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Some Changes Sought

Library Groups Welcome Draft FCC Tribal E-rate Order

Library groups and E-rate participants welcomed a draft FCC order and Further NPRM that would modify program rules for tribal colleges and university libraries and seek additional updates for all participants. Commissioners will consider the item during their open meeting Thursday (see 2306290056). Some sought clarifying language in the draft FNPRM.

Many of the items in the draft order "will greatly advance the E-rate program and benefit applicants," said the Schools, Health & Libraries Broadband Coalition in separate meetings with aides to Commissioners Nathan Simington, Geoffrey Starks, an aide to Chairwoman Jessica Rosenworcel and Wireline Bureau staff. The group sought several revisions regarding funding rules and eligible services, per an ex parte filing in docket 02-6.

The draft order would adopt a competitive bidding exemption for libraries seeking support for category two equipment and services totaling a "pre-discounted" amount of $3,600 or less in a single funding year. SHLB asked the FCC to extend the exemption to schools, noting the item "was not recommended previously by any party that submitted comments." The group also asked that the draft order's cost allocation standards for cabling be applied to "any equipment listed on the eligible services list," saying "other types of equipment in addition to cabling, such as switches, may also connect to E-rate ineligible equipment but would nonetheless be part of a local area network primarily serving an eligible purpose."

The draft order will "provide needed clarity in program rules and remove complex nuances in the rules that tripped up applicants," State E-rate Coordinators Alliance (SECA) said in a meeting with Wireline Bureau staff. SECA backed SHLB's suggested edits.

If adopted, the draft FNPRM would seek comment on invoicing deadline rules for E-rate participants. SHLB asked the FCC to issue a waiver on its own motion granting extensions automatically for requests made no later than the 15th day after the original deadline, "pending the completion of the FNPRM."

The American Library Association sought additional training for state E-rate coordinators "to advance equity and build capacity for libraries," citing its findings from partnering on outreach to tribal libraries during the E-rate tribal libraries pilot program in a meeting with a Rosenworcel aide.

SECA asked the FCC to include questions on discount calculations in its FNPRM. "Since discounts do not vary widely from year to year, we believe that a simplification measure would be to allow applicants to validate their discounts once every five years," the group said, noting it would "coincide with the same five-year period governing the category 2 budgets."

E-rate customers "sometimes ask providers to bid on and provide diverse circuits for backup purposes," said NCTA in a meeting with a Rosenworcel aide. The group sought clarifying language in the draft FNPRM regarding the prohibition on support for duplicative services. Responses to such questions "can affect whether a solution will be viewed as cost-effective and eligible for support," the group said, asking that the FCC include language asking how E-rate applicants or service providers can demonstrate that services wouldn't be "unreasonably duplicative."