ALAWON v11n0026 (April 3, 2002) URL = http://www.infomotions.com/serials/alawon/alawon-v11n0026.txt ALAWON: American Library Association Washington Office Newsline Volume 11, Number 26 April 3, 2002 In This Issue: ALA TO FILE COMMENTS WITH THE FCC ON THE E-RATE; DEADLINE APPROACHES Friday, April 5, 2002 is the deadline for submitting comments to the Federal Communications Commission (FCC) responding to their Notice of Proposed Rulemaking (NPRM) on the Schools and Libraries Universal Service Support Mechanism, or E-rate (CC Docket 02-6). Reply comments will be due May 6, 2002. Anyone wishing to file comments or a letter of support for ALA's comments may use the FCC's electronic filing system by visiting www.fcc.gov/e-file/ecfs.html and following the online directions. Please note: the electronic filing system will be unavailable starting at 9:00 pm on April 5 due to maintenance requirements. Alternatively, paper comments may be addressed to the Commission's Secretary: Magalie Roman Salas, Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Suite TW-A325, Washington, DC 20554. The FCC requests an original and four copies of any paper filings. ALA urges all program participants or potential participants to support the association's comments, which are summarized below, or to file comments expressing their own particular concerns with the program. ALA's comments will also include support for the following: + Allowing libraries alternative methods of establishing their discount levels. + Including new services in the definition of eligible services. + Increasing the funding cap. + Revising the categories of eligible services. + Revising the priority schedule for discount eligibility. + Eliminating disincentives for consortia . + Recognizing the role of the State Coordinators in reducing the administrative costs of the SLD and increasing the efficiency of the program as a whole. Also, the FCC asks several specific questions in their NPRM which ALA will address as follows: Any audit rule should be carefully drafted to ensure that it does not actually harm participants. An audit rule is not really necessary, since all libraries are audited regularly, and in any event requiring the audited entities to bear the expense of an audit is entirely unreasonable. ALA supports restriction on transferability of equipment. A two- or three-year moratorium on transferring equipment or a bar on funding applicants for the same equipment in the same location for two successive years might address this concern. A bar or suspension for willful or repeated noncompliance would also increase accountability. Such a restriction should apply to providers as well as to applicants, and should be carefully crafted to apply only in the case of repeated and willful failure to comply with material provisions of the FCC's rules. Minor or inadvertent errors should not be used as an excuse to cut off participation. ALA also supports the proposed enforcement measures for remittal of payments by providers. Any fines or forfeitures imposed on providers under such a rule should be used to fund audits or other enforcement measures. ALA strongly supports the Americans with Disabilities Act, but does not believe that additional enforcement measures outside the scope of ADA itself rules adopted under the Act's authority are necessary or appropriate. ALA supports the proposal to extend the time period for filing appeals and setting the appeal deadline based on the date of postmarking. Applicants should have the choice of paying the full cost of the service to the provider and being reimbursed by the Administrator, or paying only the discount price. Providers should not be allowed to dictate this decision. Many ALAWON readers provided valuable input that helped to shape the ALA's comments. For this feedback and for the leadership of the ALA E-rate Taskforce we are grateful. Should you have any questions, please contact Claudette Tennant, Internet Policy Specialist, Office for Information Technology Policy at ctennant@alawash.org or 1-800-941-8478. If you need further details about ALA's comments in order to facilitate your filing, please contact Carol Wheeler at cwheeler@alawash.org or. ALA will continue to participate in this process by reviewing the comments filled and crafting appropriate reply comments. These reply comments are due May 6, 2002. We will be providing additional information throughout the remainder of this process and will highlight additional opportunities for participation from the library field. ****** ALAWON (ISSN 1069-7799) is a free, irregular publication of the American Library Association Washington Office. All materials subject to copyright by the American Library Association may be reprinted or redistributed for noncommercial purposes with appropriate credits. To subscribe to ALAWON, send the message: subscribe ala-wo [your_firstname] [your_lastname] to listproc@ala.org or go to http://www.ala.org/washoff/alawon. To unsubscribe to ALAWON, send the message: unsubscribe ala-wo to listproc@ala.org. ALAWON archives at http://www.ala.org/washoff/alawon. ALA Washington Office, 1301 Pennsylvania Ave., N.W., Suite 403, Washington, D.C. 20004-1701; phone: 202.628.8410 or 800.941.8478 toll-free; fax: 202.628.8419; e-mail: alawash@alawash.org; Web site: http://www.ala.org/washoff. Executive Director: Emily Sheketoff. Office of Government Relations: Lynne Bradley, Director; Camille Bowman, Mary Costabile, Don Essex, and Miriam Nisbet. Office for Information Technology Policy: Rick Weingarten, Director; Jennifer Hendrix, Carrie Russell, Claudette Tennant. ALAWON Editor: Bernadette Murphy.