Report to the Federal Communications Commission (FCC)
by
The E-Rate Implementation Working Group (Working Group)
composed of
U.S. Department of Education
Institute of Museum and Library Services
National Telecommunications and Information Administration
Rural Utilities Service
Education and Library Networks Coalition
July 31, 1997
III. Aggregation/Disaggregations
The Snowe-Rockefeller-Exon-Kerrey Amendment to the Telecommunications Act of 1996 is written in terms of discounts to schools and libraries. Accordingly, in the E-Rate Ruling the FCC adopted a discount-rate matrix for individual schools and libraries (¶520).
In fact, most applications for E-rate support will likely be by higher-level entities (such as school districts, library systems and States) or consortia acting on behalf of multiple service acquirers. With the exception of some private schools and libraries, this will occur because technology procurement does not ordinarily take place at the building level. Rather, for schools it most frequently takes place on an aggregated basis at the district level or, particularly in the case of telecommunications services, at one of the higher governance levels (such as a State) or through an entity (such as an education service agency) formed expressly to provide services to schools. For libraries procurement often takes place through group purchase plans, site licenses and other arrangements by members of regional library consortia or through established State contracts. Thus, the entity applying to procure the supported services may well not have a discount rate of its own.
The situation is further complicated by the fact that, although most inventories of existing technology components would at least originate at an individual school or library, 9 technology planning by schools is more likely to take place on an aggregated basis at one or more of the district, city/county (particularly in the case of large, multi-district metropolitan areas), or State levels. Thus, an education applicant seeking to procure the supported services may well not have an inventory/assessment and/or approved a technology plan of its own and will need to aggregate that information from a number of lower-level entities. By contrast, library technology planning does usually take place at the individual-building level. Even when main or central libraries plan for their branches, the branch managers normally participate in the process. When regional library consortia engage in technology planning for consortia-wide services and applications, such planning does not replace or preclude technology planning by the individual libraries.
The components of a comprehensive information-technology program may also be disaggregated. An individual school might, for example, procure its internal connections at the district level, receive its Internet access from a geographically larger education service agency and be part of a State network for its voice and data feed. Thus, as a result of decentralized procurement, the school's eligible services would be divided among multiple E-rate applicants covering different universes of end users. Indeed, some of those applicants, such as education service agencies, may function more as service providers to schools and libraries than as governing bodies. In that limited capacity they will not conduct the technology planning for any or all of the schools and libraries to which they provide the supported services.
In addition to the potential for existing higher-level entities as applicants, the E-Rate Ruling encourages the formation of consortia of otherwise independent entities to procure telecommunications services jointly in order to achieve lower pre-discount prices (¶¶ 476-77, 561-63, 569). Consortia would not ordinarily have a governance relationship with their members and thus may not be involved in their inventory/assessments and technology plans. Although higher-level entities could either pay the contract costs themselves or arrange for direct payment or reimbursement by the covered schools and/or libraries, consortia members would ordinarily pay their own bills directly.
An effective but minimally burdensome methodology must be established to achieve the desired goals in the context of this widespread aggregation and disaggregation.
9 For example, electrical capacity would probably be inventoried at the building level. Wide-area networks would be inventoried at the level where they are administered. Staff development could be inventoried at the building level, if measured by hours, or at a higher level, if measured by expenditures.
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This page last updated 8/10/97 (pjh).