On Friday night, the ALA filed comments to the Federal Communications Commission (FCC) on the Public Notice on the proposed changes to E-rate application forms 470 and 471.
While the ALA supports the FCC’s efforts to streamline the application process, we believe changes should be postponed until after the commission issues its order setting new rules for the E-rate program to allow applicants time to become adequately trained with the revised process.
Additionally, the ALA’s comments point out that these forms are due for their regular review by the FCC as required by the Office of Management and Budget (OMB) every three years. We suggest that rather than change the forms now because of the OMB rule, the FCC should implement a comprehensive overhaul based on the decisions they will soon make regarding which E-rate reforms they adopt. These decisions will be informed by public comments on the E-rate Notice of Proposed Rulemaking (NPRM). ALA filed comments on July 9 and reply comments on July 26.
The ALA’s latest comments outline several specific recommendations should the FCC decide to go ahead with form changes before the order is issued.
ALA Office for Information Technology Policy