As part of the 7th Report and Order, the FCC asked for further comments which were due September 15th, 2014. The FCC specifically requested comments around the following issues:
  • Future E-rate program funding needs
  • Multi-year contracts
  • Standardizing NSLP data collection
  • Encouraging consortia participation through discount rate calculations or other means
  • Whether support for libraries and library districts was sufficient

There were a number of comments filed by E-rate stakeholders. Highlights by topic are as follows:


Future E-rate Program Funding Needs


For the most part, there was overwhelming support for increasing the funding cap.  In particular, the FCC asked for data to show where applicants are in reaching set targets and goals, how much money it would take to get applicants to the FCC’s specified goals, if the budget amounts as proposed were sufficient and if the money freed up by the reforms would be enough to meet applicant needs. Almost all comments agreed that the overall funding cap on the E-rate program would need to be raised in order to meet the needs of applicants in future years.

Funds For Learning provided a detailed analysis of school and school district applicants, based on 2014 enrollment and NSLP eligibility, to project Category 2 budgets. The report shows that the current $1 billion set aside for FY2015 and targeted for future years will not be sufficient to meet the Category 2 needs of applicants for many years.

Other groups filing in support of increasing the funding for the E-rate program included the National Education Association; the Schools, Health & Libraries Broadband (SHLB) Coalition; State E-rate Coordinators’ Alliance (SECA); Cisco; Council of Great City Schools; and the Alliance For Excellent Education.


Multi-Year Contracts


The FCC also asked for comments on whether multi-year contracts should be limited to 5 years, including voluntary extensions. In particular, the FCC asked how a contract term limitation of 5 years would impact applicants purchasing off state master contracts. The State E-rate Coordinators’ Alliance (SECA) provided a list of states that either do not limit the term of the contract, or would extend beyond the proposed 5 year limit.


Standardizing NSLP Collection


Many commenters disagreed with the FCC proposal to standardize NSLP collection to reflect NSLP data reported by the appropriate state agencies to USDA’s Food and Nutrition Service (FNS). The New York State Education Department (NYSED), provided examples of how this would not provide accurate results in the state of New York.


Encouraging Consortia Participation


Many groups commented on consortia applications as well and how best to encourage consortia participation. Overall there was support for allowing a consortia to qualify for a 5% increase in their discount rate calculation. This idea was proposed by Education Coalition, who also filed Reply Comments to amend their definition of a consortia that would qualify for the increase. There was support for the proposed increase to consortia discount rate calculations, but not for defining a qualifying consortia.

The Alliance For Excellent Education also filed comments in support of allowing non-profit, private entities join in consortia applications with schools and libraries. The goal would be to expand anytime, anywhere learning opportunities for students.


Support for Libraries


The American Library Association filed Reply Comments regarding the sufficiency of support for libraries. The budget cap calculation at $2.30 per square foot was reaffirmed, along with discussion on continuing to increase the bandwidth support libraries receive. The proposed reforms will greatly assist with increasing Internet access within a library, but most libraries do not have the necessary bandwidth speeds to the site.