Wow, y’all. After reading all (yes, I said all) of the comments and reply comments to the FCC’s Category Two NPRM, I am astounded at the amount of agreement in the comments of E-rate stakeholders. Organizations of all types – schools and libraries, service providers, equipment manufacturers, consultants, trade organizations, and more – have given the FCC a consistent and crystal-clear picture of how the rules governing Category Two funds can be changed to the benefit of everyone involved. Multiple comments expressed support for the following reforms – each in their own way, but all pointed toward common goals:
- Making the Category Two budget system permanent
- Calculating Category Two budgets on a system-wide basis, rather than site-by-site
- Increasing the Category Two budget calculation factors and floors
- Expanding the scope of eligible services to include much needed network security, filtering, and other infrastructure functions.
Just imagine what we could do in the larger political arena with this unified of a voice! 1
Now for the hard part: the waiting game. While Funding Year 2020 may not start for another nine months, applicants – especially larger organizations with long procurement cycles – need to start making preparations now. And that can be tough when there isn’t a clear picture of how much funding can be expected.
This week, I spoke with an applicant in rural Oklahoma who had a simple question: “I need to do some network upgrades – what’s my budget for 2020?” What’s the answer? Well, this particular school received C2 funds in FY2015, so their initial five-year egg timer has stopped. So depending on what the FCC does (or does not) decide, their available funding is somewhere between a little bit (rolling budget cycles with no reset) to unlimited (no action from the FCC, reverting back to the two-in-five system) with multiple possible stops in between.
With each passing week, uncertainty about the future places increased stress on schools and libraries who are prioritizing their infrastructure needs and searching for ways to pay for them. Program participants have done their part, presenting the FCC with a realistic plan for making the program more useful and less complicated. Now is the time for the FCC to do theirs.
1No warranties expressed or implied.