On August 16, the initial comment period for the Federal Communications Commission’s Category Two Notice of Proposed Rulemaking closed, with the FCC receiving more than 100 comments from E-rate stakeholders nationwide.  Funds For Learning’s filings included suggestions for regulatory reform as well as a program-wide analysis of C2 utilization from Funding Years 2015-2019.
 
Comments were received from schools, libraries, service providers, equipment manufacturers, state Departments of Education, consultants, and industry trade groups, and support was almost unanimous for the following regulatory reforms:
  • Permanently retaining the Category Two budget/cap system
  • Enforcing the C2 cap on a systemwide basis (instead of site by site)
  • Retaining Basic Maintenance, Managed Internal Broadband Services, and caching on the program’s Eligible Services List
  • Adding C2 support for advanced network security technologies
While opinion is split between “rolling” or “static” budget periods, almost all commenters who expressed an opinion favored a total reset of prior years’ C2 utilization status starting in FY2020.  Other reforms supported by multiple stakeholders include:
  • Eliminating C2 “subcategories” (IC/BMIC/MIBS) and collapsing the Eligible Services List into only Category One and Category Two services
  • Raising the cap calculation factor to at least $250/student and $5/square foot for libraries
  • Adding self-provisioned network management and monitoring equipment to the Eligible Services List
  • Eliminating C2 equipment transfer restrictions
  • Reducing the need for cost-allocations by:
    • Allowing C2 equipment to be installed in Non-Instructional Facilities (NIFs)
    • Clarifying that eligible equipment may be used for any purpose
    • Allowing multi-year maintenance and support agreements to be funded as a one-time cost in a single Funding Year
  • Raising the budget “floor” for less populated and smaller locations to at least $25,000
A complete list of individuals and organizations submitting initial comments along with links may be downloaded here. The deadline for reply comments is September 3.