I was just asked if I could summarize the last year’s worth of E-rate work we have done in the American Library Association (ALA) Washington Office. Here’s the challenge: Can I do it in two pages or less? Apparently the answer is yes and this blog post may also be an all-time record for brevity (for which I am not known). So even though the summary and timeline (pdf) is right at two pages (and spiced up with bulleted lists and descriptive headers), you can get the gist of it right now:
Timeline of the E-rate Modernization Proceeding
- July 2013: The Commission introduces the Notice of Proposed Rulemaking (NPRM).
- September 2013: Initial comments are due at the Commission.
- November 2013: Reply comments are due.
- March 2014: The Commission issues a Public Notice (PN) seeking additional comment.
- April 2014: PN Initial comments are due April 7, reply comments due April 21.
- July 2014: The Commission adopts the E-rate Modernization Report and Order and issues a Further Notice of Proposed Rulemaking (FNPRM).
- September 2014: FNPRM initial comments are due September 15, reply comments due September 30.
- The Commission is expected to vote on a second Order in November or December 2014.
ALA (Recent) Engagement
In addition to ALA’s comments, we submitted another joint letter to the Commission urging it to address the broadband capacity gap for libraries. The Association for Rural & Small Libraries (ARSL), Organizations Concerned about Rural Education (OCRE), the State Educational Technology Directors Association (SETDA), and The Rural School and Community Trust joined ALA and the Public Library Association (PLA) on the letter.
What to Expect and When
Throughout the modernization proceeding, the Commission has made clear that its review of the E-rate program is a multi-phase process. In a speech made on September 29, the Chairman indicated that the next phase of the proceeding must address the “rural fiber gap.” Since that time, the focus at the Commission has been to identify policy changes that would address the barriers that prevent libraries and schools from securing affordable high-capacity broadband. The Commission is also looking at the need to increase the overall size of the fund. The Chairman is advocating that closing the fiber gap is a significant driving factor in determining the need for more funding. He is also looking at related issues such as the lack of competition among service providers—particularly in rural areas—and the lack of affordable broadband when it is available. ALA advocated for action on these three issues (availability, affordability, and increased funding) and is pleased that these issues are squarely before the Commission now.
All indications are that the Commission plans to vote on a second Order during their November open meeting, November 21. What does this mean? The Chairman must circulate a draft Order to the Commissioners October 31. One week before the public meeting, the Commission enters into the Sunshine Period where outside parties other than members of Congress or other federal agencies may not make presentations or otherwise advocate at the Commission. Commission staff, however, may reach out to outside parties to ask questions. During the open meeting the Commission staff present the draft Order, and Commissioners may ask questions and make statements prior to voting to adopt the Order (or not). The Order is made publicly available after the vote if it is adopted. Any rule changes go into effect 30 days after it is published in the Federal Register.
• Ongoing coverage in the District Dispatch
• ALA E-rate filings to the FCC
• FCC E-rate modernization summary (pdf)
• FCC E-rate modernization fact sheet (pdf)
• Handy collection of major FCC E-rate modernization documents
• The rulemaking process at the FCC
Read the E-rate summary and timeline (pdf)