The New America Foundation's Open Technology Institute and Education Policy Program submitted joint reply comments to the Federal Communications Commission (FCC) with regard to modernizing the E-Rate program. Read the full comments (pdf) here.
Executive Summary
The New America Foundation’s Open Technology Institute and Education Policy Program offer the following recommendations in support of the Federal Communications Commission’s goal to better address the broadband capacity needs of schools and libraries. These reply comments reiterate the broad principles outlined in our initial comments, respond to ideas and concerns expressed by other commenters, and distill and tighten recommendations for achieving the Commission’s outcomes for the E-rate program. The proposed reforms are designed to improve broadband infrastructure to increase capacity for schools and libraries and provide more opportunities for innovation and flexibility in the use of that capacity at the institutional level, while enhancing accountability on the part of broadband providers.
The E-rate Fund should encourage significantly more community investment in fiber infrastructure. We express support for the proposal offered by EducationSuperHighway to create an Upgrade Fund to spur investment in fiber infrastructure. We also recommend that the Commission implement minimum service standards to ensure that the Upgrade Fund is utilized and to hold providers accountable for investing in upgrades on their networks to provide better connectivity to schools and libraries.
To foster digital inclusion, we recommend that the E-rate Fund preserve schools and libraries’ ability to facilitate greater community connectivity where feasible. Schools’ and libraries’ ability to maintain open Wi-Fi hotspots, both during and outside of business hours, should be recognized in any reforms. Further, the Commission should allow greater flexibility for schools and libraries to better facilitate the deployment of innovative network solutions that can increase community connectivity in the future.
The Commission should implement smart data collection practices to improve the efficacy of the Fund and promote greater transparency. We reiterate the belief that better E-rate data will benefit schools and libraries, researchers, policymakers, and the public, and that the Commission should collect and release Form 471 data in a machine-readable format; modify the forms to collect more streamlined and useful information from schools and libraries; and increase the transparency of the program by collecting and releasing more granular pricing data. Releasing this data will not discourage competition or unnecessarily duplicate state-level public disclosure processes, and a more streamlined approach to E-rate reporting requirements will ensure that reforms to those requirements do not increase the burden on schools and libraries.
Finally, we emphasize that E-rate funds should be distributed in a way that promotes fair and equitable service and speed for students and patrons of all schools and libraries. The Commission should not distribute support from the E-rate Fund through fixed allocations such as in a per-pupil or per-patron funding scheme. Moreover, given its primary objective of expanding broadband connectivity, E-rate funding should not be distributed based upon educational impact measures. Finally, the E-rate Fund should seek to improve support for non-traditional education—especially in the case of early education—equitably across all states where possible.
