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OITP hard at work on the first E-rate Notice of Proposed Rule Making

As promised, the Federal Communications Commission (FCC) released the first of several intended Notices of Proposed Rulemaking (NPRMs) outlining proposed changes to the E-rate program (see the FCC’s Press Release for a summary of the NPRM).  According to the FCC the proposed changes will make the program “a more effective educational tool for teachers, parents, and students.” The FCC is seeking comment on a number of proposed reforms, including several for which ALA has been advocating during the last 10 years or so of the program.  Among others, these include: streamlining the technology plan requirement, raising the 2.25 billion dollar program cap, and simplifying the application and disbursement processes.

It is easy to get excited about seeing these proposed reforms in an official NPRM, but as all things E-rate, the devil is in the details and ALA’s Office for Information Technology Policy (OITP) is currently in the process of reading (and re-reading) the NPRM and associated previous Rules and Orders, in order to analyze the potential impact the reforms as stated in the NPRM may have on the library community.  We are fortunate to have expert advice from our E-rate consultant, Linda Schatz, as well on-the-ground experience from our E-rate Task Force under the leadership of chair Linda Lord and vice chair Maribeth Krupczak, and guidance from OITP Fellow Bob Bocher.

E-rate education and advocacy has been a major focus of OITP since the inception of the program.  The E-rate program has enabled thousands of libraries to connect to the Internet and maintain these connections through over 600 million dollars in discounts received in the first ten years of the program.  At the passage of the 1996 Telecommunications Act which initiated the E-rate program (officially known as the Schools and Libraries Universal Support Mechanism), just over 44% of public libraries had a connection to the Internet.  Today, ALA’s annual Public Library Funding and Technology Access Study reports virtually 100% of public libraries are connected to the Internet.  Despite this level of connectivity, there are still significant challenges to ensuring robust connectivity for public libraries, not the least of which are availability and affordability of broadband.  OITP recognizes these factors and has been actively engaged in a number of projects to help states ameliorate the broadband issues they face.

Throughout the tenure of the E-rate program, OITP has met with FCC staff to educate them about library specific issues related to connectivity and telecommunications.  More recently, OITP was actively involved in parts of the development of the National Broadband Plan.  Former Program on Networks Director, Carrie McGuire (Lowe) served on an FCC panel discussing the future of E-rate.  The office also worked with the Social Science Research Council on a project commissioned by the FCC which studied low-income broadband adoption issues.  OITP continues to work closely with several FCC staff members on elements of the National Broadband Plan as it moves from a set of recommendations to the next phases toward implementation.

Beyond regular interaction with the FCC and the submission of official comments to the FCC, OITP has been involved with several projects focusing on educating the library community about library connectivity in general and the benefits of the E-rate program in specific.  This spring marked the final training for state E-rate coordinators of a three year project funded by the Bill & Melinda Gates Foundation.  Ongoing education and outreach include monthly conference calls for the state coordinators with representatives of the FCC and the Schools and Libraries Division of the Universal Service Administrative Company (USAC), the organization that administers the E-rate program as part of the Universal Service Fund, for the FCC.  Additionally, the E-rate Task Force advises the work of OITP and actively participates in the development of official comments related to E-rate.

As we craft the ALA response to the current NPRM, we will depend on the institutional knowledge that has built up through OITP’s continual work on the E-rate program and all its many related facets.  In recognition of the FCC’s focus on broadening the broadband capacity of schools and libraries, thereby increasing the positive impact this kind of connectivity has on individual communities, OITP will be carefully evaluating the previous and current E-rate landscape in preparation for supporting a future facing library community.  Just as the previous thirteen years of E-rate have held tremendous opportunity for libraries, so too can the next.  ALA is well equipped to walk the fine lines between the E-rate program as we know it, the intent at the FCC, and the best interests of the library community.  The FCC encourages comments from all interested parties and there will be ample opportunity to do so during the reply period of this NPRM.  The comment date (30 days from publication) and reply period (45 days from publication) will be determined when the NPRM is published in the Federal Register.

It wouldn’t be E-rate if it weren’t a challenge, but the future opportunities are too important to pass up and ALA has a solid track record on supplying insightful and timely comments to the FCC.

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Marijke Visser

Marijke Visser is the associate director and senior policy advocate at the American Library Association’s Washington Office. She is involved in all stages of Libraries Ready to Code, E-rate, and Connect Home projects. She earned her bachelor’s degree in Peace and Global Studies/Sociology and Anthropology from Earlham College in Indiana. Before joining the ALA in 2009, Marijke earned her master’s in Library and Information Science from Indiana University-Purdue University, Indianapolis.

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