The American Library Association (ALA) filed comments to the Federal Communications Commission (FCC) yesterday regarding the Commission’s Notice of Proposed Rulemaking, which proposes a new rule for schools as a result of the Protecting Children in the 21st Century Act and rule revisions for schools and libraries to reflect existing statutory language of the Children’s Internet Protection Act (CIPA). Both the proposed new rule and rule revisions would impact the universal service support mechanism for schools and libraries also known as the E-rate program.
E-rate discounts are critical in meeting the ongoing and ever increasing telecommunications needs of libraries. ALA commented that the additional burden caused by the proposed rule revisions will likely have a negative impact on library participation in the E-rate program through added complexity and potential funding delays.The ALA asks the Commission to carefully review the necessity or benefit of making the proposed changes. ALA points out that the burdens and delays associated with the resulting form and instruction changes, online form programming, and OMB approvals as well as the time and energy that will be required to deal with the confusion associated with these changes, are unnecessary and counter-productive. With the exception of the added language in the Protecting Children in the 21st Century Act, there have been no other statutory changes to CIPA since its enactment in 2000, and ALA is not aware of issues that would cause the need for the revisions being proposed at this time.