FCC Seeks Comments on How to Improve Category 2 Funding Program

September 26, 2017

Attached: DA-17-921A1 – PN on C2

The FCC has just released a Public Notice seeking comments from schools, libraries and others about the E-rate Category 2 funding initiative and ways it should be improved.  Specifically, they are seeking input on these issues:

  1. The sufficiency of Category 2 budgets.
  2. Is $150/student (or $2.30 or $5/sq. foot for libraries) over 5 years enough funding?  How have applicants have used their budgets and what percentage of the eligible C2 projects were NOT covered by the C2 budget amounts?
  3. Are there specific situations where the C2 budgets were not enough because of differences in geography, rural status, applicant type, or student population?
  4. For those applicants that have not used any of their C2 budgets, why?  Did those applicants already have adequate internal connections in place before FY 2015 when the C2 initiative began?  Do they intend to seek support for category two services in FY 2018 or FY 2019?
  1. The administration of the budgets from both from a policy perspective and with regard to the application process.
  2. Should the C2 budgets be calculated differently (different than student counts or square footage)?   Is there a simpler way to calculate the C2 budgets?  If so, how?  How would that simpler method be an improvement over the current system?
  3. How could the current C2 application process be changed to ease the burden on applicants?  Specifically, how could EPC be changed?  The Form 471?  The Invoicing Process?  Form 500?

Feel free to include comments on anything Category 2-related that you want the FCC to know or change, not just the topics listed above, such as…

  1. District-wide allocation instead of building allocation?
  2. Easing of equipment transfer rules?
  3. Need for comprehensive C2 budget tracking tool?
  4. Expansion of eligible equipment list?

Comments are due by Monday, October 23.  If you’ve ever thought, “$150/student isn’t nearly enough to cover what we need in a school,” or “I wish the rules gave districts a single C2 budget that covered all buildings and not require a building-by-building allocation,” this is your chance to provide input to the very FCC officials who will be making those changes.  I encourage anyone who has comments – even brief, 1 page comments that only touch on one aspect of C2 – to submit those comments to the FCC by October 23.   I promise you, the FCC staff who write the rules read every comment that is submitted.

Submitting comments is easy to do and here are the steps:

Writing Comments:

  • Put comments on district or library letterhead.
  • Reference “Category 2 Public Notice – WC Docket No. 13-184” at the top of your document.
  • Include your name and contact information.
  • Wherever possible, include examples and data.  If the $150/student wasn’t enough, explain the exact amount you needed for eligible equipment.

Uploading Comments to the FCC:

  • Go to: https://www.fcc.gov/ecfs/filings.  There will be a cover page containing several fields which should be completed as follows:
  • Proceeding:  13-184
  • Name of Filer:  School or Library Name
  • Law Firm:  Leave Blank
  • Attorney/Author Name:  Name of Person Submitting Comments
  • Type of Filing:  COMMENT
  • Then upload your comments, select ‘Continue to Review Screen,’ and then ‘Submit.’

If you have any questions about this Public Notice or would like me to review your comments before they’re submitted, please let me know!

– Julie

Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 – o
717-730-9060 – f


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