library
card holders, or other metric. Also, should support for certain "outdated"
technologies be phased out so that high-capacity broadband may be better

New funding also is discussed, though in a somewhat muted fashion. With
demand already double the available E-rate funding, ALA will submit
comments on raising the funding cap for the program. Funding for special
initiatives, to accelerate progress towards the President's ConnectED
goals, is proposed, and we are considering library-centric possibilities to
launch if indeed such funding is identified.

Broadband technology and metrics are a priority. Schools have a specific
goal suggested by the FCC in paragraphs 22-24 in the NPRM (at least 100
Mbps per 1,000 students and staff by the end of the 2014-15 school year and
at least 1 Gbps per 1,000 by the end of the 2017-18 school year). Should
libraries have an analogous goal and, if so, what should it be? The FCC is
promoting high-capacity broadband solutions generally, and we will be
commenting on how they should be carried out, especially the role of fiber
technology and how broadband construction projects should be funded.

There are many proposals for simplification and improving the efficiency
and effectiveness of the program. Of these possibilities, we expect to
comment on direct payments to recipients; reducing the application burdens
for multi-year projects; consortia and bulk-buying arrangements; and
favoring the use of existing state and local procurement procedures. In a
number of places, the FCC proposes additional applicant/recipient data
collection and procedures. We are cautious about increasing the burden on
libraries in the name of increasing program efficiency and effectiveness
and will review this area carefully.

The interpretation of CIPA with respect to E-rate also is discussed and
demands careful attention at a time when BYOD is becoming more and more
common in our libraries.

All questions and proposals have the possibility of creating unintended
consequences for which the E-rate program is dubiously famous. As Linda
Lord put it, "E-rate is a chess game." Weighing options, interpreting
intent, negotiating politics of one path over another and formulating a
library position is all part of the final product ALA will submit on
September 16 when comments are due. (And we will almost certainly submit
reply comments, due October 16).

We also are developing a plan for engaging stakeholders. Developing the
substance of our positions is obviously critical, but positions are not
valuable unless they are communicated and adopted by key decision makers
and influencers. Certainly, advocacy for various policy positions will be
intense. Discussions and informal input will continue, perhaps for many
months, after the October 16 date.

We look forward to working with the library community to receive broader
perspectives and suggestions. Please let us know if you have specific
questions or concerns as we go along.


*Diedre Conkling**
Lincoln County Library District
P.O. Box 2027
Newport, OR 97365
Phone & Fax: 541-265-3066
Work email**: **diedre at lincolncolibrarydist.org*<diedre at lincolncolibrarydist.org>
Home email: **diedre08 at gmail.com* <diedre08 at gmail.com>

 "If you don't like something, change it. If you can't change it, change
your attitude."--Maya Angelou
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