After schlepping the 176 pages of the E-rate modernization Order around since July 23 (when the Commission released the Order, voted on July 11), my bag is remarkably empty today. While I didn’t continually refer to it over the last month and a half, it has been a constant companion as we prepared our comments to the Commission on the Further Notice of Proposed Rulemaking (FNPRM) that accompanied the July Order. I can unabashedly leave it behind since we filed our comments (pdf) last night.
E-rate may be the “other” proceeding with comments due yesterday, but for ALA they represent a milestone of sorts. True to form, the Commission asks many detailed questions in the FNPRM, but two issues stand out for us. First, the Commission opened the door to talk about the long-term funding needs of the program. Second, it’s now time for the Commission to take up our concern that has followed ALA certainly since this proceeding began a year ago, but really since ALA started tracking broadband capacity of libraries. We reopen the call to immediately address the broadband gap among the majority of libraries. With 98% of libraries below the 1 gigabit capacity goal asserted in the National Broadband Plan and adopted by the Commission, we have a long way to go before we can comfortably say we have made a dent in the gap.
In looking to the next order (hopefully sometime this fall) we have heard from our members that while having access to more funding for Wi-Fi (the heart of the July Order) is important, if the library only has a 3 or even 10 Mbps connection to the door, the patron trying to upload a rÃ©sumÃ©, or stream an online certification course, or download a homework assignment is still going to have a marginal experience.
Our comments therefore focus on these two primary issues–adequate funding to sustain the program and closing the broadband gap for libraries. Among other recommendations we ask the Commission to increase and improve options for special construction where libraries do not have access to affordable, scalable high-capacity broadband by:
- Clarifying the amortization rules;
- Eliminating the ban on special construction for dark fiber;
- Allowing longer term contracts where there is special construction involved; and
- Requiring service providers to lock in affordable prices for a significant number of years for agreements involving special construction.
As to the overall funding question, ALA is engaged with partners to gather data that will give us an understanding of the costs necessary for libraries to achieve the Commission’s capacity goals. We plan to submit information to the Commission in the next several weeks.
For more details on our comments you can certainly read the whole thing. Or, we prepared a summary (pdf) to start with. With reply comments due at the end of the month, it’s time to get started reading other submissions and picking up where we left off (and with FCC filing system intermittently down–all those net neutrality filers, no doubt). We will continue connecting with our library colleagues and will begin more meetings at the Commission. More to come!