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The Order’s out – now what? ALA seeks clarification on FCC E-rate Order

It may appear that all has been quiet in the Washington Office regarding E-rate, but things are never quiet for long with E-rate.  Since the release of the FCC’s Sixth Report and Order on September 28, we have been reviewing the numerous changes in the Order and assessing their potential impact on applicants especially in relation to the 2011 E-rate application  process.  While there was great excitement with the initial release, as with all things E-rate, when the dust settles, it remains important to vigilantly evaluate program changes in order to fully understand the effect even minor changes in language can have on applicants.

The FCC produced this newest Order in about four months.  It was part of the Commission’s effort to follow through with recommendations made in the National Broadband Plan to update the E-rate program and make it easier for more schools and libraries to benefit from this successful program.  This monumental task began with the release of a Notice of Proposed Rule Making in May which generated over 3,000 pages of comments from some 400 commenters.  Now that stakeholders, including ALA, have had the opportunity to read through the resulting Order, it is clear that there are a number of areas that will require further clarification — perhaps even changes — from the Commission.

Fortunately, we have Linda Schatz as our E-rate consultant as well as additional help from OITP Fellow, Bob Bocher advising us on telecommunications policy and library connectivity.  We gain “real world” input from the ALA E-rate Task force (Linda Lord, chair and Maribeth Krupczak, vice-chair).  With the help of this expertise, ALA identified areas in the Order that require more clarity.

ALA is paying particular attention to the addition of dark fiber to the 2011 Eligible Services List.  While ALA generally supports increasing the options for libraries to select the most cost-effective solution for their Internet and/or telecommunications needs, we remain attentive as to how this addition will be implemented.  Applicants need clear rules and guidance to be able to take full advantage of this new option while at the same time ensuring that they have been compliant with the new rules.

ALA has met with FCC staff several times to bring some of our issues to their attention and to seek the clarification we know is necessary in order to provide libraries with the most accurate information possible.  ALA is also generating a list of questions collected from state E-rate coordinators and members of the E-rate Task Force to submit to the Commission for its consideration.

At the very least, it is likely that the Commission will issue an erratum to address minor issues.  It is also possible that the Commission may issue an Order on Reconsideration to address any significant areas that it determines require more in depth clarification or to make actual changes to the Order.  Through our meetings and discussions with FCC staff, it is clear that their intent is to address concerns brought to their attention so that additional clarity and/or changes can be made as necessary.  In any case, we are in a period of flux as we await further action by the FCC.  Here in the Washington Office, we will continue to advocate on behalf of E-rate applicants and will inform the library community as new information comes to light.

Marijke Visser
Office for Information Technology Policy (OITP)

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