On September 16, 2013, Funds For Learning® submitted comments to the FCC in response to the E-rate Notice of Proposed Rulemaking. Funds For Learning® presented the FCC with the following recommendations for reforming and updating the landmark funding program:
Increase funding to $4.5 billion per year. School budgets are tight, and their computer networks are lagging. The available E-rate funding for schools has increased 5 percent since 1998. During that same time, schools have increased their Internet access and telecommunications services by 321 percent.
Restore local decision-making and technology planning. Rather than the current FCC-mandated technology choices, schools would set their own funding priorities.
Streamline work with one Form 471 application. Applicants would submit one funding application rather than multiple “Priority 1” and “Priority 2” applications, as they are encouraged to do today.
Make planning easier with set filing window dates. Rather than waiting each year to find out when the filing window will open, the filing window dates would be set much like they are for taxes.
Release funding sooner. The proposed system allows USAC, the fund administrator, to issue funding commitments much earlier in the year. Knowing that the funds have been committed helps schools plan to use their technology more effectively.
Keep the program solution-minded. Technology changes much more rapidly than federal regulations. Funds For Learning® urges the FCC not to set quotas on the types or quantities of technology used to connect students.
Protect small and rural schools. Funds For Learning® proposes specific safeguards for small and rural schools to ensure that they receive E-rate discounts. Today, no such safeguards exist, and many of these schools are at risk of losing out on E-rate funds.
Preserve what works. The original discount rate matrix and eligible services framework are strong. Funds For Learning® requests that the FCC keep and expand the eligible services list, and maintain the existing sliding scale of E-rate discounts. Busy applicants do not have time to needlessly learn new forms and procedures.
To bring about these improvements, Funds For Learning® proposed a new discount budget system. Under this system, applicants will request E-rate discounts just as they have every year, but with one important difference. Rather than the current unpredictable discount threshold denials, applicants would know ahead of time the maximum amount of discounts that they could request. This maximum would be calculated based on the applicant’s size, location and E-rate discount rate. The new system would mean 100 percent of applicants could receive discounts on critical Internal Connections equipment, as well as other eligible connectivity services.
Rising demand for Internet access, combined with 1990’s-era regulations, has shifted the program away from its core mission of connecting students. Today, the E-rate program routinely denies funding for critical networking infrastructure, such as Wi-Fi hot spots; and on its current course, the majority of E-rate applicants will likely be denied funding for any services within two years.
