FCC Releases Projected State By State Expednitures on ERate; AASA Deeply Concerned

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Earlier this afternoon, the FCC released a report of the potential impact of the pending proposal to modernize the E-Rate program to provide Wi-Fi connectivity to all libraries and schools. The report a state-by-state breakdown of the estimated number of additional students, schools and libraries that would gain E-rate funding needed for Wi-Fi upgrades over the next five years under the proposal. This report projects that nationwide, the proposal would increase funding for Wi-Fi 75 percent for rural schools and 60 percent for urban schools, allowing an additional 44 million students and 16, 000 libraries to have access to Wi-Fi services by 2019. 

AASA has deep concerns with this proposal. As with any of these plans, the devil will be in the details. These numbers, at the state level, look sizeable and impressive, but especially for rurals, it is a situation of 'you get what you get', regardless of actual need, access to previous funding, access to basic school broadband, concentration of poverty or other unique characteristics.

These large funding numbers for internal connections exist in large part--if not solely--because the FCC sat on available funding over the past few years. It is nice that this funding is now available, but we have deep concerns that this proposal is an element of smoke and mirrors and, as stated before, lacks any serious demonstration that the funding needed to maintain the higher levels of connectivity and broadband will be available in the out years.

Rural communities have been down this road before: the rural utility service within the stimulus fund. A recent GAO report detailed the experience of rural communities as it relates to broadband build out as provided through the stimulus. The report found that 14 percent of the projects were terminated, and that of the remainder, 87% were complete or partially operational.

Given the scope of this serious infusion of funding to support broadband build out focused solely on rural areas, these data give us great pause. The proposed changes in E-Rate will rightfully be available to all school districts. As much as the FCC wants to say the proposed changes are focused on driving more dollars to rural areas, it is hard to see how they can (or would or should) disproportionately direct dollars to rural communities. The GAO report illustrates how rural communities were in the position of having promises made related to the out years, and then seeing those promises evaporate or being underdelivered.

It bears strong resemblance to the current E-Rate conversation: "Trust us, take a leap of faith that these programmatic changes can be made now. We have the funding for the first two years, and trust that we can realize the funding for the following three. Trust us that we will be able to meaningfully engage on and deliver as it relates to the conversation of raising the E-Rate cap." These are big asks to make of all E-Rate entities, and especially of the rural communities the FCC seems so focused on, especially when that same community has deep concern with the proposed programmatic changes (related letter and blog post).

We welcome the chance to continue to dialogue with the FCC and to work to make improvements to the proposed modernization so as to not only update the program to reflect the Chairman's focus on internal connections but to also ensure the program's sustainability and capacity to meet schools' and libraries' ever-growing connectivity needs in an equitable manner. Any conversation serious about modernizing E-Rate will reflect the voice of the beneficiary community, and the FCC has been very diligent in working with all E-Rate stakeholders. To the extent that the changes proposed don't gather support from the field and beneficiaries, there may be more good to be gained from 'slowing down to get it right' than to rush to meet an arbitrary deadline.

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