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 SEPARATE  STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 Re:  Request  for  Review  of  the  Decision  of  the  Universal  Service  Administrator  by  Bishop  Perry  Middle  School  New  Orleans,  LA,  et  al.;  Schools  and  Libraries  Universal 
 Support  Service,  Order  (File  Nos.  SLD-  487170,  et  al.,  CC  Docket  No.  02-  6) 
 E-  Rate  plays  a  decisive  role  in  providing  schools  and  libraries  with  the  communications  tools  they  need  for  our  children  and  communities  to  compete  and  prosper  in  this  digital  age. 
 Because  access  to  E-  Rate  is  so  important,  we  need  to  be  dead  serious  about  rooting  out  abuses  and  punishing  those  few  bad  actors  who  would  exploit  the  program.  But  that  is  not  the  case  in  the 
 select  appeals  before  the  Commission  today.  Clearly,  these  cases  are  not  about  waste,  fraud  or  abuse.  These  are  about  limited,  and  I  believe,  relatively  minor  ministerial  errors.  When  a  school 
 inadvertently  provides  the  right  information  on  a  slightly  dated  but  virtually  identical  form,  when  technical  problems  prevent  an  applicant  from  interfacing  with  USAC’s  electronic  filing  system 
 and  when  a  third-  party  carrier  prevents  an  application  from  arriving  in  a  timely  manner,  flat-  out  funding  denial  is  a  harsh  consequence.  It  can  be  especially  harsh  when,  as  was  the  case  in  one 
 application  here,  a  minor  clerical  error  led  to  a  denial  of  E-  Rate  funding  for  an  entire  state.  In  fact,  it  becomes  hard  to  square  denial  for  slight  clerical  errors  like  these  with  our  duties  under  the 
 statute  to  further  the  deployment  of  advanced  services.  For  these  reasons,  I  support  today’s  decision. 
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