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Schools weigh in on national broadband plan


School stakeholders have several suggestions for how the e-Rate can be a part of the National Boradband Plan.
School stakeholders have several suggestions for how the e-Rate can be a part of the National Broadband Plan.

To help provide broadband access to more citizens, the Federal Communications Commission should expand the eligible uses of e-Rate discounts to include after-school programs and community centers, many school leaders and education groups say—but only if the $2.25 billion-a-year funding cap also is raised.

The federal stimulus package that Congress passed last year directed the FCC to submit a National Broadband Plan to lawmakers by Feb. 17, but FCC Chairman Julius Genachowski has asked for a one-month extension so the agency can comb through the vast number of public comments it has received over the past year as it has gathered input on how to make universal broadband a reality.

Several dozen of those comments come from education stakeholders, who responded to the FCC’s call for feedback on how it might leverage the e-Rate in its national plan.

The e-Rate provides telecommunications discounts of up to 90 percent for eligible schools and libraries, based on the percentage of students they serve who qualify for free or reduced-price lunches and whether they are considered in an urban or rural area.

Under current program rules, schools applying for discounts cannot use e-Rate funded equipment to deliver internet access to their communities, either by acting as an internet service provider or by opening their facilities to the public after school.

Relaxing these eligibility rules is an approach favored by several education stakeholders, including Albuquerque Public Schools, Chicago Public Schools, the Consortium for School Networking (CoSN), AT&T, and the state of Alaska, among others.

Keith Krueger, CoSN’s chief executive, said his organization supports opening e-Rate supported connectivity in schools for community use during non-school hours, but this change is only a small step in terms of what the FCC must do.

“The far bigger and more significant leap it must pursue is raising the e-Rate’s $2.25 billion annual cap, which has remained unchanged for more than 10 years,” Krueger said. He cautioned that the program’s current funding level soon won’t be capable of supporting the growing demand for connectivity in schools and libraries.

“The program is oversubscribed by approximately $1.75 billion each year and, without a major funding increase soon, the e-Rate may not be able to support the internal connections needs of our nation’s poorest students. That is a tragedy that must be averted. We urge the commission to include substantially raising the e-Rate cap in its final plan,” Krueger said.

The FCC should expand e-Rate benefits to include after-school use of equipment, wrote the Chicago Public Schools in its comments—but the agency also should remove the many barriers to applying, such as redundancies and complexities in the forms that cause many schools to lose out on needed funding.

AT&T also supports after-hours use of equipment by community members. However, this raises several filtering issues that the FCC must think through, the company noted. Under current program rules, schools receiving e-Rate discounts must certify that they are using “technology protection measures” to block access to inappropriate content by minors. If adults use e-Rate funded infrastructure, will these filters still be in place, and who will be responsible for turning them on or off?

Besides raising the program’s funding cap, education stakeholders suggested a variety of ways to ensure that e-Rate discounts extend to schools that need them most.

AT&T suggested that the FCC adopt a “bifurcated” approach to the application process, dividing applications between “facilities” and “recurring charges” as a way to give priority to schools that need basic infrastructure. Alaska suggested capping the maximum discount rate at 70 percent for Priority 2 services (internal network connections), so the discounts on these services would extend to more applicants.

But Alaska also was among several commenters who noted that relying on the e-Rate to help deliver broadband service to more Americans could be problematic for several reasons.

“One can argue that the primary goal and achievement of the e-Rate has been not to accelerate broadband deployment but rather to connect schools and … libraries with some degree of internet connectivity,” the state wrote in its comments to the FCC. The e-Rate “has not traditionally promoted fiber deployment, and it was not too many years ago that some FCC staff thought a T-1 [line] per school would be sufficient.”

Alaska also observed that the e-Rate’s “bottom-up” approach is awkward, because it relies on local school leaders to recognize a need and provide matching funds.

Tom Ryan, chief information officer for Albuquerque Public Schools, wrote that the FCC must implement transparent due-process procedures so e-Rate applicants can address concerns with their applications more quickly.

Albuquerque has some $15 million in e-Rate requests still pending, dating back to the 2005 funding year, Ryan wrote. He added that this “black hole” in e-Rate processing makes the program “unreliable”—and is a barrier to using the e-Rate to improve broadband deployment.

Other aspects of the National Broadband Plan

Overhauling the e-Rate is just one part of the FCC’s broadband approach. Expanding the fund that subsidizes telephone service for poor and rural communities and finding more spectrum for wireless broadband services also will be key pieces of the agency’s plan to bring high-speed internet connections to all Americans.

One proposal would use money from the general Universal Service Fund (USF), of which the e-Rate is a small part, to build broadband networks in underserved communities and pay for high-speed internet connections for those who cannot afford them. The USF, which is supported by a surcharge on consumers’ phone bills, originally was established to subsidize telephone service in rural areas.

Another FCC proposal would explore ways to make more wireless spectrum available for mobile broadband services, including the potential reallocation of some spectrum held by television broadcasters and federal agencies.

The agency also is seeking ways to promote greater use of unlicensed frequencies, such as the “white spaces” between TV stations, and development of new technologies that can make more efficient use of spectrum.

Still another proposal would seek ways to create a new market for television set-top boxes that would be able to work with any video TV service and would integrate online content and applications. The FCC wants to ensure that consumers would be able to buy these new boxes at electronics stores, rather than rent them from a cable operator or other video provider.

Blair Levin, the FCC official in charge of developing the broadband plan, said the plan would focus on encouraging competition and leveraging private-sector investments.

Although the agency will not deliver a final set of recommendations to Congress for several more weeks, at least one public interest group, Public Knowledge, is already complaining that the plan does not do enough to bring new competition to the broadband market, which is dominated by the nation’s big phone and cable companies.

The Obama administration is calling on federal regulators to make more radio spectrum available for wireless internet services so they can compete with broadband plans provided by the major phone and cable companies.

Lawrence Strickling, head of the National Telecommunications and Information Administration (NTIA), said in a letter to the FCC that wireless connections offer the best hope for injecting new competition into the duopoly market for broadband services in the United States.

The NTIA letter draws heavily on a Justice Department analysis of the state of competition in the broadband market. That analysis says it’s premature to know whether next-generation wireless services will be fast and reliable enough to become a viable alternative to offerings from phone and cable companies.

But the Justice Department warns that the high cost of building such wire-based networks means there will likely be limited competition—with at most two choices and, in many places, just one service fast enough to handle applications that require a lot of bandwidth.

Finding more radio spectrum for wireless internet connections is therefore “a primary tool for promoting broadband competition,” Strickling wrote in the NTIA letter.

The NTIA’s recommendations to the FCC include exploring ways to make more efficient use of the airwaves—for instance, by developing new access technologies and encouraging users to share spectrum—and examining whether to reallocate spectrum now in the hands of other commercial and government users.

The FCC is already considering reallocating some frequencies held by television broadcasters, which have mounted an aggressive campaign to hang onto their spectrum. Wireless companies are also eyeing bands used by satellite-communications companies and federal agencies such as the Pentagon.

The industry is asking the government to make an additional 800 megahertz of spectrum available to license to wireless companies for voice and data services over the next six years. That would be a huge expansion from the industry’s current slice of roughly 500 megahertz.

Ben Scott, policy director for the public interest group Free Press, said the Obama administration’s analysis of the broadband sector offers a “sober portrait” of an industry with very limited competition. Free Press, for one, is urging federal policy makers to consider forcing big telecom companies to share their networks with rivals—an approach played down in the NTIA letter.

Still, Strickling said, the administration is committed to finding “the proper balance between regulation and market forces in the internet environment.”

Links:

Comments to the FCC regarding the e-Rate’s role in broadband deployment

Public Knowledge

National Telecommunications and Information Administration

Free Press

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