Education, Library Groups Seek More Funding, Permanent Status in E-rate Category 2
Those representing schools and libraries endorsed an FCC plan to update its rules on USF E-rate category 2 spending to make permanent a pilot program that was to expire at the year-end, and asked that it move to a districtwide vs. a building-level budget approach, add to its list of eligible services and lessen filing burdens for applicants, in comments to docket 13-184 posted through Monday (see 1907090074).
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E-rate category 2 spending supports internal connections and basic network maintenance for schools and libraries that provide broadband access to students and patrons. Cisco Systems said the agency should update the definition of "internal connections and basic maintenance" needs to reflect changes in technology, such as cloud-based services and new software. "These systems are especially prevalent in schools with lean IT budgets, where funding is unavailable for staff to manage, monitor, and maintain traditional hardware solutions," Cisco said.
Network security is high among recommendations of what to add to the category 2 eligible services list. School and library information technology departments face new cybersecurity challenges including ransomware attacks, while their IT budgets face increasing pressure, said Cox Communications. "Considering how commonplace cyber attacks occur, it is essential that networks be protected against such malicious attacks," said the State E-rate Coordinators' Alliance and the Schools, Health & Libraries Broadband Coalition in joint comments.
School districts and library systems sought increases to per-pupil or per-square-foot spending and more flexibility in how they distribute those funds among their various buildings. EducationSuperHighway said high schoolers use technology more frequently than those in lower grades and require more tech infrastructure and Wi-Fi coverage even when elementary schools have a larger student body. It said other factors can affect costs: older buildings can cost more to upgrade than newer ones.
"System-wide C2 budgets are an absolute necessity," said Funds for Learning, saying 93 percent of those surveyed recently support the move to a district-wide approach to E-rate category 2 funding. The change to systemwide budgets will simplify the application process for school and library districts and make the review process easier for the Universal Service Administrative Co., it said.
If the FCC and USAC adopt a districtwide approach to funding schools or libraries, other benefits would follow, some said. A "simplification factor of moving to a system-wide budget is that there is no need to track the transfer of equipment within any branch of the system," said the American Library Association. "Since the system will make decisions on what hardware to purchase for any particular branch, it should then have the ability to move that equipment to another branch if needed. This would reduce the burden on the library, as well as the Commission and USAC."
Commenters also asked the FCC to clarify how it will transition to the new permanent funding status and funding levels if it adopts them as expected. Some want the E-rate program to start fresh in the 2020 funding year and reset all applicant budgets even for those who had not used all the money allotted from the previous funding cycle. Applicants "cannot make a decision regarding a new Category Two project until they know how much E-rate funding they will be receiving," said Infinity Communications & Consulting. The firm asked the FCC to allow a longer filing window or delay it by four months if its new rules are released late in 2019, or postpone the new five-year budget cycle until funding year 2021 and allow applicants to use the last year of their current category 2 budgets if the FCC decides not to allow extra time for filing.
The American Library Association said "many rural libraries and smaller libraries at the funding floor may be deterred from applying for C2 funds because the administrative costs of participating outweigh the benefits of doing so."
In joint comments, the State E-rate Coordinators' Alliance and the Schools, Health & Libraries Broadband Coalition said they support making permanent the E-rate category 2 budget program but recommended changes. "The five-year pilot has allowed for experience to be gained and analyzed but has identified certain anomalies that impede the full realization of the benefits of the program."