Policy & Advocacy

Uncle Sam Wants YOU To Comment on E-Rate

Want more funding for broadband? Now's your chance to let the FCC know what you need and why.

• By Geoffrey H. Fletcher
• 09/03/13

My name is Geoff and I'm a policy geek.

I have just read through the 100 single-spaced pages (that's 339 paragraphs) of the mind-numbing, footnote-laced Notice of Proposed Rulemaking (NPRM) for the E-rate. This proposed "modernization of the E-rate" is the cornerstone of the President's ConnectED program, and it addresses all aspects of the E-rate in an incredibly comprehensive way. You should take note of the NPRM because you can have a say in whether the E-rate has more money put into it, how that money might be distributed, and how the program operates and is administered. The potential for you to have an impact on one of the most vital components of infrastructure for education is enormous.

SETDA believes that for most states and districts: 1) demands for more broadband for learning are growing beyond schools' ability to provide it; 2) broadband access is necessary to meet school reform and improvement goals and improve learning for all students; 3) the E-rate program needs to be simplified and better targeted to school needs; and 4) more funding is required to meet these needs.

When it comes to revising the E-rate program, all the proverbial stars are aligned. As Michael Steffen, director of digital learning at the FCC, told SETDA members on a call, "We are at a special moment in education technology and the possibilities that it creates. That idea has created enthusiasm for really pushing on this issue in the near term ... all the way up to the President of the United States, but also the chair of our oversight committee in the Senate, the secretary of education, the leadership here at the commission — all the commissioners are very engaged in this. That confluence of things doesn't happen that often."

So let's all take advantage of this celestial miracle and let the FCC know what schools want. And the way to do that is through the NPRM, whose purpose is to solicit feedback on the E-rate.

In other words, how the public — which includes you, other educators in your district, your state policymakers, the telecommunications carriers, and all the suppliers of products and services that are affected by the E-rate — responds to the NPRM in general (as well as specific questions) will determine the future of the E-rate. And you do not have to geek out like I did and read the full 100 pages to respond.

After listening between the lines on our member call with Steffen, as well as talking with people around the country, I can tell you the kinds of information that the FCC wants to hear from you.

General Information
Data is key. The FCC would love to hear detailed data about what technology connects each school (copper, fiber, microwave, and so forth), the speeds going up and down, what you are paying for telecommunications services, where you stand with internal connectivity, and if the internal connectivity is wired or wireless. The more granular and the more complete your data, the better. If the FCC can get a good cross-section of districts around the country providing this data, that will go a long way toward establishing a baseline.

Examples of teaching and learning are crucial. Steffen admitted that the folks at the FCC are not digital learning experts, so they need to know what is going on with digital learning in your school or district. This will help them build the case that we are at a critical moment for learning and we have to make the necessary investments in infrastructure to get us there.

If your teachers are using primarily digital content in their classes, if you have X percent of your students taking online or blended learning classes, if your school has flipped instruction and/or your teachers are spending an average of an hour a day searching the Internet for videos and other content to use with kids or their own professional development, tell the FCC about it. If you can link your examples to specific data about the trends in bandwidth usage that you have seen in your district over the last few years, so much the better.

Trends or policy changes help to paint the picture of the larger ecosystem. For example, North Carolina recently passed a bill that requires all instructional materials to be digital by the 2017-2018 school year. Obviously, that has enormous implications for broadband in North Carolina schools. If your district has made a similar move or is going to 1-to-1 or launching any other initiative that will require more broadband, the FCC needs to know that. The more schools that provide this information, the more powerful the case will be to expand funding. (See below.)

Specific Information
The E-rate experts in states and districts will weigh in on the esoteric and painfully detailed questions about such issues as the alteration of specific forms, dark versus lit fiber, and how to account for multiyear contracts to prevent waste, fraud, and abuse. But even if you don't have a working knowledge of the E-rate, you probably have opinions about a number of topics that are raised in the NPRM. Here are a few examples:

Sufficient funding: Paragraph 62 of the NPRM states, "The E-rate program has traditionally been able to fund all priority one requests but the total demand including priority two requests has exceeded the E-rate program's [sic] almost every year since the program's inception." If you feel you need more funding, the FCC needs to hear that with some specificity: What is it that you have not been able to do vis-à-vis infrastructure and digital learning because of a lack of funds? If people at the local level are not advocating for it, the chances that it will happen diminish significantly.

Connectivity within the school: A key set of questions within the NPRM concerns where some of the funded services should be changed in order to increase broadband connectivity inside a building. The E-rate is weighted heavily to getting connectivity to the school door — but if it can't get around the building, it doesn't do teachers and students in classrooms much good. You need to share your classroom connectivity challenges.

Wireless community hotspots: Paragraph 319 of the NPRM asks if the FCC "should permit schools to provide wireless hotspots to surrounding communities using E-rate supported services." In 2010, the FCC allowed E-rate-supported services to be used by the community at large when classes were not in session. Because "the Commission recognized that students' need for broadband access does not end when their schools' doors close for the day," it allowed after-school, on-premises access to students and other members of the public.

If you are doing 1-to-1 or other digital learning programs, you will have a much greater chance of success if students can use connected devices beyond the four walls of the school. In SETDA's groundbreaking white paper, "The Broadband Imperative: Recommendations to Address K-12 Educational Infrastructure Needs," we strongly recommended that "the federal government, states, and districts take responsibility for ensuring easy access to robust broadband connectivity outside of schools including, but not limited to, the home and publicly accessible institutions to libraries and community centers."

Connectivity Goals: A key question from the NPRM is this: How do we measure success? The NPRM specifically cites the targets SETDA set in "The Broadband Imperative": At least 100 Mbps per 1,000 students/staff for external connections in the 2014-2015 school year and at least 1 Gbps per 1,000 students/staff in the 2017-2018 school year. For internal wide-area networks, the targets are at least 1 Gbps per 1,000 students/staff in 2014-2015 and at least 10 Gbps per 1,000 students/staff in 2017-2018. These targets have become a prominent focal point in the ConnectED Initiative and the NPRM, and the NPRM asks if these targets are high enough or too ambitious. They were specified in April 2012, and since then we haven't seen anything that would call for the targets to be diminished in any way.

This is one of those situations where speaking up is not a futile gesture. As Michael Steffen and the FCC commissioners have said, it is critically important that the FCC hear what schools across the country are doing. Your response will make a difference, and your lack of response could say to the FCC that you have sufficient broadband and do not need any additional funding support. Change the world — respond to the NPRM.

NPRM Comment Deadlines and Details There are two deadlines to comment on the NPRM. The first is Sept. 16. That's the date by which you need to tell the FCC what your schools' needs are and what you think of some of the proposed changes to the E-rate. The second is for "reply comments," which means you get a chance to see what others have filed and then you can either comment on their comments or you can file fresh comments. This deadline is Oct. 16. To comment, you can refer to the NPRM, which you can download from the FCC's site. To submit your comments electronically, save them as a PDF file, making sure to include your organization's name and date on each page. It is also best for your comments to refer to a specific paragraph in the NPRM, if possible, to make it easy for the reviewers. The FCC's submission page is at apps.fcc.gov. In the box that says, "Proceeding Number," enter the code 13-184. After you fill out the basic information about your school or district, you can use the "Browse" button at the bottom of the "Document(s)" section to find and upload the PDF you have created.