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E-Rate recommendation

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Released: April 1, 2014

FCC Consumer Advisory Committee Recommendation

Regarding Improving the E-rate Program

We recommend that the FCC improve and modernize the E-rate program for the 21st Century.
We make this recommendation in light of the Chairman’s recent statements regarding the need
to improve the E-rate program and its requests for comment on the subject, as well as the
overall goal of the administration to improve access to broadband internet for our nation’s
students and communities.
We recommend the FCC include the following priorities in its efforts to improve the E-rate
program and promote more efficient use of E-rate funds:

General priorities

1. Broadband connectivity for schools and libraries should be a priority. Demand for much
higher speeds has increased rapidly over the last several years and will continue to
grow. Schools and communities must be provided with a framework that empowers a
range of options to invest in broadband.
2. E-rate funding should be distributed in a way that promotes fair and equitable service
and adequate speeds to schools and libraries of various sizes and in various locations.
3. The E-rate program must ensure that schools and libraries are not only connected to the
internet, but also assist in the purchase of essential equipment to spread that
connectivity throughout the schools and libraries and beyond.
4. The FCC should consider whether Priority 2 funding adequately addresses the unique
needs of rural communities and smaller schools, as well as the changing educational
environment, where learning does not stop at the end of the school day or when the
student leaves the campus.
5. Do not tie funding to specific educational outcomes. Funding based on educational
outcomes has the potential to further the digital divide and deepen the gap in the
effectiveness of our schools.

Process-oriented priorities

6. Data collection and monitoring of the E-rate program should be improved. This process
starts with simpler, better designed E-rate application forms. Better data can help
improve the efficiency of allocation of E-rate funds, identify needs, and promote greater
transparency about the services and network speeds in schools and libraries.

7. Implement an electronic filing system. An electronic filing system would both streamline
and centralize the application process by making all forms electronically accessible and
automating what is an otherwise tedious process.
8. Simplify the application and disbursement processes for E-rate applicants and
customers. For instance, the FCC could create a Form 471EZ to save time in the
application process as well as the reviewing process; and consider eliminating the Form
470 requirement altogether.
9. Enhance predictability of funding. The filing window dates have shifted each year since
the program’s inception. There should be a set permanent and stable annual filing date
for applications. Then, schools can knowingly set aside the resources, manpower, and
time necessary to file the applications in an orderly fashion, while limiting filing deadline
waiver requests.
10. Allow multi-year applications, such as three-year Form 471 applications. By allowing
applicants to plan more than one year in advance, they will be able to pursue long-term
networking plans based on stable, predictable funding. This would increase the
utilization rate and should cut back on waste and hasty, short-term solutions.
E-rate requests in 2012 and 2013 greatly exceeded the $2.25 billion cap, doing so by nearly
double in 2013. In addition to making reforms to the program to ensure E-rate funds are spent
effectively, the FCC should closely monitor and determine the appropriate level of funding to the
E-rate program necessary to bring schools and libraries into the 21st century and remain
internationally competitive in an evolving educational environment.
Adopted: March 28, 2014
Respectfully submitted:
Debra R. Berlyn, Chairperson
FCC Consumer Advisory Committee

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