Reply comments on the FCC’s Public Notice on E-rate Modernization (DA 14-308) were due last Monday, April 21st. Depending upon how you count — because many recent filings in this proceeding were labeled “COMMENT,” rather than “REPLY TO COMMENTS” — we estimate that there were less than 100 reply-type submissions filed within the last week of the reply comment window.
Many of the reply comments focused on a few key issues, including:
- The best method to allocate limited funding for broadband internal connections equipment. The FCC has proposed three alternatives, briefly referred to as (a) 1-in-5, (b) rotating bands, and (c) annual budget caps. Each, or some combinations of each, have their supporters. As long as funding remains limited, there will be advantages and disadvantages to any allocation process.
- The wisdom of assigning funding from a single pool of funds or from separate pools established to assure some funding for certain categories. The FCC appears to be leaning towards the creation of separate funding pools for (a) broadband network services, (b) broadband internal connections equipment, and possibly smaller pools for (c) capital investment for applicants currently without any broadband access, and/or (d) demonstration projects. E-Rate Central’s reply comments note the difficulty of accurately predicting demand for separate pools, and urge the FCC to adopt flexible allocation and reserve procedures to account for actual vs. projected demand for funds.
- The desirability of funding demonstration projects. One side, led by the American Library Association (and a few other library organizations), supports grant-type demonstration projects, including those for technical assistance. Others, largely school organizations, argue against diverting E-rate funding to demonstration projects as being administratively burdensome and difficult to evaluate in a timely fashion.
- The growing acceptance — albeit with some reluctance and with clear differences on details — of the need to eliminate or phase out E-rate support for “legacy” services and/or to reduce discount rates (as least for the internal connections category of service).
- Support for positions raised in initial comments by the State E-Rate Coordinators’ Alliance encouraging the FCC to revisit the following two appeal decisions:
- The Macomb ISD decision that effectively prevents applicants from contracting with more than one carrier to design more fail-safe networks using “multi-homing” or load-balancing. In the Macomb case, the FCC had determined that only one service provider’s bid could be deemed most cost-effective.
- The Queen of Peace decision that creates major bidding problems for state procurement agencies seeking contracts for multiple types of equipment. In this case, the FCC determined that all bids for a given product or service type naming specific vendors must include the phrase "or equivalent.”
For a sampling of other interesting reply comments, see:
To search for all filed comments and reply comments in this proceeding, use the search function in the FCC’s Electronic Comment Filing System. Enter “13-184” in the Proceeding Number field, and click the “Search for Comments” button near the bottom of the screen.