ISTE is a strong supporter of the E-Rate program. When the Federal Communications Commission (FCC) modernized this program in 2014, it focused funding on broadband internet service (Category 1) and Wi-Fi and internal connections (Category 2). For Category 2, E-Rate provides schools with a formula distribution of $150 per pupil that is supposed to last schools five years and that schools have five years to use.
Since the modernized E-Rate with a higher spending cap rolled out in 2015, schools have made active use of their Category 2 allotments. However, not all schools have used their full allotments yet. According to data gathered by Funds for Learning, "more than a third (37 percent) of participating sites have not touched their Category Two (C2) budgets, and another quarter (23 percent) have used less than half of their budgets. Only a relatively small percentage of sites (18 percent) have maxed out their C2 discounts." In total, $2.35 billion in Category 2 funds remain unclaimed and unspent.
Last month, the FCC's Wireline Bureau launched a public notice seeking comment on Category 2 budgets. Specifically, this public notice asks how schools have used their allotments and whether schools made Wi-Fi purchases without E-Rate support. The public notice also asks why some schools have not used their allotments yet and whether they plan to do so before the end of the five-year formula cycle.
What's at stake?
ISTE is growing concerned that the FCC is not asking these questions merely for data-gathering purposes, but for another end entirely. Two of E-Rate's sister universal service programs, also administered by the FCC, are short of funds. The data collected in this rulemaking may stand as evidence that schools are not using or do not need some or all of their Category 2 funds, providing the FCC a pretext to transfer E-Rate dollars to other universal service programs. Once those dollars are transferred out of E-Rate, they may be gone forever and stand as a precedent for lower overall funding for E-Rate for years to come.
What you can do?
The FCC has asked the public to submit initial comments on this public notice byOct. 23. and reply comments by Nov. 7. Schools, districts, educators and parents should file comments in the next month that tell the FCC: Hands-off E-Rate Category 2 funds. A strong response from the education community might prevent the FCC from taking action to transfer E-Rate funds.
What should you say?
Comments can be short and to the point, saying:
- The E-Rate's investment in Category 2 Wi-Fi and internal connections funding is extremely valuable and could not be replaced by school, district or state funds.
- Your school or district has already used some or all of its E-Rate Category 2 allotment for the following items: ___________. The connectivity provided by these Category 2 items has improved our school or district's educational experience in the following ways: ___________. Or ...
- Your school or district plans to use all of its E-Rate Category 2 allotment by 2020 for the following items:_____________. We anticipate that the connectivity provided by these Category 2 items will improve our school or district's educational experience in the following way:____________.
How do you file?
To submit comments to the FCC:
- Go to fcc.gov/ecfs/filings.
- Fill out the required sections of the form, inputting 13-184 into the "Proceedings" line.
- Upload your filing.