- NEA files comments with FCC on E-rate Further Notice of Proposed Rulemaking ( PDF, 241 KB, 13 pgs.) (9/14/14)
- NEA files reply comments with FCC on E-rate Public Notice ( PDF, 99 KB, 9 pgs.) (4/21/14)
- NEA files initial comments with FCC on E-rate Public Notice ( PDF, 98 KB, 14 pgs.) (4/7/14)
- NEA files reply comments with FCC on E-rate ( PDF, 143 KB, 7 pgs.) (11/8/13)
- NEA files comments with FCC on E-rate ( PDF, 278 KB, 15 pgs.) (9/16/13)
- FCC Seeks to Modernize the E-rate Program
- President Obama Unveils ConnectED Initative
In funding year 2013, the E-rate program provided $2.4 billion in discounts annually for advanced, affordable telecommunications and Internet services, and internal connections to public and private schools and public libraries.
Since its enactment by the U.S. Telecommunications Act of 1996, the E-Rate program has, for countless students, opened the door to developing the skills needed to compete in a digital age and had overwhelming success in connecting our schools and libraries to the Internet. The E-rate program, a vital resource for enhancing student learning, is the fourth-largest source of non-state or local funding to schools. In fact, more than 8 out of 10 public schools rely upon E-rate discounts.
The program has been so successful that merely accessing the Internet is not enough.
President Obama’s ConnectED Initiative
In June 2013, President Obama unveiled the ConnectED Initiative aimed at connecting all schools to the digital age. The ConnectED initiative seeks to connect schools and libraries serving 99 percent of our students to next-generation high-capacity broadband (with speeds of no less than 100 Mbps and a target speed of 1 Gbps) and to provide high-capacity wireless connectivity within those schools and libraries within five years. President Obama has called on the Federal Communications Commission (FCC) to modernize and leverage the E-rate program to help meet those targets.
Modernization of the E-rate
In July 2013, the Federal Communications Commission (FCC) published a Notice of Proposed Rulemaking ( PDF, 1.5 MB, 175 pgs.)(NPRM), or request for comments, on the E-rate program, in response to President Obama’s ConnectED Initiative. The FCC is seeking comments on ways to modernize and leverage the existing E-rate program in light of the fact that for 2013 funding year, schools and libraries sought E-rate funding in excess of $4.9 billion — nearly double the amount available. NEA believes that in order to support 21st century teaching and learning, the E-rate program needs an increase in funding coupled with cost-saving measures and efficiencies.
FCC Seeks Focused Comments on E-rate
In March 2014, the FCC followed up on earlier requests for comments by issuing a Public Notice seeking additional focused comments on how to best “modernize” the E-rate Program. NEA filed initial comments with the FCC on April 7, 2014.
Highlights from the NEA’s initial comments on the FCC’s proposed ideas to modernize the E-rate Program included:
- The E-rate Program’s 18 years of success demonstrates it is a program that works — and is vital to keeping schools connected to the Internet.
- Proposed changes to the E-rate Program that reduce or abjectly remove equity from equations on how to prioritize and distribute funds to applicants are not acceptable.
- The E-rate’s historic use of concentration of poverty (using applicants’ percentage of students that qualify for free and reduced lunches), taking into account geographic isolation, is critical to the continued distribution of E-rate funds in a truly equitable way.
- Distributing E-rate funds via a “per-pupil” or “per-capita” formula turns the program into a block grant to applicants, eliminating concentration of poverty, thus eliminating the equitable distribution of funds.
- NEA strongly opposes demonstration projects (i.e. carve-out or set-aside special interest projects) being funded with existing E-rate funding. Existing applicant demand — which is double what is currently available — should be met before investing in any new initiatives.A one-time infusion of $2 billion from existing E-rate coffers earmarked to support Priority two (P2) services does not solve, nor alleviate the on-going inability of the E-rate Program to meet beneficiary demand.
- NEA cautions against the idea that eliminating basic telephone and other related eligible services will result in significant savings to the E-rate Program.
- NEA supports encouraging consortia applications; however, they should not be required nor should those not participating in consortia applications be penalized.
- NEA wholeheartedly advocates for streamlined applications (e.g. multi-year or renewable).
- Ultimately, the NEA believes the greatest challenge facing the E-rate Program’s ability to support sufficient high-speed broadband capacity has been its inability to keep up with applicant demand — as the Program’s funding has been capped since its inception.
On March 21, the NEA submitted reply comments in response to Public Notice filings submitted to the FCC by other groups to ensure educators’ voices are heard. In NEA’s reply comments, we expressed concern on behalf of E-rate beneficiaries in response to comments and suggestions put forth by other organizations including the E-rate Program abandoning equity and need in favor of prioritizing by institution type, companies and organizations that do not represent program beneficiaries requesting preferential treatment, and entities other than the Universal Service Administration Company assuming the role of program data collector.
NEA Concerns with FCC's Proposed E-rate Changes
On June 20, 2014 the FCC Chairman circulated among the Commissioners a draft Order on E-rate Modernization (not made publically available), that will be taken up for a vote during their July 11 meeting. The NEA, along with 12 other national education organizations, sent a letter to the Commission expressing strong concerns with the Commission’s proposed changes to the E-rate Program articulated in the draft Order.
Specifically, the NEA and education community is extremely concerned about:
- The sustainability of the E-rate Program is jeopardized in response to the Commission’s intent to implement a five year $5 billion plan to invest in Priority II Wi-Fi connections. While the Commission has reprogrammed $2 billion in existing funds for the first two years, the plan does not articulate sufficient funding for years three through five. Without investing additional money, the only remaining funding source for the five-year Wi-Fi connections plan would be Priority I funds — resources beneficiaries depend upon to help meet their ongoing, monthly costs for broadband connectivity — to support Wi-Fi.
- The Commission’s intent to change the existing funding structure for Priority II to a per-pupil allocation to be used within a five-year period, even if done within the existing discount matrix, abandon’s equity (calculated by need and geographic local). Moving away from a need-based method erodes the equitable distribution of E-rate funds as well as our ability to ensure funds reach those the Program was designed to help: those schools, libraries and communities most in need.
In addition, the NEA is believes that the Commission’s unsustainable plan to invest in Wi-Fi connections over a five-year period does not help address those schools who do not already have sufficient high-speed broadband capacity to their building — and will result in leaving those students most in need, predominately in our nation’s rural areas, behind.
The Commission will vote on the E-rate Modernization draft Order during their meeting on July 11, 2014.
Media coverage related to the NEA’s letter and the Commission’s proposed changes include:
- National Journal: Teachers give failing grade to Obama’s push for tech in schools 6/24/14
- Education Week: E-rate plan for Wi-Fi expansion draws praise, and calls for greater action 6/20/2014
- NEA News Release: NEA President - FCC E-rate Policy is bad public policy 6/20/14
Read more about NEA positions on technology and education.
- Education and Library Networks Coalition (EdLiNC) Coalition of public and private schools and public libraries of which NEA is member.
- FCC Guide to E-rate Program
- Universal Service Administrative Company (USAC): Schools & Libraries E-rate To find funding specific to your state, see “Funding Commitment Tool” and use “advanced search”