The National School Boards Association (NSBA) Executive Director Thomas J. Gentzel issued the following comments on the Federal Communications Commission (FCC) Public Notice on the Wireline Competition Bureau Seeks Focused Comment on E-rate Modernization to provide key recommendations to modernize the E-rate program and increase the quality and speed of Internet connectivity in our nation’s schools and libraries. NSBA applauds the FCC’s proactive efforts to ensure efficient operation and integrity of E-rate; increase the quality and speed of connectivity in our nation’s schools; and address the technology gaps that remain.
Gentzel’s full comment are available and an excerpt of the recommendations are below:
“For nearly twenty years, NSBA has supported the goals of the E-rate program to increase Internet connectivity and provide digital learning opportunities to underserved students, schools and libraries. NSBA is steadfast in its support for the ConnectED initiative and applauds the Federal Communications Commission (FCC) focus on broadband deployment in education, so that students are prepared to be competitive and successful in the global marketplace.
“To successfully usher in a new future for E-rate, NSBA urges the FCC to ground modernization of E-Rate in the individual circumstances of the nation’s 14,000 school districts and 98,000 public schools. Put eloquently by the Pennsylvania School Boards Association: School entities across the nation are diverse in their composition and their needs. Local decision-making and local flexibility should be maximized in implementation of the E-rate program.
“Further, NSBA’s recommendations are predicated on the need for additional resources in the E-rate program. Simply repurposing or rearranging priorities for the $2.5 billion E-rate program is not sufficient to achieve the ambitious goals of the ConnectED initiative, and could impact school district finances and operations in ways that make it even more difficult for low-income and rural schools and libraries to meet the instructional needs of their students. Therefore, in addition to NSBA’s filings of September 16, 2013 and November 8, 2013, we recommend the following:
“1. Focus $2 billion in one-time funding for E-rate on Priority 2 services for broadband deployment, and assure that additional schools and libraries have access to the funds. The onetime funding described in paragraph 7 is best suited for initial and one-time investments in broadband deployment such as internal connections, as opposed to ongoing operating costs. Further, there has been a dearth of funding for Priority 2 in recent years, so that only a small number of schools benefit. NSBA recommends that affirmative steps be taken to assure that a one-time infusion of Priority 2 funds is disseminated to schools and libraries that have not had access to such funds in the last five years.
“2. Voice and other legacy services – Establish a menu of options for schools and libraries making transitions to broadband. NSBA supports refocusing E-rate on broadband connectivity, but cautions against eliminating eligible uses of E-rate funds without support for school districts during the transition. An across-the-board approach to elimination or phase down of support for legacy services as described in paragraphs 40 – 46 is not responsive to school districts, whose current equipment, hardware, connectivity, access to broadband, contracting obligations, and other circumstances will vary. NSBA recommends a case-by-case approach and flexible timeframes for transitioning E-rate eligibility to broadband.
“3. Demonstration and pilot programs – Eliminate demonstration programs, pilots, or other carve outs from E-Rate 2.0 unless they are resourced by other Universal Service or alternative funds. While there is great potential in the innovations described in paragraphs 55 – 61 to streamline E-rate and make the program more efficient and effective at meeting the needs of schools and libraries, they should not come at the expense of the School and Libraries Fund itself, which is severely oversubscribed.”
View NSBA’s Issue Brief on E-rate.