ALA files E-rate comments with the FCC about C2

I <3 E-rate button on a desk.ALA, along with over 140 libraries and library organizations, submitted comments to the Federal Communications Commission on its Public Notice seeking information about the E-rate program category two (C2) budgets yesterday.

ALA’s comments highlight the fact that libraries are assured access to critical funding for internal connections for the first time in many cases in 15 years. This is true whether you are a small rural library in Montana or a large urban library in Pennsylvania. ALA strongly supports the current C2 budget process.

We note, however, that it is premature for the FCC to make comprehensive assumptions about why libraries are not applying for C2, as there are many different reasons why not. We heard from the ALA E-rate Task Force that planning for an equipment upgrade can take a long lead time, which does not correspond to the E-rate application window. Libraries may also be preparing for new construction and holding off on applying until those plans are finalized.

Our comments also raise several issues that should the FCC address them, we think it likely that more libraries can make use of their C2 budget allotment. In brief, these are:

  • The FCC should direct USAC to accept the IMLS square footage data to determine the library budget without further PIA review;
  • Allow applicants to spend their C2 funding over two years; and
  • Review and fund C1 and C2 applications at the same time.

While we do not have any indication that the current $2.30 per square foot is insufficient, we do ask the FCC to add another IMLS locale code to the pool of libraries eligible to receive $5 per square foot.

We look forward to working with the FCC as they move forward with determining how to address issues raised in the ALA comments as well as those from more than 140 libraries that also submitted comments. Having that number of libraries on record voicing their support for E-rate and C2 is phenomenal. Thank you all for stepping up!

Of the libraries that filed yesterday, many have submitted personal stories that paint the picture of library users across the country downloading job applications, applying for financial aid, seeking health information, and communicating with family – all dependent on a strong WiFi signal.

For example, the Vigo County Public Library in Terre Haute, IN filed a comment that goes into detail about the library’s mission and the way high-speed internet has impacted the library’s customers:

“Whether looking for a new job, taking classes, connecting with family and friends, or simply downloading a book to read, the service we are able to provide is appreciated by our community. We would not be able to offer the range of programming and other services without the funding provided by Category 2 to upgrade our equipment.”

North Carolina’s Durham County Library’s comment tells the story of a patron who had complained about the Wi-Fi but wrote in again to complement the library on its upgrades. The letter also has a great quote:

“A library without reliable internet access is almost like a library without books.”

Robertson County Public Library, which is the smallest Kentucky county by both population and geographic area, explained the importance of Wi-Fi to her community.

“The nearest college is 25 miles away and many of our patrons use our WiFi for their classwork. There is no industry in our county so a large percentage of people travel out of the county to work. They can be seen using our WiFi in the library parking lot after hours, many nights per week.”

Patrons are also voicing their support. A woman in New York wrote in who relied on Wi-Fi at Bennington Free Library in Vermont while unemployed during the recession.

The Texas Library Association states, “College students, jobseekers, K-12 students, small business owners, entrepreneurs, researchers, seniors, and community members across Texas rely on libraries as a vital link to online information and resources… Libraries must continue to invest significant resources in costly internet equipment and services, and expand their WiFi and internal connectivity to offer enhanced access to their communities.”

Want to file comments? You still can! We have until November 7 to file reply comments. Commenting at the FCC takes a few steps, but it’s not challenging. Here’s what to do:

  • Format your response as a PDF document (Use letterhead!).
  • Go to https://www.fcc.gov/ecfs/filings
  • For the Proceeding Number, enter the following proceeding numbers: 13-184
  • Complete the rest of the information on the form.
  • Select “REPLY TO COMMENTS” in the drop-down menu under “Type of Filing”
  • Upload your comments at the bottom of the form.

Not sure what to write? Use this template to tell the FCC how your patrons depend on the library to connect to the internet. We encourage you to edit the template to add specifics (like the examples above!) that are important to your library and your community. These stories and examples are critical for the FCC to know about!

About Marijke Visser

As associate director and senior policy advocate, Marijke leads and coordinates all of ALA’s work on E-rate. In addition, Marijke supports the Program on Networks focusing on broadband adoption issues for diverse populations. Marijke also serves as Program Director for OITP’s emerging portfolio on children, youth, and technology.

2 comments

  1. A quote from one person in Lodi, WI, which is located over 20 miles from a college, a patron recently said,
    “For me, the library connects people without technology to the rest of the world.”
    “Not only do I get books there, but their technology allows me to order more obscure books from other libraries.”
    She went on to say “It is also a resource for me as the Lodi Ag Fair approaches to research exhibit requirements that no longer are printed.”
    In addition, she said “I go there to check my e-mail from work.”
    Visit our library, every day people are there for short and long stays. Recently I assisted in a count of people using our library and it is amazing to witness the people from all walks of life that are dependent on our library community. I am a member of “Friends of the Lodi Library” a fund raising arm of our library and we have projects going all the time to help pay for services. We are trying to do our part, so please help us.

  2. A library without WFI.. is a library without books… This is critical !! I appreciate the WFI for book notices and music.

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