As part of its efforts to develop a National Broadband Plan, the Federal Communications Commission (FCC) is seeking comments about how the e-Rate program can be improved to meet the broadband needs of schools and libraries — and how it might play a role in delivering or stimulating the adoption of broadband service within communities.

In its Public Notice, the FCC asks educators what they believe are the barriers to increasing broadband deployment and usage in their schools. The agency also asks e-Rate applicants what factors they consider when determining their broadband needs.

In figuring how the e-Rate can be used to help deliver broadband service to more people, the FCC asks stakeholders whether they think the rule requiring that discounts apply only to services used for "educational purposes" should be changed, to allow for the use of school broadband facilities by the community at large. If that were to happen, "what practical or operational impact would such a change have?" the agency asks.

The FCC also wants to know whether it should seek legislative changes that would open the program to more eligible applicants, such as community colleges, pre-kindergarten or Head Start programs, or even colleges and universities. And it wants to know whether the fact that computers and training are ineligible for e-Rate support hinders the adoption of broadband in schools.

"If the e-Rate program were to fund computers and training, what would the projected demand be?" the agency asks. "From a policy perspective, what are the potential negative consequences if such a change were adopted?"

In addition, the FCC seeks comment on whether to allow funding for wide-area networks (WANs) that are built or purchased "to provide telecommunications services" within a community. "Would modifications to this rule regarding WANs … result in greater broadband deployment?" it asks.

What’s more, the agency wants to know how changes to the disbursement of e-Rate funds or the discount calculation process might spur greater broadband deployment.

For example, should the FCC create a new priority level for schools and libraries that don’t yet have broadband service or that have extremely slow internet speeds, allowing those entities to receive funding before other eligible applicants–in essence, letting them "catch up?"

Or, the FCC could change the way discounts are calculated to factor in not just poverty and whether a school is urban or rural, but also whether it lacks broadband services. In addition, the agency could change its priority structure to give preference to those schools that have not received funding for internal connections in several years.

Finally, the FCC asks what should be done about the $2.25 billion annual e-Rate funding cap.

Rather than simply requesting that the cap be raised, the agency would like applicants to give their best estimate for how much they think is needed "to achieve specific levels of broadband connectivity." And should the FCC lower the discount levels for basic telecommunications, or otherwise modify the existing discount levels, to increase the amount of funding available for broadband deployment?

The FCC’s Public Notice comes a few months after the agency held a hearing to discuss the implications of its national broadband plan for education. During that Aug. 20 hearing, panelists testified that the e-Rate can play a significant role in this plan–but only if commissioners raise the funding cap to at least $4 billion. (See "Panelists to FCC: Raise e-Rate funding cap.")

Comments in response to National Broadband Plan (NBP) Public Notice No. 15 are due by Nov. 20, and reply comments are due Dec. 11.

Link:

NBP Public Notice No. 15 (PDF)