The Federal Communications Commission Oct. 9 unveiled drafts of the application forms that schools and libraries will use to qualify and apply for E-rate funding. But at a workshop the next day it was clear that the forms themselves would not resolve some of the key questions that still surround how the program will be administered.
Representatives of the commission staff, the Schools and Libraries Corporation board and the National Exchange Carrier Association listened as workshop attendees representing associations, school systems, state departments of education and service providers offered comments and suggestions for improving the forms. One, labeled Form 470, will be used by schools and libraries to describe what kinds of services they need so that interested service providers can bid on them. The other, Form 471, will be used when schools and libraries are ready to request E-rate funds to purchase specific services.
FCC staffers repeatedly were careful to note that there were a number of issues they could not discuss because the commission was still considering how to resolve them. These included:
- what kind of technology plan approval will be required and by whom;
- how the discount rate will be determined when an application is submitted for more than one school and/or library, or aggregated for several school districts and other entities;
- how "educational purposes" are defined for determining eligible services;
- how applications to support existing services will be treated.
Frank Gumper of Bell Atlantic, the service provider representative to the SLC board, told attendees: "If we wait until every decision is made, no one will be able to complete the form" by the start date of Jan. 1, 1998.
Mary Ann McCormick, special counsel to the FCC, echoed that point of view at the end of the workshop. "We're very cognizant of the fact that we need to get the applications out on the street" so that people can start working on them. Then she added, "We acknowledge how anxiety-ridden this is. We go to bed at night with knots in our stomachs. We look forward to the SLC taking over the process."
Once the FCC revises its draft forms to reflect workshop suggestions and subsequent comments, they must be reviewed by the Office of Management and Budget for compliance with the Paperwork Reduction Act. That process is expected to take about two weeks under special "emergency" procedures. The FCC calculated that it should take three hours to fill out each of the two draft forms, a claim that many in the workshop audience greeted with skepticism.