A Big Week for E-Rate: First Round of Comments Wraps Up

Laptops by mrpetersononline, on Flickr

E-Rate helps provide the infrastructure for in-class technology use. Photo: Laptops by mrpetersononline, on Flickr

Hear that? It’s the sound of educators across the nation making their voices heard—digitally, of course.

Monday was the deadline for submitting our first round of comments to the Federal Communications Commission (FCC) about the E-Rate program, which helps connect America’s schools to the internet. ISTE filed comments as part of the Education and Library Networks Coalition (EdLiNC), drawing on the expertise of our members to outline the nine primary messages we want to convey to the FCC. These are:

1. The E-Rate program is extremely successful.

E-Rate has been pivotal for many schools and libraries across the nation. We believe its core priorities and structure have proven their validity and should remain intact. Operationally, the program functions smoothly.

2. E-Rate’s funding is inadequate to meet current and future demand.

With requests for E-Rate assistance totaling more than double the current annual cap, EdLiNC urges the FCC to increase funding to at least $5 billion annually.

3. We support establishing national bandwidth goals.

Connecting to the internet is no longer enough. Digital age learning requires sufficient bandwidth, and our national goals should reflect this reality. However, we believe any bandwidth goals developed should include entity-specific goals that account for the different needs, geographies and costs faced by each E-Rate applicant.

4. Connectivity metrics are the only appropriate way to measure E-Rate’s success.

EdLiNC does not support evaluating E-Rate based on educational outcome measurements. The FCC’s statement in 2007 still holds true: “There are too many variables involved in educational achievement; internet access is but one of many educational resources for students and teachers.” The program’s success should hinge on the connectivity it provides.

5. There is no need to change the “educational purposes” definition.

To qualify for E-Rate funding, services must fall within the FCC’s definition of “educational purposes” as services that are “integral, immediate and proximate to the education of students or, in the case of libraries, integral, immediate and proximate to the provision of library services to library patrons.” We believe changing this definition (to make services used only by staff or administrators ineligible for E-Rate, for example) would be impractical and burdensome.

6. EdLiNC has deep misgivings about instituting a per-pupil formula.

One proposal on the table is to establish an annual fixed budget for each applicant eligible for E-Rate based on the number of students. We have several concerns with this model, primarily that a formula-driven system will be unlikely to adequately account for the needs of low-income schools and libraries.

7. We support streamlining the application process and making E-Rate more efficient.

However, EdLiNC cautions the FCC to carefully consider the full impact of such changes across all program activities. Some of the changes likely to be proposed could throw a huge monkey wrench into the administrative processes of both the program and its applicants. We do support:

  • Improving online applications
  • Eliminating paperwork
  • Encouraging consortia

8. Districtwide E-Rate applications should be supported but not mandated.

Requiring all schools within a district to apply for E-Rate together—and receive the same discount—could negatively impact schools in districts with wide income disparities as well as private and charter schools.

9. EdLiNC fears the ramifications of eliminating priority distinctions.

E-Rate funding is distributed based on a system that prioritizes certain services to ensure all eligible applicants receive some assistance. We believe the priority system works well and does not need to be revised.

Read the full EdLiNC comments.

Thank you to the several hundred educators who made their voices heard by filing comments on this important issue. If you have not already submitted your comments, there’s still time. Between now and October 16, we have the opportunity to read and reply to others’ comments as part of the ongoing conversation about how to best bring high-speed broadband to U.S. schools.

To read the E-Rate comments that have been filed to date, visit the FCC website and enter proceeding number 13-184 in the search form.

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