Marijke Visser

In these comments to the Federal Communications Commission, the American Library Association affirms support for including Wi-Fi hotspots and services in the E-rate program, ALA urges the FCC to:

The American Library Association released its new report "Keeping Communities Connected: Library Broadband Services During the COVID-19 Pandemic." Key takeaways include:

A coalition of education advocates petitioned the Federal Communications Commission to close the remote learning gap for the estimated 15 to 16 million students who lack home internet access. If granted, the petition would allow schools and libraries to connect these disconnected learners using funding from the E-rate program.

While we anticipated the Federal Communications Commission would take a look at its Universal Service Fund (USF) programs once Chairman Ajit Pai was in place, we did not anticipate the speed at which moves to review and evaluate previous actions would occur. After the Commission retracted the “E-rate Modernization Report,” our E-rate ears have been itching with concern that our bread and butter USF program would attract undue attention. We did not have long to wait.

Last week, FCC Commissioner Michael O’Rielly sent a letter to the Universal Service Administrative Company (USAC) seeking detailed information on libraries and schools that applied in 2016 for E-rate funding for dark fiber and self-provisioned fiber. Our main concern is that the tenor of the Commissioner’s inquiries calls into question the need for these fiber applications. The Commission’s reforms to allow self-construction costs for dark fiber and applicant owned fiber were correct in 2014 and remain so. In addition, applicants will evaluate and select the best, most cost effective fiber option for their library or school. If the last few weeks are any indication of activity at the FCC, we’re in for a busy spring.

The American Library Association submitted brief comments to the Federal Communications Commission for its annual Broadband Progress Report. The Commission released a Notice of Inquiry (NOI), which it is required to do through Section 706 of the Telecommunications Act of 1996, to report whether “advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion.” The NOI asks questions about criteria and benchmarks by which to measure connectivity in the classroom and refers back to the recent E-rate modernization proceeding. Because E-rate is the Schools and Libraries Program, our comments ask the Commission to address the oversight in not including questions regarding connectivity in libraries.

We asked the Commission to include reference to the benchmark they adopted for libraries which is a goal of 100 Mbps for those libraries serving communities of 50,000 or less and a 1 gigabit goal for those serving communities with a population of over 50,000. In addition to these broad goals we reminded the Commission that using a more granular benchmark based on the number of internet connected devices a library has can be very useful. This number would also account for patrons who bring their own devices and use those with the library’s Wi-Fi. While libraries likely need to move toward the 100 Mbps and 1 gigabit goals, a meaningful measure based on connected devices will be useful in helping a library understand and plan for the “right” amount broadband to meet the needs of their community.

The Federal Communications Commission’s (FCC) E-rate modernization proceeding is one of the most consequential public policy discussions in a decade. The success of this proceeding is essential to enable libraries and schools to meet the needs of America’s communities in the digital age. The gigabit broadband vision outlined by the President -- and which is a fundamental aspect of the Commission’s E-rate reforms -- is critical to support the indispensable role libraries play in our communities.

The American Library Association (ALA) recognizes the difficult task in front of the Commission to move the E-rate program from basic connections to high-capacity broadband and is supportive of its effort to do so. ALA and libraries also have fully engaged in this challenge with our school colleagues and hundreds of other stakeholders to answer an urgent call to meet 21st century learning demands. And there is broad consensus that we cannot meet these demands with funding that has hardly budged in 18 years. We must establish a sustainable foundation for the future.