Kellogg & Sovereign Consulting (KSLLC) submitted reply comments to the FCC's Notice of Proposed Rulemaking (NPRM), Protecting Against National Security Threats to the Communications Supply Chain Through the FCC Programs released April 18, 2018 seeking comment on rules to restrict Universal Service Fund payments to any equipment and/or service providers deemed to be posting a national security risk to U.S. communications networks or supply chains.
KSLLC's reply comments included results of the survey the firm conducted in June 2018 to provide input from local service providers along with KSLLC client schools, libraries, and health care providers regarding the questions posed in the NPRM.
32 surveys were returned representing 22 school districts, 1 library system, 4 health care providers, 4 service providers and 1 other entity. Respondents were in support of the Commission's proposal that, "“no Universal Service Funds (USF) should be used to purchase or obtain any equipment or services produced or provided by a company posing a national security threat to the integrity of communications networks or the communications supply chain.” However, the applicants participating in both E-rate and Rural Health care programs believed that the FCC would need to provide clear guidance on which products or companies were banned and that only the service providers should bear the responsibility for ensuring compliance.
Kellogg & Sovereign Consulting Reply Comments (07/02/2018)
American Library Association Comments (06/01/2018)
State E-Rate Coordinators Alliance Comments (05/29/2018)