ALAWON v6n87 (October 10, 1997) URL = http://hegel.lib.ncsu.edu/stacks/serials/alawon/alawon-v6n87 ================================================================= ALAWON Volume 6, Number 87 ISSN 1069-7799 October 10, 1997 American Library Association Washington Office Newsline In this issue: (124 lines) ACTION ALERT: SERIOUS PROBLEMS DEALING WITH AGGREGATION RAISED AT FCC MEETING ON PROPOSED FORMS; ACTION URGENTLY NEEDED BY NOON ON TUESDAY, OCTOBER 14 _________________________________________________________________ ACTION ALERT: SERIOUS PROBLEMS DEALING WITH AGGREGATION RAISED AT FCC MEETING ON PROPOSED FORMS; ACTION URGENTLY NEEDED BY NOON ON TUESDAY, OCTOBER 14 During a Friday, October 10 meeting at the FCC on the proposed application forms for the universal service program (see http://www.fcc.gov/formpage.html#470 and http://www.fcc.gov/formpage.html#471), changes in the forms were proposed that would dramatically increases the level of burden faced by libraries and schools in filling out the application forms. The proposed forms outline a system wherein libraries and schools would be required to allocate all services down to the level of individual libraries and schools and calculate discounts for those services, irrespective of how library and school administrative entities are already allocating costs. This burden has the potential to limit participation among the poorest and most rural schools and libraries. ALA firmly believes that the application process should not be this complex. ACTION NEEDED: We urge ALL public and school library supporters to contact the FCC immediately and inform them how burdensome these calculations are. These burdens actively discourage aggregation (which is perhaps the single most effective way of lowering costs for libraries and schools), and, in fact, discourage libraries and schools from applying for the discount program. The FCC will be accepting comments on the forms until noon on Tuesday, October 14. Comments should be sent via email to Mark Nadel and Irene Flannery in the Universal Service Branch at the FCC. They can also be faxed to 202-418-7361. ALA strongly requests that comments be copied to Aleck Johnson at ALA's Office for Information Technology Policy (fax -202-628-8424) so that we can continue to press the FCC and other parties on this issue based on your input. We also encourage library supporters to speak with their local school districts and urge them to comment on this issue. BACKGROUND: On Friday, October 10, a meeting was held at the Federal Communications Commission to discuss the draft forms that the FCC released on Thursday (see http://www.fcc.gov/formpage.html#470 and http://www.fcc.gov/formpage.html#471). Forms 470 and 471 were reviewed and commented on. All of the comments sent to the ALA Universal Service listserv on October 9 were included. During the meeting changes were made that will dramatically increase the level of burden faced by libraries and schools in filling out the application forms. Commission staffers verified that these changes were receiving serious consideration. The most troubling changes were made on Form 471, where applicants list the services for which they wish to receive universal service support, several key wording changes were made. Specifically, items #7 and #8, which had been labeled "Services ordered by more than one entity (e.g. file server used by entire school district)(not location specific)" and "Services ordered by individual school or library (location specific)" were altered to read "Services PROVIDED TO more than one entity" and "Services PROVIDED TO individual school or library". The net effect of this change is to force applicants to apply individual library's and school's discounts to the vast majority of services, rather than allowing library systems and school districts to calculate an "area wide" discount rate. For EVERY service ordered for EVERY location, the applicant will be required to apply an individualized discount rate. Applicants also will be required to provide extensive information on the contract for each branch -- even if the same contract serves multiple branches. For instance, for a library system with three branches ordering a leased line and Internet services, the library system would be required to enter 6 sets of information (one for Internet and one for the leased line for each location). The larger the system, the greater the burden; a consortium with 15 libraries would be required to make at least 30 separate entries. Each entry would require a calculation of the discount percentage, a listing of the number of patrons served, the name of the service provider, individual information on the contract signed (including the contract number, award date, and expiration date), and cost forecasts for one time, monthly, and/or annual costs. The more services a consortium, library system, or district wishes to purchase, the greater the burden. Needless to say, this functions as a strong disincentive to aggregation. Furthermore, this move sets the stage for requiring all consortia, library systems and school districts to "allocate out" all of their shared services (such as Internet connections) according to an as-yet unformulated cost allocation scheme. Such a scheme would undoubtedly undermine currently existing cost allocation mechanisms for library consortia which, in many cases, effectively subsidize poor and rural libraries by treating all line costs as shared. _________________________________________________________________ ALAWON is a free, irregular publication of the American Library Association Washington Office. To subscribe, send the message: subscribe ala-wo [your_firstname] [your_lastname] to listproc @ala.org. To unsubscribe, send the message: unsubscribe ala-wo to listproc@ala.org. ALAWON archives at http://www.ala.org/ washoff/alawon. Visit our Web site at http://www.alawash.org. ALA Washington Office 202.628.8410 (V) 1301 Pennsylvania Ave., NW, #403 202.628.8419 (F) Washington, DC 20004-1701 800.941.8478 (V) Lynne E. Bradley, Editor Deirdre Herman, Managing Editor Contributors: Carol C. Henderson Aleck Johnson Andrew Magpantay All materials subject to copyright by the American Library Association may be reprinted or redistributed for noncommercial purposes with appropriate credits. =================================================================