Deluge of Comments on E-rate Revamp as Schools Ask for $5 Billion Cap

FCC members encouraged schools and libraries across the country to comment on the agency’s proposed E-rate rules -- and they got their wish. More than 250 comments from school districts, associations and individuals were filed in docket 13-184 on Friday and Monday. Several school districts asked for the program cap to be expanded to $5 billion per year -- more than twice the current cap.

E-rate has become “the primary foundation of funding for digital education in America,” said the Los Angeles Unified School District, which, with more than 640,000 students, is the No. 2 U.S. school district (http://bit.ly/1aOheZe). To ensure continued effectiveness, the E-rate program cap must be permanently increased to at least $5 billion per year, LAUSD said. It’s important to factor in concurrent use in determining “true bandwidth need,” the district said. Bandwidth goals suggested in the NPRM might be “a bit ambitious,” it said, necessitating a “staggering amount of WAN connectivity need if based on the goals as stated by the commission” -- as much as “an unimaginable 64,000 GB” per second at LAUSD.

The Houston Independent School District also asked for a permanent increase to at least $5 billion per year, with an annual adjustment for inflation (http://bit.ly/1aOhtUr). Houston touted leasing fiber connections as the “most cost effective and efficient way” to deliver high-capacity broadband in its district. The New Hampshire Department of Education echoed the $5 billion per annum request, which it said is “close to the average demand level for each of the past two years” (http://bit.ly/1aOhJT6).

The Telecommunications Industry Association asked for “flexibility” for institutions to select the solutions they need “consistent with a general principle of technological neutrality.” TIA said it supports changes to the E-rate rules that incentivize upgrading internal connections. This can be achieved using both wired and wireless, the association said: “Observing the principle of technology neutrality in this regard will help ensure that E-rate recipients choose the most efficient technological solution to meet their internal connection needs.” TIA supported a “meaningful matching requirement” for schools and libraries. “Matching is a time-tested means of motivating program applicants to better define their investment priorities,” it said.

The National Association of State Chief Information Officers (NASCIO) wants a process that gives states discretion to choose whether to collaborate with the FCC in planning and providing priority funding (http://bit.ly/16dnEcU). This could promote efficient use of federal and state funding for broadband services, and improved long-term planning for state investments, NASCIO said. The association supported efforts to promote consortium purchasing. Creating incentives such as “additional support based on potential savings and efficiencies” would help the Universal Service Administrative Co. and recipients better use E-rate funds, it said. Consortia applicants should get top priority, it said.

NASUCA pushed for all broadband providers to contribute to the USF. That’s the best way to fund the E-rate program, the association said (http://bit.ly/15y7XR4). “Increasing the size and scope of the E-rate program will increase the size of the federal Universal Service Fund,” it said. “Under the current rules, the burden on customers of funding this program will increase, in an environment where the strain of supporting the federal fund is already increasing.” NASUCA urged the commission to make the contribution “truly competitive,” by “prohibiting carriers from assessing USF charges on end users.” While the commission is at it, the group said the agency should “take the step that the current Internet protocol ('IP') transition demands” -- redefining broadband “as including” a telecom service. In the “immediate context” of the NPRM, NASUCA encouraged the commission to expand reporting requirements to get pricing, service quality and actual speed data for broadband.