The American Library Association (ALA)’s comments (pdf) to the Federal Communications Commission (FCC) regarding the E-rate program, the program that provides schools and libraries with discounts on telecommunications services, urge the FCC to implement and build upon recommendations proposed in the National Broadband Plan (NBP).
The ALA wholeheartedly supports the FCC’s initiative to “maximize the utilization of broadband” and agrees “it is time to re-examine what is working well and what can be improved in the current program.” The ALA acknowledges the tremendous scope of this undertaking and commends the FCC for the opportunity to comment.
The association calls on the FCC to streamline the E-rate application process and index the annual funding cap to inflation plus address actual applicant demand, among a number of other recommendations. ALA continues to caution the FCC not to expand the program to new services at the expense of the critical current applicant needs.
“Over the past 13 years of the E-rate program, libraries have received over one billion dollars. This figure represents real dollars libraries are bringing to their states and local communities – something that is of no small significance when we hear stories about shrinking budgets from libraries across the country,” said Marijke Visser, information technology policy analyst for the ALA’s Office for Information Technology Policy.
“Libraries depend on E-rate discounts in order to be able to provide services their patrons have come to expect – completing job applications, participating in online classes, learning basic computer skills. ALA will continue to monitor the progress started with this Notice of Proposed Rulemaking and expects to provide additional comments on some of the issues during the reply comment period.”
While the ALA believes the commission accurately identified application complexity as a major stumbling block for libraries, the ALA specifically asks for further streamlining to make it easier for applicants to apply for and receive discounts. The ALA also proposes that the commission should remove the technology plan requirement entirely from the application process and allow applicants to rely on the requirements of their own state and local governments.
The association’s comments affirm the ALA’s position that Priority Two services, such as internal connections and basic maintenance of connections, are an important component of providing advanced telecommunication services, but the association suggests that the primary focus should remain Priority One services. Without adequate funding for Priority One services, libraries would have little need for Priority Two funding. The ALA asserts that this is critical since proposals to improve applicant access to Priority Two services are all at the cost of Priority One services.
The ALA projects that applicant demand for Priority One and Two services in 2010 is about $10 billion – more than the entire Universal Service Fund – and will reach close to $13 billion by 2015. Since, as the NBP states, the current buying power of the $2.25 billion fund has diminished by about $650 million since the beginning of the program, the ALA asserts that raising the cap to the rate of inflation is the correct first step in increasing the buying power of the fund but more needs to be done to account for actual applicant demand.
Linda Lord, State Librarian of Maine and chair of the ALA E-rate Task Force, believes that the changes the ALA seeks will benefit citizens in every state.
“In the State of Maine every school building and every public library benefiting from E-rate is receiving a 10mbps connection this summer. This would not be possible without the federal e-rate program” Lord said.
“Since many of our citizens rely on public library computers for job information, access to government forms, legal and medical information, and general research, we regard this connectivity as an essential service to Maine citizens. Simplification of the E-rate process, while maintaining its integrity, and raising the funding cap will make this program even more accessible to libraries in Maine and across the country.”