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NPRM Comments Favorable to Proposed Changes

Several organizations made comments to the Federal Communications Commission's Notice of Proposed Rulemaking on the eligibility of products and services in the E-rate program, according to an analysis by Funds For Learning. Comments were submitted by E-rate stakeholders from across the country as part of the FCC's review process of its current product and service eligibility guidelines.

The majority of the comments were centered around telephone broadcast messaging, anti-virus, anti-spam, and filtering software. Many applicants and service providers that submitted comments were in favor of allowing the E-rate program to provide discounts for these services and software; noting that these components are required–either by CIPA or for as a common-sense approach to protecting users and network assets.

While applicant and service provider support including these services is notable, others expressed concern about the increased demand on funding if these products and services were included. As the demand for funding increases, the Priority Two funding request discount threshold increases as well. For Funding Year 2007, the discount threshold for Priority Two services is set at 81%; meaning that any funding request at or below 80% has been rejected.

Stakeholders wishing to respond to any submitted comments may provide "Reply Comments" to the FCC. The deadline for submitting Reply Comments is October 3, 2008.


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