Reply Comments on Further Changes to the E-rate Program

Joint Recommendations from the Open Technology Institute and Education Policy Program on E-rate Modernization

article | October 01, 2014

Yesterday, New America’s Open Technology Institute and Education Policy Program submitted joint reply comments with Common Cause to the FCC in the E-rate modernization docket. The executive summary is below, or you can read the full comments(pdf).

In the past year, the Federal Communications Commission (FCC) has made significant strides toward the modernization of the E-rate program, which supports broadband connectivity at schools and libraries across the country. Yet the FCC must now finish the job it started last year by implementing additional changes to ensure that schools and libraries are able to make sufficient investments in scalable, future-proof infrastructure, and that the E-rate program rests on solid financial footing for the future. In these reply comments, we urge the FCC to address critical issues that were not dealt with in the July 2014 E-rate Modernization Order, including support for infrastructure investments to allow schools and libraries to meet growing, long-term connectivity needs. Specifically, we recommend that the FCC support those investments in scalable infrastructure—which in nearly all cases means fiber—by creating an upgrade or buildout fund that supports the one-time upfront costs with rules that are flexible to enable innovative solutions that meet local connectivity needs. We also reiterate our previous recommendations that the FCC should raise the E-rate funding cap to ensure the long-term sustainability and predictability of the program. And finally, we remind the FCC to ensure that future changes to the E-rate program promote equity and parity across types of institutions, including support for non-traditional learners.

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