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The e-rate: a nice idea, circumvented.

By now most of you who are going to do so have at least attempted to fill out the infamous "Form 4701" and perhaps even its near-twin, "Form 471." There's a two-and-a-half-month window for filing during which all applications are deemed to have been filed simultaneously, and that window "closes" sometime in mid-April, so you may have a few days yet. Well, consider this.

This program has been hyped for a couple of years now, so it is no wonder early February saw a feeding frenzy at the Schools and Libraries Corporation (SLC), the not-for-profit company set up to handle requests for part of that $2 billion slush fund designed to give schools and libraries discounts for telecommunications bills. My first attempt at filling out Form 470 took an entire day of excruciatingly slow response time, JavaScript errors, timeouts, and "server failed to create process" errors, all of which were attributable to a very overtaxed server, running Windows NT, that simply could not handle the load.

It should have come as no surprise. In theory, the forms were supposed to be ready last summer, in 1997. Then the online version was supposed to be ready in the fall, then in December, then in January. They finally appeared in February along with the admonition that you had only a few days to get your application in before they were considered first-come, first-served. Naturally, everyone in the entire country who was even potentially eligible for such discounts had been primed at the keyboard since last Thanksgiving.

At its most basic level, the e-rate is a sound idea. Very simple, very egalitarian. Offer schools and libraries discounts in telecommunications rates. Peg these discounts on a sliding scale based on the poverty rate in each served area. Measure the poverty rate by counting the percentage of students eligible for a federal subsidized lunch program and a measurement of urban or rural districts. Given that this is a federal program, that's fairly simple stuff that addresses major "concerns" that the program be fair.

Tele-Com, Tele-Phone, Tele-What?

That's probably why it couldn't last. Nothing is simple when bureaucrats get involved, nor when there's that much money at stake. Now understand that this e-rate was initially for "tele-communications," but that the underlying theme here was "Internet." Well, a purist would insist that the Internet is "data communications," and that purist would reserve "tele" for "tele-phones." Nevertheless, both were lumped together.

Once this happened, schools across the country began to complain that they couldn't take advantage of the Internet because they didn't have their communications infrastructure in place. So they wanted money to fix that part of their operations up as well. But they weren't content to get their telephone bill slashed in half and apply that windfall to their infrastructure. No, they wanted money from the fund to pay for the infrastructure as well. So we're not talking telephone discounts anymore, we're talking in-house wiring contracts.

This is kind of interesting insofar as school districts' decisions to create a data communications infrastructure are not always based on richness of the district, but on the foresight of their administrators and computer personnel. In our county, with its five school districts, one of the lowest-funded districts with the poorest population (as measured by the federal subsidies for school lunches) was the first to have an advanced data communications infrastructure. Another, Central Kitsap, had become famous a decade earlier for its computing resources. Only that district's oversupply of 8088 Tandy computers slowed them down a year or so before they could dump the junk and build their now-modem network, which is state-of-the-art. When three of these districts were very modern, a fourth still had a only single modem in the business office.

Today, three out of five of the districts are what I would consider "up to par" with modem networks. The other two are struggling, although they have both made advances over the last couple of years. The thing is, there is no real reason that all five could not be at the same place. It was not a matter of funding; it was a matter of priorities. Now, those districts in which the infrastructure was a low priority--for whatever reason, legitimate or otherwise--are insisting that the feds give them priority in establishing an infrastructure. Therefore, the districts that did make a data communications infrastructure a priority are penalized and the e-rate funds are eroded. So, some of this burgeoning complication can be laid at the feet of the constituents.

The Bid-It-Out Mentality

The second major deviation from simplicity was the requirement for bidding out services. This is shocking, really. Here we are with 105 phone lines that cost about $70,000 a year to operate. They are POTS phone lines: Plain Old Telephone Service. In our state these rates are tariffed. Anyone who offers telephone service has to offer it at the same rate. Yet we're required to fill out a Form 470 and post it at the SLC Web site so service providers can take a look. Now, it's true that it is not quite as bad as all that, in that SLC has recognized there is such a thing as POTS; yet the same "bid-it-out" mentality can be seen in the requirement for other data communications services that are themselves tariffed services, including our Frame Relay Network.

Frame Relay is tariffed. Would anyone in his right mind actually bid out a perfectly working system? No more than you would jump out of a perfectly working airplane. The whole idea verges on absurdity. Perhaps some school district somewhere might gain an advantage in bidding out internal wiring of classrooms nationally, but I suspect their local procurement processes would be far superior.

The Technology Plan

The third little bureaucratic bonus to the e-rate is the requirement of a technology plan. One video I saw sported an elderly fellow condescendingly telling everyone that you really did need a technology plan because otherwise you didn't know what you were doing. Now, who is going to judge your technology plan? A state agency of some sort. In our state that would be the superintendent of public instruction for school districts, or the state library for public libraries.

In our state it used to be, a long time ago, that the state library was the Mother of all Libraries. Whenever you wanted to do something, you'd ask Mother how to do it. Mother had a lot of experts on staff. I remember one fellow who knew all there was to know about cassette tapes, all about the kind of roller bearings they had and how long they would last. So if you needed to know advanced information about cassette tapes, you'd call up Mother and Mother would tell you. Cassette tapes were what amounted to technology back then.

But a funny thing happened, and that is that all these little libraries grew up. Many developed quite advanced technology infrastructures. They didn't get the information from the state; they developed it on their own. And the state library became more of a partner with other libraries than the older Mother Superior approach. Rather than the small library going to the big library to see how it was done, trips reversed their direction. In any case, I think the partnership is much healthier now than it was.

The state library is, of course, a natural entity to collect these required technology plans. But how can its people judge them? By and large they can't judge them for technological content; they can only judge them by criteria promulgated by, you guessed it, SLC. And if SLC says you have to have a tech plan that projects 3 years into the future, then by Jimminy, you better have it!

I object to technology plans per se on the grounds that if you are sufficiently advanced technologically, you ought not to have them. That's because technology ought to be integrated into your planning process anyway, rather than be a separate entity. If you should be encouraged to do anything, it would be to integrate technology, not separate it out. In our state, the state library, in programs where it is more in control of what to suggest, asks for "evidence of technology planning." That's what we ought to be seeing from the SLC.

In our 40-page "technology summary," I pointed out a generation's worth of technological achievements, described our infrastructure, and referred to a dozen documents that addressed the library's future. Most of these documents had the "Year 2000" as part of their title. I suppose that it was predictable that the summary would come back with the comment that we didn't have a 3-year future-projected timeline in the summary itself.

The fact is, we don't need one. That's because we are, thankfully, already there. Over the next few years, we will replace parts that are already installed. This isn't really the state's fault. They are simply judging plans based on what the SLC guidelines are saying, and those have changed over time. The state can't possibly judge us for what we are doing technically. The guy in charge of cassette tapes is long gone. So, they are left with seeing whether we can follow directions and fill out forms properly.

The thing is, this is a marginal proposition. For basic POTS service you don't need a technology plan. For us, that amounts to something like $70,000 per year and is the majority of the base where we might enjoy a discount. The only other areas are our Frame Relay service, now 5 years old, and, potentially, Internet access, although that's kind of questionable at the moment. The only sure thing if we do it right is Frame Relay, where we pay about $18,000 per year. If we get a 40 percent discount, that's something like $7,000 per year saved.

The Cost/Benefit Analysis

So how much is it costing us in staff time to put this together? We have the cost of a technology plan to make the bureaucrats at SLC happy, the cost of spending a few days at the SLC Web site filling out forms, and the cost of the internal machinations necessary to see this project through to completion. My guess is that if we added all this stuff up, we would be perilously close to $7,000 in staff costs to comply with all requirements. This includes whatever internal mechanism you use to measure what it costs to keep you away from other vital projects that need to be put aside in favor of the deadlines imposed on the e-rate.

This means that the incremental costs of what it takes to do anything more than apply for basic POTS discounts simply may not be worth it to your system. The evolution of the e-rate from a simple concept to a bloated, year-late blizzard of paper, forms, and certifications reminds me of that old oxymoronic sentence: "I'm from the government and I'm here to help."

Thanks anyway.

Michael Schuyler is the systems librarian for the Kitsap Regional Library System in Bremerton, Washington. His e-mail address is
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Author:Schuyler, Michael
Publication:Computers in Libraries
Article Type:Column
Date:Apr 1, 1998
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