Comments needed for FCC rulemaking on E-Rate Program

As you know, the Federal Communications Commission (FCC) has recently launched a rule making process to modernize the E-rate program to ensure that the program is able to continue its critical role in supporting universal access to advanced telecommunications services and robust broadband in support of student learning. The E-rate, which currently provides approximately $2.3 billion a year for educational technology infrastructure nationwide, has been instrumental to enabling the adoption and implementation of state policies that support the transition to high-quality digital textbooks and instructional materials, online assessment, data-driven decision making, online and blended learning, and competency-based education. The current FCC rule making process is expected to result in a comprehensive reform, re-alignment, and expansion of the E-rate to better support K-12 education’s increasing reliance on access to broadband-enabled tools and services.

The State Educational Technology Directors Association (SETDA) called for a modernization of the E-rate program in our May 2012 report, The Broadband Imperative: Recommendations to Address K-12 Infrastructure Needs. Based on existing trends and the experiences of leading states and districts, SETDA recommended that schools will need external Internet connections to their Internet service provider of 100 Mbps per 1,000 students and staff by 2014-15 and of 1 Gbps per 1,000 students and staff by 2017-18. SETDA also made recommendations for internal (wired or wireless) connectivity needs of schools: 1 Gpbs per 1,000 students and staff by 2014-15 rising to 10 Gpbs per 1,000 students and staff by 2017-18. The SETDA capacity recommendations have been widely endorsed and have been instrumental to spurring the recent FCC action.

In order to ensure that the E-rate rule making results in program changes in support of state and local education priorities, it is vital that state agencies, school districts, and all other state and local organizations with whom you work, also file comments with the FCC emphasizing a few simple, high-level messages by no later than September 16, 2013. SETDA urges your state agency, your school districts, and other stakeholder agencies and organizations to submit a simple 1-2 page letter to the FCC emphasizing the following four overarching themes:

1) Universal, robust educational broadband access is necessary to meeting school reform and improvement goals, including to preparing all students for college and 21st century careers.

2) Despite the prior successes of the E-rate program, the demands for access to broadband for learning are growing beyond schools’ ability to provide it cost-effectively.

3) A modernized E-rate program must be less burdensome for schools to participate in and better aligned to current and future K-12 education priorities, including in helping all schools to plan and budget for ongoing technology needs.

4) Given the high cost to schools of providing universal, robust educational broadband access, the demand for the E-rate program has exceeded available funding. E-rate funding will need to be increased to meet state and local needs.

In attachments to this communication, SETDA has provided a modifiable template response suitable for this purpose, as well as detailed instructions on how to submit your comments directly to the FCC by the due date of September 16.

In addition, SETDA will submit comments on behalf of our state members as part of this proposed rule making. We are currently working with a task force of knowledgeable state education agency staff from across the country to inform our comments, but would welcome additional state education agency participation. Christine Fox, SETDA Director of Educational Leadership and Research, can connect you to that ongoing process. She is available at or 202-715-6636 x702.

Finally, we understand and would encourage those most experienced with this complex program to provide additional detailed and specific feedback on the proposed rule making (or to incorporate these messages into your comments) and to evaluate the proposals advanced by other commenters over the coming weeks and months. SETDA will provide additional details and suggested guidance to state members to inform your further deliberations as it is available. Moreover, we would be pleased to connect you directly to other state agency staff preparing detailed comments.

Thank you for your leadership.

Douglas A. Levin
Executive Director

1.  PDF of Letter: E-Rate Modernization: Action Steps for State Leaders (suitable for forwarding to 3rd parties)
2. Suggested Template to Comment on E-Rate Modernization and Instructions on How to File Comments (.doc format for ease of editing)

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