Skip Navigation

Federal Communications Commission

English Display Options

Commission Document Attachment






Modernizing the E-rate Program for Schools and Libraries, WC Docket No. 13-184.

While perfection may be the enemy of the good, some may question whether this item rises to

that level. It certainly is not perfect, and there are key aspects I would have approached differently, but

the Order makes a number of improvements that streamline and modernize the E-rate program, and, at the

end of the day, that is good.

To say that there has been a lively debate leading up today’s meeting is an understatement but I

fear some may have lost sight of the forest for the trees. If my sister, a middle school teacher, read only

the press coverage of the last few weeks, I am not sure that she would have a full appreciation of why we

are here today. For what gets lost in all the talk about numbers, per square foot budgets, and lists of

services – some of which may require a dictionary to decipher – is how this item could improve my

sister’s ability to teach her students at Dent Middle School or how our local library could better serve the


Setting aside all the rhetoric, this item is fundamentally about the educational forest surrounding

our children and their communities. It is about ensuring that our youth have the tools needed to be the

leaders of tomorrow; it is about providing our country with the means to be an enabler of excellence; it is

about breaking down barriers of poverty and demographic differences through our schools and libraries

by making sure they have access to world-class broadband and WiFi.

This is why we have E-rate.

And because of those visionaries in Congress, including Senators

Rockefeller and Markey, and former Senator Snowe, many of our schools and libraries, particularly in

rural and high poverty areas have the world-class technology they need to succeed.

For me and so many others, broadband is the greatest equalizer of our time. It has the power to

break down decades of barriers and provide children from Moncks Corner, South Carolina, to Tysons

Corner, Virginia, with access to many of the same world-class digital learning and tools they will need to


But the fact is that the schools and libraries in Moncks Corner do not have the same means or

resources as those in Tysons Corner, and, absent the FCC’s E-rate program, schools and libraries in rural

and higher poverty areas likely would not even begin to have the means to purchase high capacity robust

broadband to and within their learning centers. I have seen and spoken about how robust connectivity and

1:1 initiatives can transform communities from Loris Elementary in South Carolina, to Muir Middle

School in South Central Los Angeles, and this is why we are here.

We are here because we would be derelict if we leave our most vulnerable children and

communities without the infrastructure they need to be successful. And while today’s item does not make

all of the changes necessary to achieve each and every goal, it does make noteworthy steps in the right


I noted from the start that, in my opinion, this item is not perfect. At this juncture, I wish to

highlight what is good about the Order.

First, we take a significant step in addressing the concerns regarding affordable access to internal

connections or WiFi. Although many schools and libraries have sufficient capacity to the building, some

cannot take full advantage of that capacity because they do not have the resources to purchase internal

WiFi connections.

The item’s approach to closing this gap is not necessarily the one I would have taken, and I must

admit I have reservations about a per-student or a per-square-foot metric to allocate support. I would

have preferred a narrower framework grounded on the needs of the community that takes into account the

gaps that exist in the highest poverty centers. But I appreciate the Chairman’s willingness to address


those concerns, by increasing the per square foot allocation for libraries to $2.30, raising the school and

library floor, and adjusting the discount for Category Two services to 85%, for the highest poverty

schools. These changes make me more comfortable with this approach as an initial step to close the gaps.

Second, the item phases out or eliminates support for certain services. This is a step in the right

direction because we must continue to update services eligible for support and focus foremost on

broadband and connectivity. E-rate funds are finite so funding should be directed only to those services

that are enablers of a robust broadband infrastructure.

But when we make changes, no matter how sound, there are impacts to stakeholders and I was

concerned about the effect these changes would have on our most vulnerable schools and libraries, which

serve high poverty areas where buildings are often old and budgets are almost always tight. I wondered if

they would they have enough time to adjust because abrupt, significant changes could bring them

disproportionate harm and result in districts cutting teachers or other essential services.

Staff’s projections indicate that, over the next two years, the new funding for WiFi should more

than offset the reductions in voice and legacy services for these schools and libraries. The WiFi support

in Category Two will largely be new funding for these learning centers and will enable the purchase of

high quality WiFi on par with our country’s most wealthy school districts. After two years, the Bureau

will report on the impact of the phase down of voice services to help ensure that these projections are


Third, the Order significantly increases transparency, which is good, and will not only help the

FCC but also schools and libraries. Learning centers will be able to compare their prices to what their

neighbors receive and question if and why their rates, differ. This will provide us with useful data and

help us to monitor the program as we make sure that each dollar going to E-rate is maximized.

Fourth, the item takes initial steps to streamline and reduce administrative burdens and leaves

room for us to evaluate and introduce additional steps.

But the promise of robust WiFi will only become a reality if schools and libraries have adequate

connectivity to their buildings. In the beginning, I must admit I was concerned that WiFi connectivity

could negatively impact the Priority One (now Category One) funding base, but the item makes clear that

the Category Two funding for WiFi will not be prioritized over the funding for Category One support.

However, I do not believe this change alone is quite enough. The staff analysis shared with my

office indicates that only 20 percent of our nation’s libraries have fiber. And, while I will admit that we

may need more data, and perhaps not all libraries need fiber, I certainly believe that that more than 20

percent of our libraries are in need of such capacity. The number of schools that have fiber is

significantly higher but I am afraid even those numbers are not ideal.

So our work is not done and we will continue to contemplate how to close these gaps and ensure

that all schools and libraries have affordable access to the connectivity to and within their buildings.

Now I end as I began asking rhetorically, why are we here?

We are here because there are a

number of positive directives in this Order that will help our children and our communities, and, as

Benjamin Franklin said, “An investment in knowledge pays the best interest.”

So, thank you, Mr. Chairman, for working with my office to address our key concerns. Thank

you, Commissioner Rosenworcel, for your passionate advocacy that goes back to your days as a staffer on

the Hill. And, many thanks, of course, goes to the incredibly dedicated and overworked staff of the

Wireline Competition Bureau, the Office of Managing Director, the Office of Strategic Planning & Policy


There are too many to name but I wish to thank Jonathan Chambers, Jon Wilkins, Trent

Harkrader, Lisa Hone, my law clerks, Adrian Peguese and Laura Arcadipane, and last but certainly not

least, to my fatigued but ever dedicated wireline adviser, Rebekah Goodheart, I thank you for your advice,

wise counsel, and dedication to this agency’s mission and for the people we serve.


Note: We are currently transitioning our documents into web compatible formats for easier reading. We have done our best to supply this content to you in a presentable form, but there may be some formatting issues while we improve the technology. The original version of the document is available as a PDF, , or as plain text.


You are leaving the FCC website

You are about to leave the FCC website and visit a third-party, non-governmental website that the FCC does not maintain or control. The FCC does not endorse any product or service, and is not responsible for, nor can it guarantee the validity or timeliness of the content on the page you are about to visit. Additionally, the privacy policies of this third-party page may differ from those of the FCC.