Focused Comments on E-Rate Modernization

article | April 07, 2014

The New America Foundation's Open Technology Institute and Education Policy Program submitted joint comments to the Federal Communications Commission (FCC) with regard to modernizing the E-Rate program. Read the full comments (PDF) here.

Executive Summary

Last fall, New America's Open Technology Institute and Education Policy Program outlined a series of priorities for E-rate reform based on the idea that the program should be updated to better support libraries and schools in their roles as hubs for connected communities. In these comments, we focus on two areas consistent with our previously established priorities: funding high-speed connectivity both to and within schools and libraries, and improving data collection and transparency.

To address both external and internal connectivity constraints, we recommend that the Commission (1) create a dedicated, one-time Upgrade Fund to help schools and libraries invest in significant infrastructure upgrades that will support gigabit speeds and beyond, and (2) restructure the existing priority system to increase the availability of funding for internal connections equipment that will help connectivity spread within institutional walls. We believe that the $2 billion the Commission recently identified should be dedicated primarily toward addressing immediate infrastructure needs through the Upgrade Fund. Once an Upgrade Fund has been created, the Commission should consider moving certain services from Priority 2 to Priority 1 to better support internal connections, as well as to address related privacy and security issues.

Better data collection practices and greater transparency are also critical to the success of a modernized E-rate. Improvements in this area will produce more useful data that can be analyzed by the Commission, researchers, and the public (including the applicant community) to more clearly understand how E-rate money is being spent and what services and equipment schools and libraries are getting through this support. We therefore urge the Commission to improve its data collection practices and application process, particularly with regard to information about speeds and prices.

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