FCC Seeks Comments on How to Improve Category 2 Funding
Program
Public Notice Document:
The FCC has just released a Public Notice seeking comments
from schools, libraries and others about the E-rate Category 2 funding
initiative and ways it should be improved. Specifically, they are seeking
input on these issues:
- The
sufficiency of Category 2 budgets.
a. Is
$150/student (or $2.30 or $5/sq. foot for libraries) over 5 years enough
funding? How have applicants have used their budgets and what percentage
of the eligible C2 projects were NOT covered by the C2 budget amounts?
b. Are
there specific situations where the C2 budgets were not enough because of
differences in geography, rural status, applicant type, or student population?
c. For
those applicants that have not used any of their C2 budgets, why? Did
those applicants already have adequate internal connections in place before FY
2015 when the C2 initiative began? Do they intend to seek support for
category two services in FY 2018 or FY 2019?
- The
administration of the budgets from both from a policy perspective and with
regard to the application process.
a. Should
the C2 budgets be calculated differently (different than student counts or
square footage)? Is there a simpler way to calculate the C2
budgets? If so, how? How would that simpler method be an
improvement over the current system?
b. How
could the current C2 application process be changed to ease the burden on
applicants? Specifically, how could EPC be changed? The Form
471? The Invoicing Process? Form 500?
Feel free to include comments on anything Category 2-related
that you want the FCC to know or change, not just the topics listed above, such
as…
a. District-wide
allocation instead of building allocation?
b. Easing
of equipment transfer rules?
c. Need
for comprehensive C2 budget tracking tool?
d. Expansion
of eligible equipment list?
Comments are due by Monday, October 23. If
you’ve ever thought, “$150/student isn’t nearly enough to cover what we need in
a school,” or “I wish the rules gave districts a single C2 budget that covered
all buildings and not require a building-by-building allocation,” this is your
chance to provide input to the very FCC officials who will be making those
changes. I encourage anyone who has comments – even brief, 1 page
comments that only touch on one aspect of C2 – to submit those comments to the
FCC by October 23. I promise you, the FCC staff who write the rules
read every comment that is submitted.
Submitting comments is easy to do and here are the
steps:
Writing Comments:
- Put
comments on district or library letterhead.
- Reference
“Category 2 Public Notice - WC Docket No. 13-184” at the top of your
document.
- Include
your name and contact information.
- Wherever
possible, include examples and data. If the $150/student wasn’t
enough, explain the exact amount you needed for eligible equipment.
Uploading Comments to the FCC:
- Go to: https://www.fcc.gov/ecfs/filings.
There will be a cover page containing several fields which should be
completed as follows:
- Proceeding:
13-184
- Name
of Filer: School or Library Name
- Law
Firm: Leave Blank
- Attorney/Author
Name: Name of Person Submitting Comments
- Type
of Filing: COMMENT
- Then
upload your comments, select ‘Continue to Review Screen,’ and then
‘Submit.’
If you have any questions about this Public Notice or would
like me to review your comments before they’re submitted, please let me know!
Thanks,
Todd Lawrence
