WASHINGTON, D.C.—Womble Bond Dickinson attorneys Rebecca Jacobs Goldman and Mark Palchick continue to advocate for schools and libraries before the Federal Communications Commission regarding confusing and problematic changes to the FCC’s E-Rate Program.

On July 23, Goldman and Palchick submitted comments to the FCC on behalf of the Ohio Information Technology Centers opposing the FCC’s request to extend approval of Forms 470 and 471 under the Paperwork Reduction Act of 1995. Goldman and Palchick explain that the forms in question have been revised significantly without public review, as is required by the Paperwork Reduction Act.

“Since the beginning of the 2017 funding year, USAC, without public comment and FCC approval, has made substantial changes to the Form 470,” Goldman and Palchick write. “Since the 2015 Forms were never presented for public comment consistent with Office of Management and Budget (OMB) guidance, and since there have been substantial impactful changes since 2016 the currently existing Forms cannot be considered OMB-approved Forms.”

The concerns of the Ohio Information Technology Centers and many other schools and libraries participating in the E-Rate program stem from changes to the E-Rate application process (Forms 470 and 471). Due to these changes, which were made without proper authorization and contrary to previous federal guidance, some schools and libraries may not receive E-Rate support from broadband services that they are eligible to receive.

Goldman and Palchick met with FCC members on March 14 to discuss this issue. In this latest filing, the Womble Bond Dickinson attorneys request that the FCC retake control of the Forms 470 and 471 and conduct a full review (including soliciting public comment) to ensure that the forms are consistent with the FCC’s intentions and meet the needs of E-Rate Program participants.

Click here to read Goldman and Palchick’s full comments to the FCC on behalf of the Ohio Information Technology Centers.

Also see “Rebecca Jacobs Goldman Discusses E-Rate Program Changes, Impact on Schools & Libraries, with Communications Daily”

Rebecca Jacobs Goldman has a diverse communications law practice, guiding clients in media law, Internet, telecom, cable, broadcast and privacy/data protection matters. She counsels communications industry clients in negotiating contracts and complex business transactions, as well as helping them resolve disputes and regulatory challenges. Her clients include cable operators, broadband service providers, video programmers, network operators, spectrum owners, radio broadcasters and telecommunications companies.

Mark Palchick has been an attorney in the communications field since 1975. He is experienced in matters relating to the domestic and international cable industry, international copyright, negotiations of program affiliation agreements, E-rate funding, pole attachment matters, interconnection agreements between private carriers and other FCC regulatory matters. In 2013 he was honored by the Cable Television Industry and inducted into the Cable Pioneers.