The FCC should continue allowing E-rate money to go to basic...

plans but asked that any expansion of the program be technology-neutral. Cristo Rey Network, which operates 23 high schools throughout the country, said it relies on E-rate funding to keep its networks operational because it can’t afford to have dedicated IT staff. Eliminating the program would add an annual expense, it said. St. John’s Catholic School of Kansas said E-rate money helps it keep its website up. “Students and their parents expect our district to provide them with timely information, and more than ever before, this information is disseminated via the Internet. … As a result of recent reductions in state funding, Kansas school districts are reducing staff to balance our budgets. … Eliminating E-rate funding for web hosting will only further hinder financially struggling districts, including ours, and our overworked staff,” it said. Cristo Rey also argued against funding programs at a per-student rate. Doing that would “cripple” small needy schools, it said. Using a hypothetical example of capping the rate at $15 a student, it said the support it would receive for a typical project would decrease to 2.4 percent from 90 percent. Charter Communications, however, said it supports the per-student cap. With a cap and the elimination of the 2-in-5 rule, which limits an eligible entity’s receipt of discounts on internal connections to twice every five years, schools could predict funding better, it said. Charter also supported eliminating technology plans and procurement processes that overlap with state or local requirements and suggested that funding approvals be for the length of a contract, in place of a requirement of annual requests even when a multiyear contract is in place. The E-rate Service Providers Association, though, said technology plans aren’t necessarily duplicative but can be used with both the state and the commission. Instead, applicants should be able to explain and amend technology plans, it said. In addition, Charter opposed using E-rate to subsidize leases of dark fiber. NCTA also opposed including dark fiber among the allowed services, saying that would go against the principle that “schools may not request funding for more services than are necessary for educational purposes. … Devoting a fiber network for the sole use of a school (or even a school district) would amount to over-investment in infrastructure because it goes beyond meeting the needs of students and teachers.” NCTA also said if the commission decides to provide support to off-campus Internet access, it should make the support available for wireline and wireless access. But if the FCC adds off-campus support, it would no longer be able to require that the Internet be used solely for educational purposes, the association added. Instead, the commission should adjust the support amounts to reflect the mixed uses, NCTA said. The Richmond Public Library in Virginia said almost all public schools take part in the program, but only half of public libraries do. Simplifying the regulations would help increase libraries’ participation, it said. The current discount matrix means few libraries qualify for Priority Two funding, it said. It compared the funding levels of Richmond Public Schools and itself and noted that in some years the library has been denied all Priority Two funding.