Kellogg & Sovereign Consulting, LLC (KSLLC) submitted comments in response to the FCC's Notice of Proposed Rulemaking for Category Two Budgets. In their comments, KSLLC provided results of their survey conducted July 26, 2019 - August 14, 2019 with 156 respondents.
KSLLC also supports the comments submitted by the E-Rate Management Professionals Association summarized as follows:
1. Establish permanent extension of the category two budget approach
2. Implement per-district or per-library system category two budget instead of per building calculations
3. Provide separate category two budgets for independent charter schools
4. Allow applicants to utilize category two budgets for non-instructional facilities
5. Establish the category two budget amount in the first year of the five-year budget block. Allow the applicant to adjust category two budget at their option if student enrollment for schools or square footage for libraries changes during the five-year budget block
a. Reset category two budgets for all applicants beginning July 1, 2020.
b. End the category two budget for all applicants at the end of each five-year block
c. Do not roll over category two budget at the end of the five-year block
d. Synchronize all applicants so that everyone is on the same five-year cycle and all budgets reset every five years
6. Do not require repayment of category two E-Rate funding if enrollment (schools) or square footage (libraries) decreases during a five-year budget block
7. For purposes of calculating the category two budget:
a. Allow separate institutions the ability to count students who attend their facilities even if the same student is counted at a separate institution.
b. Do not include virtual students unless they attend classes in-person on a part-time basis
8. Continue to provide E-rate category two funding support for Basic Maintenance of Internal Connections, Managed Internal Broadband Services, and Caching
9. Provide support for advanced firewall features