Federal Communications Commission
Washington, DC 20554
In the Matter of:
Comprehensive Review of Universal Service
Fund Management, Administration and
WC Docket No. 05-195
Federal-State Joint Board of Universal Service
CC Docket No. 96-45
Schools and Libraries Universal Service
CC Docket No. 02-6
Rural Health Care Support Mechanism
WC Docket No. 02-60
Lifeline and Link-Up
C Docket No. 03-109
Changes to the Board of Directors for the National
Exchange Carrier Association, Inc.
C Docket No. 97-21
REPLY COMMENTS OF THE
ILLINOIS STATE LIBRARY/OFFICE OF THE SECRETARY OF STATE
IN RESPONSE TO NOTICE OF PROPOSED RULEMAKING
FURTHER NOTICE OF PROPOSED RULEMAKING
The Illinois State Library, Office of the Secretary of State, strongly supports the
recommendations of the American Library Association for streamlining the E-rate application
process. The American Library Association comments were filed with the Federal
Communications Commission on October 18, 2005.
The Illinois State Library is the official library for state government officials and employees and
also works with the network of 4,000 public, school, academic and special libraries to expand
and enhance library services statewide. We work with Illinois public libraries, library systems
and other eligible library consortia with the E-rate process. However, many eligible public
libraries have not applied for E-rate funding because of the lengthy, convoluted application
process that involves multiple forms.
Illinois State Library, Dec. 12, 2005, p. 2
According to the FY03 public library annual reports filed with the Illinois State Library, 143
Illinois public libraries (out of 645) did not apply for E-rate discounts because of the complex
process. Finding time to submit an E-rate application (often including Forms 470, 471, 486 and
472 every single year) is extremely difficult in light of other priorities (with public service in the
forefront of these priorities). In some instances, public libraries have applied for E-rate funds
one year and decided it wasn?t worth the hassle in the future. In other cases, they haven?t tried
to apply because of the intimidating application process.
Many rural Illinois public libraries are staffed by three or fewer full-time-equivalent employees.
These staff members do not have time to complete the protracted application process in order
to get universal service discounts on telecommunications services, Internet access and internal
connections. A simpler application process to enable public libraries to benefit from the E-rate
program is needed.
For libraries that apply for E-rate each year, the process is frustrating and protracted. The
Putnam County Public Library District in Hennepin, Illinois provides the following example:
?I have been told that our E-rate application is a very complicated one. Not
only do I deal with the four phone companies, 3 LATA boundaries, numerous
bills, and shared services, but I also deal with shared services in two school
districts. I can never get the reviewers to understand the differences in
eligibility since they refer to the Putnam County Schools and insist that I agree
to accepting that discount. ?? One year I amended the application 13
times, just to get the original version [funded]. I happily endorse a less
complicated E-rate application process???
?Our budget is really tight ? our six library branches eat up the telco $ since
we cross 3 LATA boundaries, utilize 4 service providers, and pay 14 bills.
-July 15, 2005 e-mail from Putnam County Public Library District
director, Randie Dellatori
Illinois State Library, Dec. 12, 2005, p. 3
Eva Kirk, director of the Cherry Valley Public Library District in northern Illinois describes the E-
rate application process as ?convoluted, complicated and frustrating.? She also stated that the
E-rate application process is her least favorite task as library director. This refrain is heard
again and again as public libraries try to address their burgeoning telecommunications costs but
encounter extensive bureaucracy in their quest.
Joseph Sciacca from the Lincoln Trail Libraries System in Champaign, Illinois indicated that one
library that is seriously considering dropping participation in the E-rate program estimated that
the time required to complete the forms and manage the process took more than 200 hours per
Public libraries are often the only access point in a community to broadband Internet service for
the general public. The E-rate program, which is supposed to make services more affordable
for libraries and schools, needs to be comprehensible to the libraries that the program is
intended to serve. The American Library Association?s in-depth comments on how to simplify
the E-rate program while maintaining accountability are rational, valid and strongly supported.
Illinois State Library