Groups Disagree in ‘Focused’ Comments on E-rate Updates

The commission should prioritize funding for broadband deployment and internal connections that support broadband connectivity, AT&T said (http://bit.ly/1ko6NAq). It should include all aspects of the E-rate process in its streamlining review, and further streamline the funding disbursement process, AT&T said. For instance, schools and libraries should be able to use E-rate funds to pay their service providers directly, it said. The commission should also phase out funding for voice services, and fund demonstration projects if applications “demonstrate a need,” and support off-campus “mobile learning,” AT&T said. The agency should also address “the eligibility of off-campus mobile broadband connectivity,” said the telco.

It would be “reasonable” for the commission to annually allocate a set amount of E-rate funds for local area networks and Wi-Fi networks within schools and libraries, Verizon said (http://bit.ly/1jrqkMQ). The FCC could use part of the available $2 billion in additional support identified by staff to “front-load” support in 2015 and 2016, Verizon said. The agency should be “cautious” about providing incentives for the deployment of high-capacity broadband connections to schools and libraries, it said. “The existing priority one system is working well,” with high-capacity services “already affordable for most schools,” it said. Verizon “continues to have concerns” that phasing out support for voice services could “create implementation issues": It would be tricky to determine what portion of the price for a bundled voice and broadband service should be attributed to “voice.”

The commission should not reduce or eliminate E-rate support for voice, the Independent Telephone and Telecommunications Alliance said (http://bit.ly/1hzZj5C). “Countless schools and libraries, particularly in rural areas, continue to rely on plain old telephone service” to communicate with students and parents, the association of mid-sized telecom carriers said. “Forcing schools and libraries to adopt VoIP service in order to continue receiving E-rate funding would require unnecessary additional expenditures that many schools and libraries cannot afford.” Any reduction in support for traditional voice services should come with an “adequate transition period, such as five years, to phase it out,” ITTA said. Comptel focused on how to ensure the use of consortia “does not unfairly disadvantage recipients or smaller providers,” like the association’s members (http://bit.ly/1jrrjg9). “Collaborative purchasing or other forms of bulk buying may drive down costs in many circumstances,” Comptel said. “The Commission should not, however, mandate collaborative purchasing through consortia or only cover certain costs if Applicants participate in consortia."

The Urban Libraries Council called for a special “L-Rate” fund for model library networks (http://bit.ly/1ep7Ic4). The FCC should “define several model library network architectures” it would fund through a program “dedicated to libraries,” ULC said. Adoption of model network architectures would allow E-rate administrator Universal Service Administrative Co. to grant “very rapid and streamlined approvals of conforming equipment purchases,” ULC said. Of the 120,000 libraries in the U.S., more than 100,000 are inside schools, said former FCC Chairman Reed Hundt, representing the ULC. As “completely distinct” entities from school systems, “the cost of connecting them ought to be calculated differently, and the administration ought to be different, and they ought to have different contracts,” Hundt told us. “They're no more similar to classrooms than rural healthcare is” -- another universal service group that has its own fund administration process, he said. “It is the lack of an L-rate that is the primary reason for the really dismal state of connectivity at libraries."

Wireless Role

PCIA-the Wireless Infrastructure Association said the E-rate program should allow for flexibility and not lock schools and libraries into a narrow list of services and equipment eligible for funding. “Be it for external connections, or in this case of this Public Notice, internal connections, locking schools and libraries into specific technologies will frustrate the Commission’s purposes by driving up costs and slowing the deployment of advanced broadband services,” it said. To ensure robust connections, carriers need to be able to build out their networks and siting concerns also must be addressed, PCIA said (http://bit.ly/1g3aibI).

Microsoft encouraged the FCC to allow for flexibility, including the use of wireless connections. The price of bandwidth varies widely, Microsoft noted (http://bit.ly/1jZOoao). Increasing the bandwidth of a school in Cascade, Mont., by 100 MB would cost $3,000 a month, compared with $200 a month in Seattle.

Sprint said “it is critical that the Commission adhere to the long-standing principle of competitive and technological neutrality in its efforts to modernize the E-rate program.” Fiber is not always the answer, Sprint said. “For some rural community schools and libraries, wireless point-to-point connectivity will be more cost-effective and can be deployed more quickly and efficiently, and with far less disruption, than a wired solution,” the carrier said (http://bit.ly/1hdgUFc). E-rate should support managed Wi-Fi, integrating hardware, software, network transport and professional integration, it said. Managed Wi-Fi might be used for schools and libraries lacking in-house information technology staff, said the carrier.

SouthernLINC Wireless said the FCC should not eliminate support for wireless voice services. “Schools and libraries unquestionably are in the best position to know their needs,” the carrier said (http://bit.ly/1hpeVib). SouthernLINC urged the FCC to “create a category of mobile services for which E-rate support is available on a priority basis that includes traditional voice services.”

State Concerns

Modernizing E-rate should be guided by a few, clear performance goals and metrics, including increasing broadband capacity from 100 Mbps per 1,000 students and teachers to 1 Gbps per 1,000, said the State Educational Technology Directors Association (http://bit.ly/1gHMCWj) in FCC docket 13-184. Among a number of SETDA’s other recommendations was prioritizing the availability of a robust baseline for broadband in and throughout all U.S. schools, including rural schools. The Ohio E-Rate Consortium (OERC) said wireless access service from the cloud to the classroom is fully fundable as an Priority One E-rate service. The FCC appears to be struggling with balancing the need for wireless access in classrooms with the ability of schools to fund the service under the E-rate program, failing to recognize the availability of the Priority One funding, OERC said (http://bit.ly/1lNENWU) Monday. The consortium is made up of semi-public entities that provide phone and broadband service to public and non-public K-12 schools.

Streamlining the multiyear contracting process would incentivize E-rate use, in many instances lowering costs for applicants, said OERC. It also encouraged continued E-rate funding for VoIP services. The Kentucky Department for Libraries & Archives said (http://bit.ly/1ee0XiJ) KDLA’s libraries would benefit from increased availability of Priority 2 funding. The average Kentucky public library building was built in 2000, and a third of the state’s buildings were constructed in 1999 or earlier, requiring significant investments in internal connections, said the department. KDLA opposed preferential treatment for consortia purchasing agreements, because its libraries are able to make purchases at lower prices through state master agreements. KDLA also opposed reducing support for voice services, saying VoIP isn’t considered a viable alternative to landlines, in part because Internet access can be unreliable in some parts of Kentucky.