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Up Next? E-rate and it’s worth the wait

We’re not sure how you best characterize waiting with your finger poised over the refresh key anticipating the release of an FCC Public Notice. But, nonetheless, we at ALA were not the only ones who impatiently awaited the latest installment of the E-rate modernization proceeding that began last June (if not before with the 2010 National Broadband Plan) with the President’s ConnectED initiative announcement.

Since the summer release of the Notice of Proposed Rulemaking (NPRM), the Commission has logged over 1500 comments and ex parte filings. Some of the issues raised in the NPRM warrant further public input to help the Commission determine the best path forward. To that end the Commission is seeking detailed input on three specific issues:

  • “How best to focus E-rate funds on high-capacity broadband, especially high-speed Wi-Fi and internal connections;
  • Whether and how the Commission should begin to phase down or phase out support for traditional voice services in order to focus more funding on broadband; and
  • Whether there are demonstration projects or experiments that the Commission should authorize as part of the E-rate program that would help the Commission test new, innovative ways to maximize cost-effective purchasing in the E-rate program.” (Paragraph 4)

Within these issues, there are a number of critical questions asked that are important to libraries and decisions made through the public record will certainly influence library broadband capacity and the ability of libraries to deliver key community services. The opportunity to shape the future direction of the E-rate program is immense and therefore somewhat daunting as we begin to fine-tune our own proposals. In our initial comments and throughout the process we have sought input and feedback from a wide range of librarians and expect to do so again through the guidance of the ALA E-rate Task force, other ALA member leaders, and expert consultants.

Once a Notice is released, the most common thing to do is count the pages (phew, “only” 20 pages of questions) and search for your key interest — in our case “librar.” It is noteworthy to mention that a number of comments by libraries are cited as well as those from ALA. Moreover, some of our ideas are discussed explicitly (paragraph 59). This is reflective of the Commission’s dedication to capturing the important role libraries play in their communities that broadband enables; the great need libraries have in boosting broadband capacity; and potential differences in needs of libraries from our school counterparts.

We are gratified to see that the Commission remains open and even aggressive in soliciting new ideas about how to make sure the program is efficient and effective — that funds are targeted to the most critical services that build library and school broadband capacity. As stated in the Notice, the targeted issues are not the sole issues that could be included in a final order. They are simply the ones for which the record to date was either unclear or commenters were equally split, or where the Commission needs more detail to fully understand how to address some of the stickiest challenges raised in the NPRM.

Many of the questions posed ask commenters to make difficult choices — such as what is the most equitable means to ensure applicants receive funding for internal wiring and Wi-Fi networks and determining how to handle voice services in a program gearing toward a broadband capacity focus. Though not mentioned in the Notice, we do understand that increasing the overall size of the fund is still somewhere on the table — while we feast on this Public Notice, we expect the overall funding question to be the next course.

So what’s the next step?

Comments are due April 7th with reply comments due April 21st. For the next few days we will be nose down reading and parsing the Notice which will be a break of sorts from the multiple meetings we have had with FCC commissioners and staff, as ALA, and as part of inside-the-beltway coalitions — in person and by phone. These meetings were a combination of advocacy for the role libraries play in education, employment and entrepreneurship, and empowering people though providing access to e-government, health information, digital literacy training, and similar services and providing the Commission with library data of the current state of broadband capacity, network configuration, and projecting future trends in library services that call for a scalable approach to building capacity for libraries.

We are appreciative of the careful review the Commission has given to the public record. In reality, the process, though sometimes murky and arguably long, is successful. Concepts are being analyzed, issues debated, and solutions weighed. There will be some changes in the future which will have to be worked through when implemented and we expect some discomfort. However, we support the direction of the Commission as we think about library needs five, ten, and twenty years from now. We view the Notice as another important step in the future of the E-rate program and thus the future of broadband capacity for all libraries.

Alan Inouye, OITP director, did the hard part of this post by getting the first thoughts down and contributed with thoughtful suggestions.

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Marijke Visser

As of November 2018, District Dispatch is no longer being updated. It is now being archived for future use. Please visit for the latest news.

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