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.”
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About Jacob Roberts
Jacob Roberts is the communications specialist for the ALA Washington Office.
ALA’s E-Rate Task Force continues to address E-RATE and Broadband regulations in a thoughtful manner. I’m particularly impressed with the simplification of the discount matrix as determined by the national school lunch program.
I’ve been away from e-rate for 2 years, but here are my questions:
1- Given there is a call for more money (raise the cap), could there be a USAC fee on telecom equipment such as routers? Right now, the fees only come from telecom services — voice, data, and wireless telecom services. Should equipment vendors pay to play?
2- Given the budget crunch at the national and state levels, if e-rate tech plans are moved down to the state or local level, how will those new or expanded jobs be funded? I can’t see e-rate dollars covering those costs.
3- Is there an AASL teacher librarian on the ALA E-Rate task force? There should be! ALA is in a position to advocate for teacher librarians and their pivotal role in teaching digital literacy to students (and classroom teachers). ALA is in a position to suggest specific wording in school technology plans, such as stating that “district plans include technology and professional development requirements of school library plans”. Most school network-based technology for students is based in the school library: networked computers, subscription databases, wireless access. As the economy has worsened, too many school districts have reduced budgets for school library programs. E-rate funds don’t go directly to school libraries, but ALA should use this highly visible funding program as an opportunity to advocate for strong school libraries.
Again, thank you for the good work you are doing. I look forward to hearing your responses.
Best wishes.
Jackie Siminitus
VP Communications
California School Library Association