The document is confusing. In some places it mentions and / or and seems to confuse if property going to local rural governments, in others it mentions a potential commercial refurbisher, and again it mentions educational institutions. It needs to be clearer at all of these points as to the donation going to the rural areas and not to the refurbishers.
How do we determine if they are eligible recipients according to this bill? Who monitors compliance of all of the terms?
This seems to be running in competition with the Computers for Learning, which is mainly operated through GSAXcess. How do we prioritize?
Our concern with refurbishing companies is that this will incur a cost to rural agencies when we believe the intent is to donate the items. Therefore there is a cost where none was intended.
This also takes the State Agencies for Surplus Property (SASPs) and GSA out of the loop.
Another problem is that if the items are refurbished and the intended recipient changes their mind or cannot pay the cost then who is responsible and what happens to the equipment?
What safeguards are being considered to sanitize the equipment before it leaves the agencies? There needs to be standardization to protect the PII of employees and Agency information.
What about the agencies who are under litigation hold? Has discussion been coordinated with the proper staffs or individuals? For example Forest Service is under a general Litigation Hold.
Operating systems and other software licenses are not generally transferrable according to the contract between the vendors and the purchasers. Who determines if this is possible and will it go through OGC or some sort of legal review?
Comment from Darlene Walls
This is comment on Proposed Rule
Guidelines for Transfer of Excess Computers or Other Technical Equipment Pursuant to Section 14220 of 2008 Farm Bill
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Public Submission Posted: 07/19/2011 ID: OPPM-2011-0001-0002
Jul 15,2011 11:59 PM ET