[Libs-Or] INFORMATION: A lull in the E-rate action?

Diedre Conkling diedre08 at gmail.com
Thu Dec 12 11:21:07 PST 2013


A lull in the E-rate action?
Posted on December 12, 2013 by Marijke Visser

If there is such a thing, this may be a quiet period for the ongoing
that officially started in July with the FCC's
the E-rate Notice of Proposed Rulemaking now that the official comment
periods are over. The path getting from point A (the NPRM release) to point
B (an FCC order), is a long one. While there may appear to be a lull in the
action, this is the period when the end product is truly shaped out of the
broad range of recommendations; arguably, the most critical time of an FCC

Backing up to the November 8 reply comment deadline, it is gratifying to
see the number of library comments filed. Among them: the Idaho Commission
for Libraries, the Illinois State Library, the Kentucky Department of
Libraries, the West Virginia Library Commission; libraries that filed in
collaboration with other city of state agencies such as the Chicago Public
Library, the Free Library of Philadelphia, the Alaska State Library, the
Hawaii State Public Library System, the State Library of New York; COSLA
(Chief Officers of State Library Agencies) and the Urban Libraries Council.
Libraries also were well-represented in comments from the Bill & Melinda
Gates Foundation and Knight Foundation.

Filling the record with these substantive comments on critical library
issues adds tremendous value to our own ALA comments. Commenters
overwhelmingly agree that for libraries to provide community services, the
E-rate program must be fully funded immediately and also take into account
the trend for applicants to seek increased bandwidth speeds where they are
available. Commenters filed on the lack of affordable options for
high-capacity broadband where it is available, specifically in rural areas
but also in areas that serve the urban poor. These comments also build on
previous library comments filed during the initial round providing the
Commission with additional library-specific information in a proceeding
that has pulled stakeholders out of a much broader pool than in previous
E-rate proceedings.

After the September 16 and November 8 deadlines, work continues but
slightly less visibly in the form of individual meetings with
Commissioners, their staffs, and with the Wireline Bureau E-rate team.
Evidence of the ongoing work shows up in ex
parte<http://www.fcc.gov/encyclopedia/ex-parte>filings. To date there
are over 80 of these records of individual meetings
on commenters' issues, questions, clarifications, additional data, and
other information, all of which is included in the final record that makes
up an FCC order, the end result of a rulemaking.

ALA, for instance, recently
met<http://apps.fcc.gov/ecfs/document/view?id=7520957956>with the
Wireline Bureau E-rate team, Commissioner Rosenworcel and her
Wireline legal advisor, Christi Barnhardt, and  Nick Degani, Wireline legal
advisor to Commissioner Pai. During these meetings, we further described
the two-prong approach we advocate for ensuring libraries have the
high-capacity broadband they need. First, we seek an immediate infusion of
funding to the E-rate program for build-out in areas where high-capacity
broadband is not available to libraries and schools. This temporary
program, "ConnectUS," builds on the President's ConnectED initiative.
Second, ALA proposes a pilot program, "FINAL," targeted to libraries where
capacity is available but where costs inhibit them from taking advantage of
higher speeds. In the coming weeks we plan to further develop these two
concepts and have been seeking input from members of the Washington Office
telecommunications subcommittee, the E-rate Task Force and other library
leaders. (We also have a running list of additional questions from the FCC
for which we are gathering examples from the library community).

In addition to meeting on our own, we have meetings with our coalitions,
SHLB (the Schools, Health and Library Broadband Coalition-see their ex
parte filings on
and EdLiNC (the Education and Library Networks Coalition). We anticipate
another round of ex parte meetings, likely to continue up until that
indeterminate deadline when the Commission announces it will put an order
up for vote during an open Commission meeting.

So is there really a lull in the E-rate action? Apparently not.


*Diedre Conkling*

*Lincoln County Library DistrictP.O. Box 2027Newport, OR 97365Phone & Fax:
541-265-3066Work email**:
**diedre at lincolncolibrarydist.org*<diedre at lincolncolibrarydist.org>
*Home email: **diedre08 at gmail.com* <diedre08 at gmail.com>

 "If you don't like something, change it. If you can't change it, change
your attitude."--Maya Angelou
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