USTelecom submits these comments in response to the Federal Register notice seeking comment on various petitions for reconsideration filed in response to the Federal Communications Commission (Commission) order that updated rules for the schools and libraries universal service support program (E-Rate). The Commission’s order made various reforms to the E-Rate program, including enhancements to funding for internal connections and streamlining of the application process.
However, USTelecom agrees with certain Petitioners that some of the Commission’s decisions should be reconsidered. In particular, the Commission should reconsider those aspects of the order relating to self-provisioning by schools and libraries and the need for incorporation of additional safeguards to ensure efficient spending. The Commission should also initiate a proceeding to determine the new methodology for calculating the reasonable comparability benchmark for high-cost recipients.