ALAWON: American Library Association Washington Office Newsline Volume 11, Number 15 March 4, 2002 Seeking Library Input for E-rate NPRM ALA is preparing comments to respond to the Federal Communications Commission's (FCC) Notice of Proposed Rulemaking (NPRM) regarding the E-rate. In order to make comments that poignantly and accurately demonstrate the needs of the library community, ALA has identified several areas in which we particularly seek input. The following questions are meant to provide a framework for that input. They are not a survey, but are intended to provide ALA with very real examples of what libraries have experienced in working with this program. We encourage you to look through the questions and answer those for which you have the strongest experience, example or opinion. DO NOT FEEL THAT YOU MUST ANSWER EVERY QUESTION. Do feel free to be thorough and share your reasoning in your comments. Please send your responses to any of these questions to Claudette Tennant at ctennant@alawash.org. 1) The FCC is seeking comments on the eligibility of several specific services, including Wide Area Networks, wireless services, and voice mail. Our comments to the FCC will support a rational, transparent and forward-looking process for determining eligibility. Other than those mentioned by the FCC, we would like to determine what other services need to be addressed. * Are there services you would like to use but that you believe are not eligible? * If so, which ones? * Have you ever had an application rejected because a service was ineligible? * If so, please explain. * Do you have any comments or suggestions on improving the current Eligible Services list? 2) The FCC is seeking comments on whether E-rate discounts should be available when Internet access is bundled with content services. We would like to know if any of you have had any experiences regarding this practice. * Have you been unable to obtain Internet access except as bundled with content? * Is obtaining Internet access bundled with content the only economically reasonable option in your experience? 3) Currently, the Administrator only reviews funding applications where 70% or more of the services requested are considered eligible services. If less than 30% of the services are ineligible, the Administrator will review the application and award funds for the eligible services. If 30% or more of the services are ineligible, the funding request in denied in its entirety. We would like to know if this rule has been a problem for you. * Have you ever had a funding request denied because more than 30% of the services requested were ineligible? * If so, please describe the eligible and ineligible services. 4) The FCC also addresses consortia in this proceeding. We think this is an opportunity for the FCC to really understand some of the issues our consortia members have run into. * We ask our consortia members to please tell us about particular problems that you have encountered with the Administrator based on being a member of a consortium. This should include: * Problems regarding the application process. * Problems in the appeals process. * Problems in communicating with the Administrator. * What changes to the current rules relating to consortia would improve the program for consortium members? 5) The FCC is proposing audit requirements where the Administrator has reason to suspect that a problem exists. The FCC is seeking comments on how an audit requirement would affect applicants. We understand that most of you currently have audit requirements, and may view additional requirements as burdensome. It would strengthen our argument if we could provide the FCC specific examples of such burdens. * Please share some of your concerns over having to comply with an additional audit requirement. * Explain the nature and frequency of your current audit requirements. * What alternatives to audits do you believe could help ensure the program's integrity? 6) The FCC has found that in the last few years, only 71% of committed funds were actually disbursed to applicants. In order to make the best use of available funds, the FCC wants to learn more about why applicants do not expend all the funds committed to them. We understand that conditions often change between the time an application is submitted and the time a library is ready to purchase the services it has requested. For example, providers go bankrupt, service charges decrease, projected budgets and funding are not approved, bond initiatives fail, and so on. We would appreciate learning of other reasons that you are aware of. * Have you ever decided not to take advantage of an E-rate funding commitment? * If so, why? * Have you ever been forced by circumstances outside your control to accept less E-rate funding than the full amount you were authorized? * If so, why? 7) While the FCC has not asked any specific questions regarding state and regional E-rate coordinators, we feel it is necessary to comment on the importance of coordinators. We would appreciate from you any stories or anecdotes regarding assistance you have received from E-rate coordinators. * Have you ever sought assistance from your state or regional coordinator? * Was the coordinator helpful to completing your application? * Was the coordinator helpful in dealing with issues that arose while your application was being processed 8) The FCC does ask for comment on any administrative or procedural rules or policies that should be revised. ALA intends to call attention to the rules governing the use of National School Lunch Program numbers in determining the discount for libraries as an area that needs attention. We would appreciate examples of your experience regarding NSLP data. * What has been your experience in obtaining NSLP data? * Do you feel that NSLP data accurately reflects the poverty rate of your area? * How might NSLP data be used more effectively and fairly for libraries? Finally, these questions do not represent the breadth of the issues that ALA will address in its comments. We anticipate being able to share and outline and key arguments from our comments in the very near future. If there are additional areas of the NPRM to which you would like to call ALA's attention, please feel free to do so. ****** ALAWON (ISSN 1069-7799) is a free, irregular publication of the American Library Association Washington Office. All materials subject to copyright by the American Library Association may be reprinted or redistributed for noncommercial purposes with appropriate credits. To subscribe to ALAWON, send the message: subscribe ala-wo [your_firstname] [your_lastname] to listproc@ala.org or go to http://www.ala.org/washoff/alawon. To unsubscribe to ALAWON, send the message: unsubscribe ala-wo to listproc@ala.org. ALAWON archives at http://www.ala.org/washoff/alawon. ALA Washington Office, 1301 Pennsylvania Ave., N.W., Suite 403, Washington, D.C. 20004-1701; phone: 202.628.8410 or 800.941.8478 toll-free; fax: 202.628.8419; e-mail: alawash@alawash.org; Web site: http://www.ala.org/washoff. Executive Director: Emily Sheketoff. Office of Government Relations: Lynne Bradley, Director; Camille Bowman, Mary Costabile, Don Essex, and Miriam Nisbet. Office for Information Technology Policy: Rick Weingarten, Director; Jennifer Hendrix, Carrie Russell, Claudette Tennant. ALAWON Editor: Bernadette Murphy.