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~fates

llmasqington, mor 20515

April 17, 2014

The Honorable Tom Wheeler

Chairman

Federal Communications Commission

445 12th Street, SW

Washington, DC 20554

Dear Chairman Wheeler:

We strongly support the E-Rate Program as School Districts in the Rio Grande Valley

have participated in theE-Rate Program since it began. E-Rate has allowed South Texas

schools to install network infrastructure and expand high-speed internet access to South

Texas students.

The E-Rate Program is particularly important to school districts with a high percentage of

economically disadvantaged students.

Approximately 85% of students in South Texas

are economically disadvantaged and many do not have internet access at home to

complete homework assignments.

We have met with superintendents from across South Texas all of whom have explained

to us the importance of theE-Rate Program to their Districts.

Given theE-Rate Program's success in South Texas, I urge you to take into account the

input of superintendents in our Districts as you consider changes to the program.

Attached please find comments submitted by the South Texas Association of Schools to

the Federal Communications Commission.

Sincerely,

R!:ôfr--

1tfitv

Member of Congress

Member of Congress

Texas District 15

Texas District 34

PRINTED ON RECYCLED PAPER

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Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, DC 20554

In the Matter of

)

)

Wireline Competition Bureau Seeks Focused

)

WC Docket No. 13-184

Comment on E-Rate Modernization

)

COMMENTS OF SOUTH TEXAS ASSOCIATION OF SCHOOLS

TABLE OF CONTENTS

Introduction ....................................................................................................................................... 3

~10- We seek comment on whether the Commission should change the current priority

two funding category by allocating annually a set amount ofE-rate funds which

are essential to ensuring high-capacity reaches students and library patrons ....................... 5

~11 -We seek comment on whether internal wiring, switches and routers, wireless access

points, and the software supporting these components are the right categories of

equipment and software to fund for the purpose of getting high-capacity

broadband from the building's front door to the computer, tablet, or other learning

devices in schools and libraries ............................................................................................. 5

~12- We seek further focused comment on what services, software or equipment are

necessary to enable high quality, high-capacity networks inside schools and

libraries, and whether such services, software and equipment should qualify for

support ................................................................................................................................... 6

~13- We seek comment on ways to provide more widespread access to funding for

internal connections in order to enable schools and libraries nationwide to take

advantage of high-capacity broadband to their buildings with robust internal

networks ................................................................................................................................ 8

~14- We seek comment on limiting an applicant's ability to receive internal connections

funding to once every five years while retaining the existing prioritization

method ................................................................................................................................... 8

~15- If the Commission were to adopt a five-year upgrade cycle approach, should the

one-in-five limitation apply at the level of applicants or, as it does today, at the

level of individual school and library building? ................................................................... 9

~16- If available funding is insufficient to fund all applicants at a particular discount

level in a given funding year, how should the Commission decide which

applicants to fund? ................................................................................................................ 9

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 1

image03-00.jpg612x792

~17- We seek comment on limiting an applicant's ability to receive funding for internal

connections that support high-capacity broadband to a single funding year until all

other applicants have received support or declined the opportunity to seek funding

in at least one funding year, starting in funding year 2015 ................................................... 9

~18- Should the rotating eligibility limitation apply at the level of applicants or, as the

two-in-five rule does today, at the level of individual schools and library? ....................... 10

~19- If funding is insufficient to fund all eligible applications at a particular discount

level in a given funding year, should the Commission give preference to the

applicants with the highest percentage of students receiving free and reduced

school lunches? ................................................................................................................... 1 0

~20 -

We seek comment on adopting a funding method that would provide some support

for internal connections that support high capacity broadband to all eligible

applicants in each funding year, as opposed to the cyclical funding method

described above ................................................................................................................... 1 0

~21- We seek comment on using a simplified version of the formula proposed by Funds

for Learning and a coalition of schools and school groups to set available funding

levels for each applicant. ..................................................................................................... 11

~22- In addition to ensuring that all applicants have the opportunity to receive at least

some internal connection funding each year, adopting this annual allotment could

have the benefit of providing applicants certainty about the amount of funding

that would be available to them each year. We seek comment on this

consideration ....................................................................................................................... 11

~22- We also seek comment on how to best utilize any remaining funding if some

applicants request less than their allocated amount. ........... Error! Bookmark not defined.

~22 -

Should district or library systems be required to spend those funds at specific

schools or libraries in certain proportions? Or should each applicant have the

flexibility to spend the funds as it decides across the district or. library system? ............... 11

~23 -

Are there variations on the options described above or other methods the

Commission should consider employing to prioritize funding for high-capacity

internal connections? .......................................................................................................... 12

~26- We seek comment on whether the Commission should undertake a limited

initiative, within the existing priority one system, to incent the deployment of

high-capacity broadband connections to schools and libraries, and what types of

fiber-deployment or other high capacity, scalable broadband technologies that

meet the connectivity goals in the E-rate Modernization NPRM, should be eligible

for funding .......................................................................................................................... 12

~30- We seek comment on how best to distribute support among applicants for high-

speed connections to schools and libraries ......................................................................... 12

~31 -

We seek comment on ways to prioritize applications for deployment costs in the

event that the demand for such funds exceeds availability ................................................. 13

South Texas Association ofSchoo1s Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page2

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~32- We seek comments on adopting one or more objective impact and/or efficiency

metrics to prioritize applications ......................................................................................... 13

~36- Should the Commission require applicants that are seeking E-rate support for

upgrading high-capacity connections to school buildings or libraries to

demonstrate that they have a plan and the capacity to use those services within

their buildings? .................................................................................................................... 13

~41- We seek comment on an approach to phase out support for voice services by

gradually reducing the support for voice services over at five-year period ........................ 13

~44- We seek comment on whether there are any voice services that should be excluded

from the phase out? ............................................................................................................. 14

~46- Should the Commission consider eliminating all support for voice services starting

in funding year 20 15? ......................................................................................................... 14

~47- We seek comment on retaining support for voice services under a lower priority ............... 14

~56- We invite suggestions of other types of projects the Commission should conduct

with regard to meeting school/library connectivity needs, the amount that should

be spent on any individual project, and the total budget for such projects ......................... 14

Introduction

The Region One area lies along the Texas-Mexico international border and encompasses a

seven county area including the area of Cameron, Hidalgo, Jim Hogg, Starr, Webb Willacy, and

Zapata Counties. The geographic location of the Region One area lends itself to serving a

diverse and unique student population compared to other areas of the state. With over

419,000 students in 37 public school districts and 10 charter school systems, Region One

schools serve a high percentage of economically disadvantaged students (85%), the state's

highest percentage of Hispanic students (97.5%), English Language Learners (34.8%), migrant

students (4.68%), and English as a Second Language students.

The Region One area is an area where you can see dilapidated houses in areas called "colonias"

where running water and electricity is considered a luxury. These areas often have unpaved

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 3

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roads that are muddied and impassable when heavy rains or bad weather arrives. As dreadful

as these conditions are, you can also witness families calling these areas "home"; their homes

consisting of cardboard boxes or school buses.

Region One School districts strive continuously to develop innovative programs and to seek out

opportunities that will help the district meet the needs of the students. Additionally, school

districts pursue avenues that will support students and bring them to an equal level to the

extent that these students have access to instructional resources and technology.

While this paper is a discussion on technology and funding issues in the K-12 environment, let

us not forget that the knowledge and skills a K-12 student learns today is the basis for a college

education or employment in the increasingly technological workplace. Many colleges and

universities have moved to digital textbooks and the use of laptops/tablets for instruction.

Many offer on-line courses for specific subjects that are Internet based and cannot be attended

other than through the Internet. Our students must be prepared to enter this arena with

knowledge that allows them to effectively use technology as an educational and workplace

tool.

Many mobile device initiatives in the Rio Grande Valley would not be possible if not for E-Rate.

With increased devices on the network comes the need for increased bandwidth. District in the

Rio Grande Valley would not be able to afford the bandwidth needed to support such devices

on the network.

Although school districts in the Region One area have benefitted greatly from the E-rate

program, the ever changing technology and academic requirements require upgrades to

maintain and expand the current networks. This requires an ongoing economic support system

to be in place such as E-rate funding.

School Districts in the Rio Grande Valley have participated in the E-Rate Program since its

inception and appreciate the opportunity to present the following comments in response to the

Commission's Public Notice proceeding "Wireline Competition Bureau Seeks Focused Comment

on E-Rate Modernization".

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page4

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!10- We seek comment on whether the Commission should change the current priority

two funding category by allocating annually a set amount of E-rate funds which are

essential to ensuring high-capacity reaches students and library patrons

The South Texas Association of Schools agrees with setting aside a portion of theE-Rate funds

to be used by Districts that are building new schools to augment their funding allocation to

purchase the additional network cabling and equipment needed to open a new facility. Other than

that, the South Texas Association of Schools firmly believes that every school eligible forE-Rate

funding should be allocated a portion of the total available E-Rate funds each year using the

Simplified Funding Formula included as an attachment with the FCC Public Notice (WC Docket

No. 13-184) with the following modifications:

Dissolve the current Priority I /Priority 2 distinction and allow schools to spend

their funding allocation on eligible equipment and services in the way that makes

the most sense for the district.

Allow the school district to aggregate the allocations for all schools in the district

and spend the portion of their total allocation at each campus that they believe

best meets the needs of their schools and the district as a whole.

Remove the 2-in-5 rule which currently leads to over-buying.

Implementing the Simplified Funding Formula with these modifications provides an amount of

money each year that schools can plan on, equitably distributes funds among all eligible entities,

and provides incentive for districts to spend their allocation wisely.

,r11- We seek comment on whether internal wiring, switches and routers, wireless access

points, and the software supporting these components are the right categories of equipment

and software to fund for the purpose of getting high-capacity broadband from the

building's front door to the computer, tablet, or other learning devices in schools and

libraries

The South Texas Association of Schools agrees that this basic classification of equipment

represents the equipment necessary to provide the basic infrastructure for providing high-speed

internet access to the end user devices. This equipment and software should continue to be

funded byE-Rate.

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 5

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,12 -We seek further focused comment on what services, software or equipment are

necessary to enable high quality, high-capacity networks inside schools and

libraries, and whether such services, software and equipment should qualify for

support

Additional equipment and services are necessary in order to provide a safe and secure computing

environment. The firewall is an example of this type of equipment. Without an adequate

firewall, the school or library network becomes more exposed to hacking attempts. Many schools

and libraries that currently have existing firewalls will likely need to upgrade these devices as

they increase the capacity of their Internet connection.

Traffic shaping appliances/services should qualify forE-Rate funding as they provide a tool to

mitigate unwanted network Internet traffic, freeing up valuable Internet bandwidth. Traffic

shaping (also known as "packet shaping") is a computer network traffic management technique

which delays some or all datagrams to bring them into compliance with a desired traffic profile.

Traffic shaping is a form of rate limiting, which increases usable bandwidth for some kinds of

packets by delaying other kinds. In this case the users will experience a low quality service and

may get the misleading impression that a site is inherently slow or unreliable which eventually

may lead to preference of other sites between users.1 A traffic shaping appliance can assist

schools in limiting traffic to less desirable sites that, because of heavy usage, are limiting

available bandwidth needed for instructional purposes.

Network security management for wireless devices should also be eligible forE-Rate discount.

With the implementation of 1:1 initiatives and Bring Your Own Device (BYOD) initiatives,

schools are bombarded with not only traffic on their network, but a combination of school-

owned and private mobile devices. Ensuring that these private mobile devices are properly

restricted on the network is vital to maintaining a secure network.

Caching appliances and services provide a unique opportunity to actually reduce the necessary

bandwidth needed by a school or district by selectively and intelligently storing information for

web pages that are being accessed, allowing subsequent requests for the same web page to be

displayed from the cache rather than requiring that the page be retrieved from the Internet a

second or third time.

Content Filtering is not currently eligible forE-Rate discount, but is required in order to be

compliant and able to receive E-Rate funding. This unfunded mandate places a burden on

schools but provides no financial assistance for acquisition. As with the firewall, as schools and

1 http://en.wikipedia.org/wiki/Traffic_shaping

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WCDocketNo.13-184

Page6

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libraries increase their Internet capacity, the filtering solution needs to scale-up to meet increased

bandwidth requirements.

Metropolitan area network (MAN) fiber connectivity between schools, even if the connection

crosses public roadways, should be eligible forE-Rate funding. Districts should be allowed to

purchase a single connection to the District network operations center (NOC) from the Internet

service provider, and then provide connectivity from the NOC to each school to share the single

high-capacity broadband Internet connection.

With this scenario, you achieve economy of scale by being able to purchase one large Internet

connection, which means the amount ofE-Rate funding required for the same amount of high-

capacity internet connectivity at the schools is less. This single Internet "pipe" is also shared

among all schools, so it is easier to use a greater percentage of what is being paid for without

some campuses suffering from not having enough bandwidth, and some bandwidth at other

schools sitting idle. The issue that needs to be addressed is that there still needs to be a means to

share that single high-capacity Internet connection with the schools. This can be accomplished

by leasing a telecom circuit between the NOC and each school, or by installing a fiber-optic

cable or microwave link between the NOC and each school.

Lease costs for the telecom circuit are an ongoing Priority 1 service cost, and will likely offset

(or more likely exceed) theE-Rate savings gained by moving to a single, larger Internet

connection. The microwave link is a one-time cost, and the equipment should last for 5-7 years,

however, there are limitations on throughput, and if available the cost for 10 Gbps microwave

connectivity is probably cost prohibitive. Allowing school Districts to install fiber-optic cable to

connect their NOC to each campus provides a one-time cost. The fiber-optic cable is currently

capable of transmitting at speeds of 1 Gbps up to 10 Gbps or even 40 Gbps at a reasonable cost

for the proper fiber-optic transmit modules.

The South Texas Association of Schools believes that fiber-optic cable, installed using

directional boring, is the most cost-effective long-term solution for us to provide connectivity for

our school district. The South Texas Association of Schools would like to see the cost of

installation of private fiber-optic cable between a school district network operations center and

each school in the district added to the eligibility list. However, some districts might still need to

have leased circuits for connectivity due to the large size of the district. Both leased and private

fiber should continue to be options. If a mandated change to the private fiber option were to

occur, a phase in period of 5 years should be available to districts.

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 7

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,13-

We seek comment on ways to provide more widespread access to funding for internal

connections in order to enable schools and libraries nationwide to take advantage of

high-capacity broadband to their buildings with robust internal networks

The South Texas Association of Schools firmly believes that the best way to ensure that the

largest number of schools are able to take advantage ofE-Rate funding would be to allocate a

portion of the total available E-Rate funds each year using the Simplified Funding Formula

included as an attachment with the FCC Public Notice (WC Docket No. 13-184) with the

following modifications:

Dissolve the current Priority I /Priority 2 distinction and allow schools to spend

their funding allocation on eligible equipment and services in the way that makes

the most sense for the district.

Allow the school district to aggregate the allocations for all schools in the district

and spend the portion of their total allocation at each campus that they believe

best meets the needs of their schools and the district as a whole.

Remove the 2-in-5 rule which currently leads to over-buying.

Implementing the Simplified Funding Formula with these modifications provides an amount of

money each year that schools can plan on, equitably distributes funds among all eligible entities,

and provides incentive for districts to spend their allocation wisely.

,14- We seek comment on limiting an applicant's ability to receive internal connections

funding to once every five years while retaining the existing prioritization method.

The South Texas Association of Schools opposes limiting internal connections to 1-in-5 years,

and advocates for the repeal of the 2-in-5 rule. However, if the determination is made to

continue with any form ofX-in-X year's model, the network operations center should be eligible

forE-Rate funding as an independent entity, and not count against any of the schools.

These artificial restrictions force schools to over-buy in the years that they are funded. The 2-in-

5 rule was originally established because schools with lower discount percentages were not being

funded. It was believed that by only allowing schools to purchase internal connections 2 years

out of every 5 years, that funding would naturally become available to the lower percentage

discount schools over time. What ended up happening was that schools went all out in the years

that they could purchase, and absorbed all available funds well before internal connection funds

were available to schools in the lower brackets. Additionally, since the network operations center

impacts every school served, it makes it very difficult to plan upgrades as they are needed and

further forces schools to replace equipment more often than necessary for fear of missing an

opportunity in one ofthe purchase years.

South Texas Association of Schools Comments to FCC Public Notice on E-Rate Modernization

WC Docket No. 13-184

Page 8

image10-00.jpg612x792

By implementing the Simplified Funding Formula with modifications, as described in ~I 0 above,

there would be less inclination to over-buy. The inclination would shift to determining the best

methodology for spending the funds that were allocated to the district. Additionally, since the

annual E-Rate funds available for each year would be equitably allocated across ALL schools,

ever school could count onE-Rate funding EVERY year, and schools would begin to think about

the best ways to spend what they were allocated.

There would need to be some amount of theE-Rate funds set aside for new schools. Districts

building new schools would receive an additional allocation for each new school based on the

size of the school. These one-time additional funds would be available to establish the network

in the new school. The amount should be equal to the average nation-wide cost to wire and

equip a school of the size being built.

,I15 -If the Commission were to adopt a five-year upgrade cycle approach, should the one-

in-five limitation apply at the level of applicants or, as it does today, at the level of

individual school and library building?

The South Texas Association of Schools adamantly opposes the one-in-five limitation.

However, if it is to be implemented, the rule should apply at the school level, and additionally

the network operations center, which currently counts against every school that it services,

should be considered a separate eligible entity for funding purposes.

,rt6- If available funding is insufficient to fund all applicants at a particular discount level

in a given funding year, how should the Commission decide which applicants to

fund?

Decisions should be made based on a formula that gives preference to schools with a high level

of socio-economic disadvantaged students (free and reduced lunch program). The South Texas

Association of Schools opposes any decision on funding based on measuring cost per student

served.

,r17- We seek comment on limiting an applicant's ability to receive funding for internal

connections that support high-capacity broadband to a single funding year until all

other applicants have received support or declined the opportunity to seek funding

in at least one funding year, starting in funding year 2015.

The South Texas Association of Schools is opposed to this methodology for attempting to spread

funding across all schools over time. Because it will be unclear on how long it would be before

funding became available again, this methodology will result in schools over-purchasing in the

years that they are funded in a manner similar to what we are seeing with the current 2-in-5 rule.

South Texas Association of Schools Comments to FCC Public Notice on E-Rate Modernization

WC Docket No. 13-184

Page 9

image11-00.jpg612x792

This methodology would also punish districts that are growing, since new facilities built mid

cycle would not be eligible for funding. Finally, the uncertainly of when funds would be

available next, and how much would be allocated to the school, would not allow staff to properly

plan for funding- feast and famine.

~US- Should the rotating eligibility limitation apply at the level of applicants or, as the

two-in-five rule does today, at the level of individual schools and library?

The South Texas Association of Schools does not support rotating eligibility, but if implemented

it should be at the individual school/library level so that new schools/libraries being built are

immediately eligible in the year they come online.

,rt9 -If funding is insufficient to fund all eligible applications at a particular discount level

in a given funding year, should the Commission give preference to the applicants

with the highest percentage of students receiving free and reduced school lunches?

Yes.

,r20- We seek comment on adopting a funding method that would provide some support

for internal connections that support high capacity broadband to all eligible

applicants in each funding year, as opposed to the cyclical funding method

described above.

The South Texas Association of Schools firmly believes that the best way to ensure that the

largest number of schools are able to take advantage of E-Rate funding would be to allocate a

portion of the total available E-Rate funds each year using the Simplified Funding Formula

included as an attachment with the FCC Public Notice (WC Docket No. 13-184) with the

following modifications:

Dissolve the current Priority I /Priority 2 distinction and allow schools to spend

their funding allocation on eligible equipment and services in the way that makes

the most sense for the district.

Allow the school district to aggregate the allocations for all schools in the district

and spend the portion of their total allocation at each campus that they believe

best meets the needs of their schools and the district as a whole.

Remove the 2-in-5 rule which currently leads to over-buying.

Implementing the Simplified Funding Formula with these modifications provides an amount of

money each year that schools can plan on, equitably distributes funds among all eligible entities,

and provides incentive for districts to spend their allocation wisely.

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 10

image12-00.jpg612x792

,21 -We seek comment on using a simplified version of the formula proposed by Funds for

Learning and a coalition of schools and school groups to set available funding levels

for each applicant.

The South Texas Association of Schools firmly believes that every school eligible forE-Rate

funding should be allocated a portion of the total available E-Rate funds each year using the

Simplified Funding Formula included as an attachment with the FCC Public Notice (WC Docket

No. 13-184) with the following modifications:

Dissolve the current Priority ]/Priority 2 distinction and allow schools to spend

their funding allocation on eligible equipment and services in the way that makes

the most sense for the district.

Allow the school district to aggregate the allocations for all schools in the district

and spend the portion of their total allocation at each campus that they believe

best meets the needs of their schools and the district as a whole.

Remove the 2-in-5 rule which currently leads to over-buying.

Implementing the Simplified Funding Formula with these modifications provides an amount of

money each year that schools can plan on, equitably distributes funds among all eligible entities,

and provides incentive for districts to spend their allocation wisely.

,22- In addition to ensuring that all applicants have the opportunity to receive at least

some internal connection funding each year, adopting this annual allotment could

have the benefit of providing applicants certainty about the amount of funding that

would be available to them each year. We seek comment on this consideration.

The South Texas Association of Schools agrees that this methodology provides a defined

"budget" that schools/libraries could use to pay for equipment, upgrades and/or maintenance of

existing equipment. By providing that predictable "budget" amount, schools would be able to

plan better. Additionally, because there is a predictable "budget" schools could begin to think

more long-term, allowing them to identify more cost effective ways to purchase and deploy

equipment and services.

,22 -

Should district or library systems be required to spend those funds at specific schools

or libraries in certain proportions? Or should each applicant have the flexibility to

spend the funds as it decides across the district or library system?

The South Texas Association of Schools advocates for school districts to have maximum

flexibility to spend at the schools that make the most sense to the district or library system in

light of their long-term plans and goals.

South Texas Association of Schools Comments to FCC Public Notice on E-Rate Modernization

WC Docket No. 13-184

Page 11

image13-00.jpg612x792

!23 -Are there variations on the options described above or other methods the

Commission should consider employing to prioritize funding for high-capacity

internal connections?

The South Texas Association of Schools contends that the "Students impacted per dollar spent"

model is not a good measure. Each campus/library is unique at any given point in time, and it is

essential to provide the school district or library system the maximum flexibility in detennining

what project best meets their needs.

The Simplified Funding Fonnula, with modifications discussed in ~I 0, provides the most

equitable distribution ofE-Rate funds. Beyond that, providing additional funds for new

construction to help offset the initial cabling of the building would seem prudent.

!26- We seek comment on whether the Commission should undertake a limited initiative,

within the existing priority one system, to in cent the deployment of high-capacity

broadband connections to schools and libraries, and what types of fiber-deployment

or other high capacity, scalable broadband technologies that meet the connectivity

goals in the E-rate Modernization NPRM. should be eligible for funding.

The South Texas Association of Schools advocates for the addition ofMetropolitan Area

Network fiber-optic cable installations to the services eligibility list. Metropolitan area network

(MAN) fiber connectivity between schools, even ifthe connection crosses public roadways,

should be eligible forE-Rate funding. Allowing for the eligibility of lighting dark fiber and the

associated costs with the deployment of this fiber would be a one-time cost and in the long run

would produce a sizable savings.

,30- We seek comment on how best to distribute support among applicants for high-speed

connections to schools and libraries.

The South Texas Association of Schools finnly believes that every school eligible forE-Rate

funding should be allocated a portion of the total available E-Rate funds each year using the

Simplified Funding Fonnula included as an attachment with the FCC Public Notice (WC Docket

No. 13-184) with the following modifications:

Dissolve the current Priority ]/Priority 2 distinction and allow schools to spend

their funding allocation on eligible equipment and services in the way that makes

the most sense for the district.

Allow the school district to aggregate the allocations for all schools in the district

and spend the portion of their total allocation at each campus that they believe

best meets the needs of their schools and the district as a whole.

Remove the 2-in-5 rule which currently leads to over-buying.

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WCDocketNo.l3-184

Page 12

image14-00.jpg612x792

Implementing the Simplified Funding Formula with these modifications provides an amount of

money each year that schools can plan on, equitably distributes funds among all eligible entities,

and provides incentive for districts to spend their allocation wisely.

~31 -We seek comment on ways to prioritize applications for deployment costs in the event

that the demand for such funds exceeds availability.

The South Texas Association of Schools advocates use of the same funding approach that is

currently used, 90%, 89%, etc., tempered with the addition of highest percentage free and

reduced lunch for applications within a funding band. Implementation of the Simplified Funding

Formula, as previously discussed, would eliminate the issue of demand exceeding supply since

each eligible entity would have a pre-determined allocation for the E-Rate funding year that they

could use to address their needs.

!32- We seek comments on adopting one or more objective impact and/or efficiency

metrics to prioritize applications.

The South Texas Association of Schools recommends the implementation of an "efficiency

points system" for upgrades, such as from two T3 circuits to a single 1 OOMbps metro Ethernet

circuit, where the circuit and internet access costs post upgrade are significantly less than pre-

upgrade. By prioritizing applications that promise more efficient use of theE-Rate funds, you

will be providing incentives for schools to find creative ways to reduce long-term costs.

!36- Should the Commission require applicants that are seeking E-rate support for

upgrading high-capacity connections to school buildings or libraries to demonstrate

that they have a plan and the capacity to use those services within their buildings?

The South Texas Association of Schools absolutely agrees with a requirement for these

applicants to demonstrate the existence of a plan and the capacity to use the services.

!41- We seek comment on an approach to phase out support for voice services by

gradually reducing the support for voice services over at five-year period.

The South Texas Association of Schools supports the gradual reduction of funding for voice

services over a five year period- provided funding is made available on a "free and reduced

lunch" weighted student- count formula that provides each school with a predictable multi-year

budget that allows them to plan for an implement the changes necessary to migrate from

traditional voice services to VOIP. To make this possible, all associated VOIP costs would need

to be eligible (ie: servers, call managers, licenses and PRis). We are also in support of keeping

cellular services that support instruction on the eligible services list.

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 13

image15-00.jpg612x792

,44- We seek comment on whether there are any voice services that should be excluded

from the phase out?

The South Texas Association of Schools proposes that certain voice services be excluded from

the phase-out plan. These would include inbound/outbound trunks at network operations center

for districts that choose to maintain VOIP within the district only, and still rely on POTS for

outside connections, and telephone lines for elevators and alarm systems. We are also in support

of keeping cellular services that support instructional activities on the eligible services list.

,46- Should the Commission consider eliminating all support for voice services starting in

funding year 2015?

The South Texas Association of Schools advocates for continuing funding for specific voice

services as detailed in ~44 above.

,47- We seek comment on retaining support for voice services under a lower priority.

The South Texas Association of Schools sees this as a viable alternative that would provide

incentive for schools to move away from voice services, while still providing funding for these

services at a lower discount rate (not priority) for services that need to be continued (i.e. elevator

phone lines, etc.)

,56- We invite suggestions of other types of projects the Commission should conduct with

regard to meeting school/library connectivity needs, the amount that should be

spent on any individual project, and the total budget for such projects.

The South Texas Association of Schools would like to see the cost of installation of Metropolitan

Area network (MAN) fiber-optic connections (private fiber-optic cable between a school district

network operations center and each school in the district) to be added to the eligibility list.

Submitted Respectfully,

Dr. Daniel P. King

Martin Pena

President

Executive Director

South Texas Association of Schools

South Texas Association of Schools

drking@psjaisd.us

213 Mesquite, Laguna Vista, TX. 78578

mpena2023@aol.com

South Texas Association of Schools Comments to FCC Public Notice onE-Rate Modernization

WC Docket No. 13-184

Page 14

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