FCC Proposes Category 2 Changes & Seeks Comments
This week the FCC released the long-awaited Notice of
Proposed Rule Making (NPRM) on the E-rate Category 2 program. The good
news is that the FCC proposes to take the 5-year “C2 test” period and make it
permanent (and not revert to the old 2/5 system), as well as extend the
eligibility of MIBS, caching and basic maintenance services. Unfortunately,
the NPRM does not provide an answer to the biggest question -- what funding
will be available in FY 2020 for applicants that first used C2 funding in FY
2015. To develop those rules, the FCC is seeking comments on a long list of
questions/issues, for which I have summarized the most significant ones below. After
the comment period, the FCC will review the submissions and develop final rules
for implementing C2 budgets in FY 2020, and any other changes they’d like to
make to the program. Hopefully, that Order will be released this fall.
I have included 2 links just below. These are a summary the actual NPRM from the FCC and a chart that correlates back
to the NPRM by paragraph. The actual NPRM is only about 13 pages long and I
encourage you to read it and consider submitting comments, even if only to
provide input on a single question or issue. Let me know if you’d like to do
this and I’ll help you navigate how to submit to the FCC’s ECFS comment system.
Comments will be due on August 16, 2019.
Reply posts are due by September 3, 2019.
Reply posts are due by September 3, 2019.
Links:
Summary of Major Questions in NPRM:
- FCC
proposes to keep the current $150/student (adjusted for inflation) budget
multiplier.
- Should
the minimum budgets for small schools and libraries be increased to
$25,000? (¶ 20)
- Should
the rural library budget multiplier be increased (perhaps to match the
urban library $5.00/sq. ft. multiplier)? If so, submit specific
data and examples to support the need. (¶ 21)
- Should
budgets be administered on a districtwide basis? Would libraries
benefit from a system-wide budget? (¶ 24)
- If
district-wide budgets are adopted should the equipment transfer rules
within a district be eased? (¶ 27)
- Should
the student count and square footage in the first year of a five-year
cycle be used for all five years to ease administration of the budgets?
- Or
are there significant advantages to having the budgets rise (or fall)
depending on student population or square footage each year? (¶28)
- Should
a presumption be established that the student counts verified in one of
the last four funding years are still accurate for the purposes of
setting a category two budget, absent an effort by the applicant to
increase the student count? (¶ 28)
- Should
5-year budgets be allocated on a “rolling” basis or should there be fixed,
5-year periods for everyone (e.g., FY 2020-2024, FY 2025-2029,
etc.)? What are the costs and benefits of either proposal? (¶ 32)
- Should
all C2 budgets be reset as of FY 2020? (¶ 35)
- What
are best ways to transition from the existing C2 budget rules following
the five-year test period, to the new rules?
- Should
the current rules be extended for one year, without modification, so that
FY 2020 will be used as a bridge to transition to the final rules? (¶ 36)
- What
are the best ways to reduce applicant confusion and provide for
simplified administration of the C2 budgets as we move beyond funding
year 2019?
- Are
there any additional services that should be eligible for category two funding
or any other issues regarding category two eligible services that the FCC
should consider? (¶18)
If you have any questions, please let me know.
-- Todd Lawrence
