Focused Comment Sought on E-rate Modernization
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
TTY: 1-888-835-5322DA 14-308
Released: March 6, 2014
WIRELINE COMPETITION BUREAU SEEKS
FOCUSED COMMENT ON E-RATE MODERNIZATION
WC Docket No. 13-184
Comment Date: April 7, 2014
Reply Comment Date: April 21, 2014
In this Public Notice, the Wireline Competition Bureau (Bureau) seeks focused comment
on three issues raised in the E-rate Modernization NPRM that merit further inquiry as the Commission
moves towards modernizing the E-rate program to meet schools’ and libraries’ broadband connectivity
needs. The E-rate Modernization NPRM sought broad comment on and proposed three goals for the
program: (1) ensuring that schools and libraries have affordable access to 21st Century broadband that
supports digital learning; (2) maximizing the cost-effectiveness of E-rate funds; and (3) streamlining the
administration of the program.1 The Commission has received more than 1,500 comments and ex parte
filings in response to the E-rate Modernization NPRM including numerous comments from individual
educators and school administrators; school districts and consortia; librarians and library systems; E-rate
vendors and educational content providers; and other interested public and private organizations.
The record in this proceeding demonstrates overwhelming agreement among stakeholders
that the E-rate program has been a crucial part of helping our nation’s schools and libraries connect to the
Internet.2 The record also shows a strong commitment to ensuring that the E-rate program quickly evolve
to meet the ever-growing need for high-capacity broadband so our students and communities have access
1 Modernizing the E-rate Program for Schools and Libraries, WC Docket No. 13-184, Notice of Proposed
Rulemaking, 28 FCC Rcd 11304 (2013) (E-rate Modernization NPRM).
2 See, e.g., Comments of the AASA and AESA, WC Docket No. 13-184, at 2 (filed Aug. 27, 2013) (AASA and
AESA Comments); Comments of the American Library Association, WC Docket No. 13-184, at 2 (filed Sept. 16,
2013) (ALA Comments); Comments of National Association of State Boards of Education, WC Docket No. 13-184,
at 1 (filed Sept. 16, 2013); Comments of National Association of Secondary School Principals, WC Docket No. 13-
184, at 2-3 (filed Sept. 16, 2013); Comments of Schools, Health & Libraries Broadband (SHLB) Coalition, WC
Docket No. 13-184, at 3 (filed September 16, 2013) (SHLB Comments); Comments of State E-Rate Coordinators
Alliance, WC Docket No. 13-184, at 3 (filed Sept. 16, 2013) (SECA Comments); Comments of Verizon and
Verizon Wireless, WC Docket No. 13-184, at 1 (filed Sept. 16, 2013) (Verizon Comments); Reply Comments of the
Urban Libraries Council, WC Docket No. 13-184, at summary (filed Nov. 8, 2013) (ULC Reply Comments);
Comments of the International Society for Technology in Education, WC Docket No. 13-184, at 3 (filed Nov. 8,
2013) (ISTE Comments); Comments of Education & Libraries Networks Coalition, WC Docket No. 13-184, at 3
(filed Sept. 16, 2013) (EdLiNC Comments).
to 21st Century educational tools.3 The record is replete with support and suggestions for how to meet the
goals for the E-rate program proposed in the E-rate Modernization NPRM.
Based on the extensive input the Commission has received, it appears that meeting the
Commission’s proposed goals for the E-rate program will require that, in the near term, the program focus
on providing the support necessary to ensure schools and libraries can afford high-speed connectivity to
and within schools and libraries, even as the Commission develops a long-term approach that allows
applicants to scale up capacity while driving down costs. More specifically, the record underscores the
importance of providing consistent and broadly available support for the equipment and services needed
to enable high-capacity wireless broadband within schools and libraries;4 greater support, at least in the
short term, for last-mile deployments needed to connect schools and libraries that do not currently have
access to high-speed connections;5 a support methodology that allows applicants to capture the long-term
cost-efficiencies associated with access to scalable, high-speed connections;6 less support for voice
services, as the cost of voice services transition in the long run to the marginal cost of packet-based voice
services provided over high-capacity broadband connections;7 incentives for making cost-effective
3 See, e.g., Comments of Amplify Education, Inc., WC Docket No. 13-184, at 6 (filed Sept. 16, 2013) (Amplify
Comments); Reply Comments of the Digital Promise League of Innovative Schools, WC Docket No. 13-184, at 4-5,
(filed Nov. 18, 2013) (Digital Promise Reply Comments); Comments of the Leading Education by Advancing
Digital (LEAD) Commission, WC Docket No. 13-184, at 6-7 (filed Sept. 16, 2013); Comments of the National
Association of State Utility Consumer Advocates, WC Docket No. 13-184, at 11 (filed Sept. 16, 2013); and SHLB
Comments at 2-3.
4 See, e.g., EdLiNC Comments at 8-9 (testimonials from school districts on how WAPs are becoming increasingly
crucial as schools continue to implement bring your own device and 1:1 technology initiatives); Comments of
EducationSuperHighway, WC Docket No. 13-184, at 7-9 (filed Sept. 16, 2013) (EducationSuperHighway
Comments) (internal networks are as great a constraint on digital learning as the lack of Internet connectivity to the
building); Comments of the Iowa Department of Education, WC Docket No. 13-184, at 5-6 (filed Sept. 16, 2013)
(Iowa Comments) (services and equipment/components are integral to providing connectivity to the device – such as
routers, switches, WAPs, and integral wiring); SECA Comments at 11 (the capability of equipment located inside
schools and libraries to transmit data to students and patrons is an important consideration in modernizing the E-rate
fund); and Comments of Xirrus, Inc., WC Docket No. 13-184, at 2 (filed Sept. 16, 2013) (LAN is the “last leg”
critical for delivering educational applications to students).
5 See, e.g., ALA Comments at 20-21 (the Commission should adopt a short-term program to fund fiber broadband
connectivity to libraries and schools); Comments of AT&T, WC Docket No. 13-184, at 3-4 (filed Sept. 16, 2013)
(AT&T Comments) (the Commission should set aside funds to focus on schools and libraries that do not currently
have broadband services); Reply Comments of the State Library of Kansas, WC Docket No. 13-184, at 2 (filed Oct.
18, 2013) (Kansas State Library Reply Comments) (the Commission should allocate “additional temporary funding
to support the deployment of ‘future proof’ fiber broadband capacity to schools and libraries”);
EducationSuperHighway Comments at 9-12 (the Commission should create a one-time, multi-year investment fund
to provide the capital for the installation of a fiber connection to every school and library); SHLB Comments at 4-5
(the Commission should create a short-term capital investment fund within the E-rate program to support the
deployment of high-capacity broadband to schools and libraries).
6 See, e.g., ALA Comments at 20-21 (upfront deployment costs are the biggest hurdle in creating “future proof”
fiber broadband connectivity); Comments of Merit Networks, WC Docket No. 13-184, at 6 (filed Sept. 16, 2013)
(Merit Comments); Comments of Minority Media and Telecommunications Council, Rainbow Push Coalition, and
the League of United Latin American Citizens, WC Docket No. 13-184, at 5-7 (filed Sept. 16, 2013) (MMTC
Rainbow Comments) (broadband deployment will drive higher speeds and long-term efficiencies); Comments of
Missouri Research and Education Network, WC Docket No. 13-184, at 5-7 (filed Sept. 16, 2013) (MORENet
Comments) (fiber most readily provides the necessary speed and efficiencies).
7 See, e.g., SECA Comments at 22 (all telecommunications services that are exclusively used for voice should no
longer receive the highest priority of funding); Comments of Mississippi Educational Technology Leaders
purchasing decisions, including incentives and opportunities for schools and libraries to benefit from
economies of scale in purchasing supported services;8 and as much administrative simplicity as possible,
while protecting against waste, fraud and abuse.9
In light of these themes that emerge from the record, as the Commission seeks to
modernize the E-rate program, there are three issues raised in the E-rate Modernization NPRM that merit
further focused inquiry at this time: (1) how best to focus E-rate funds on high-capacity broadband,
especially high-speed Wi-Fi and internal connections;10 (2) whether and how the Commission should
begin to phase down or phase out support for traditional voice services in order to focus more funding on
broadband;11 and (3) whether there are demonstration projects or experiments that the Commission should
authorize as part of the E-rate program that would help the Commission test new, innovative ways to
maximize cost-effective purchasing in the E-rate program.12 We seek further comment on how the issues
below relate to the goals for the E-rate program that the Commission proposed in the E-rate
Modernization NPRM and how they comport with relevant statutory requirements.
At the same time, the Commission continues to evaluate all of the input received in
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Association Comments, WC Docket No. 13-184, at 11 (filed Sept. 16, 2013) (METLA Comments) (voice and other
services that do not focus on providing adequate bandwidth to schools and classrooms should be removed from the
program within three to five years); Comments of Illinois Department of Central Management Services, WC Docket
No. 13-184, at 9-10 (filed Sept. 16, 2013) (Illinois CMS Comments) (recognizing voice service as an application
that can be delivered over broadband platforms and that funding for applications should be phased out in order to
direct funding towards high capacity broadband to and within schools); Comments of Weslaco Independent School
District, WC Docket No. 13-184, at 8 (filed Sept. 16, 2013) (Weslaco ISD Comments) (supporting a phase out of
voice services); Reply Comments of Education Coalition, WC Docket No. 13-184, at 5-6 (filed Nov. 8, 2013) (EdCo
Reply Comments) (supports the transition from a voice-focused E-rate program to a broadband-centric enabler of
digital learning as soon as possible); Comments of American Cable Association, WC Docket No. 13-184, at 12
(filed Sept. 16, 2013) (supports limiting funding for voice communications); Comments of State of Alaska
Department of Education and Early Development and the Alaska State Library, WC Docket No. 13-184, at 7-8
(filed Sept. 16, 2013) (Alaska EED and Alaska State Library Comments) (supporting the phase out of voice
services); Comments of CSM, Inc., WC Docket No. 13-184, at 12 (filed Sept. 16, 2013) (CSM Comments)
(Commission can streamline program by eliminating support for voice); Comments of GCI, Inc., WC Docket No.
13-184, at 14 (filed Sept. 16, 2013) (GCI Comments); Comments of Communications Workers of America, WC
Docket No. 13-184, at 4 (filed Sept. 16, 2013) (supporting phase down for non-broadband services such as voice
8 See, e.g., Comments of Alliance for Excellent Education, WC Docket No. 13-184, at 9 (filed Sept. 16, 2013)
(supporting more bulk purchasing); Comments of Education Coalition, WC Docket No. 13-184, at 19 (filed Sept.
16, 2013); Comments of Friday Institute for Educational Innovation, North Carolina State University, Raleigh,
North Carolina, WC Docket No. 13-184, at 5 (filed Sept. 16, 2013) (Friday Institute Comments) (noting that
consortia procurement and central management is the only effective way to leverage economies of scale and contain
costs); Comments of Illinois Fiber Resources Group, WC Docket No. 13-184, at 5, 9 (filed Sept. 13, 2013) (iFiber
Comments) (agrees with the concept of encouraging consortium purchasing and ways to achieve economies of
scale); Comments of Imperial County Office of Education/ California K12 High Speed Network, WC Docket No.
13-184, at 18 (filed Sept. 16, 2013) (K12HSN Comments) (Commission should encourage applicants to utilize
consortium applications to build economies of scale).
9 See, e.g., Reply Comments of Bill and Melinda Gates Foundation, WC Docket No. 13-184, at 5 (filed Oct. 24,
2013) (Gates Reply Comments); Comments of Hewlett-Packard Company, WC Docket No. 13-184, at 17 (filed
Sept. 16, 2013); Comments of National Association of Federally Impacted Schools, WC Docket No. 13-184, at 2
(filed Sept. 16, 2013); Kansas State Library Reply Comments at 2; Verizon Comments at 19.
10 E-rate Modernization NPRM, 28 FCC Rcd at 11325-30, paras. 65-89.
11 Id. at 11331-32, para. 95.
12 Id. at 11356-57, para. 198.
response to the E-rate Modernization NPRM. The issues we raise in this Public Notice do not define the
full universe of possible changes the Commission could make in an order modernizing the E-rate
FOCUSED FUNDING FOR HIGH-CAPACITY BROADBAND6.
Commenters to this proceeding have made clear the importance of focusing E-rate
support on high-speed connectivity to and within schools and libraries.13 As educational technology has
improved in recent years, equipment and cabling used to deploy the interior pieces of broadband networks
have become increasingly important, yet the E-rate program has provided less support and funded fewer
applicants seeking support for such internal connections. Numerous commenters have identified support
for internal connections as one of the program areas where modernization is most urgent and most
important. Accordingly, in this section we ask about methods to improve this funding going forward.
We also take this opportunity to ask about improvements to the existing priority one funding system for
last-mile deployments for high-capacity broadband.
In seeking further comment on how best to focus E-rate funding on high-capacity
broadband, we note that an initial review by Commission staff has found that the Commission can free up
an additional $2 billion over the next two years to help support broadband networks in our nation’s
schools and libraries, offering an opportunity to assess better ways to prioritize and distribute program
funding at support levels higher than the current program cap. We seek comment on how best to use such
additional funds to support the Commission’s efforts to provide high-capacity broadband within and to
schools and libraries, as described in more detail below.
Broadband Deployment within Schools and Libraries8.
Stakeholders in this proceeding contend that the deployment of equipment inside school
and library facilities is as essential to comprehensive broadband service at a given location as the high-
speed connectivity to that facility.14 For example, Wi-Fi has transformed computing and education,
creating the possibility of one-to-one learning in classrooms and libraries, and freeing desks and work
stations from wired connections.15 A survey of school district leaders conducted by the Consortium for
School Networking (CoSN) and Market Data Retrieval in 2013, however, showed that 57 percent of
district leaders do not believe that their schools’ wireless networks have the capacity to handle a one-to-
one student-to-device deployment.16
Internal connections essential to extend broadband throughout schools and libraries are
currently eligible for support in the E-rate program as priority two services. However, some commenters
have expressed concern because, in most funding years, there have only been sufficient funds to provide
priority two support to schools and libraries in the highest bands of the discount matrix.17 Commenters
13 See, e.g., Comments of Comcast Corporation, WC Docket No. 13-184, at 5 (filed Sept. 16, 2013) (Comcast
Comments); EducationSuperHighway Comments at 7-8; Iowa Comments at 5; AT&T Comments at 4.
14 See, e.g., Reply Comments of Cisco Systems, Inc., WC Docket No. 13-184, at 1-3 (filed Nov. 8, 2013); ISTE
Comments at 10-11; Comment of TV Band Services, WC Docket No. 13-184, at 2 (filed Sept. 12, 2013) (TV Band
Comments); ULC Reply Comments at 14.
15 See, e.g., Digital Promise Reply Comments at 3 (High-speed Wi-Fi is needed for every classroom);
EducationSuperHighway Comments at 11 (Wi-Fi has transformed computing).
16 See Reply Comments of Consortium for School Networking, WC Docket No. 13-184, at 3 (filed Nov. 6, 2013)
(CoSN Reply Comments).
17 See, e.g., AT&T Comments at 3-4 (many E-rate applicants have never received priority two funding and must find
alternative ways to pay for this equipment or go without); Comments of E-Rate Reform Coalition, WC Docket No.
13-184, at 4 (filed Sept. 16, 2013) (E-Rate Reform Coalition Comments) (allocating priority two funds is on the
generally agree that the rule that the Commission adopted limiting any school or library to two years of
priority two support in every five year period (the two-in-five rule) does not appear to have achieved its
intended goal of substantially spreading the available funds.18 Moreover, as demand for priority one
funding continues to grow, the ability to provide any priority two support is an increasing challenge.
Therefore, to address the need for funding for the services and equipment necessary to
ensure high-capacity broadband within schools and libraries, we seek comment on whether the
Commission should change the current priority two funding category (including no longer supporting
legacy services that are currently eligible for priority two funding), by allocating annually a set amount of
E-rate funds to provide schools and libraries with funding for LANs and Wi-Fi networks, which are
essential to ensuring high-capacity broadband reaches students and library patrons.
Scope of Services to Be Funded11.
Under this approach, only equipment and supporting software that is essential to getting
high-capacity broadband from the building’s front door to the computer, tablet, or other learning devices
in schools and libraries would be eligible for internal connection support. We seek comment on what
equipment is essential for such purposes. Some commenters have suggested that such equipment includes
internal wiring, switches and routers, wireless access points, and the software supporting these
components.19 We seek comment on whether these are the right categories of equipment and software to
fund for this purpose.
Other commenters have suggested other technology that improves the efficiency of the
broadband networks and should therefore also receive E-rate support. For example, several commenters
have argued that E-rate should support caching through content servers because caching can allow
schools to reduce their broadband demand by as much as half.20 Another commenter noted that slow
firewall processing, outdated content filtering, and other similar internal network problems create
significant speed bottlenecks on school and library networks.21 We now 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?
Access to Funding13.
The Commission has acknowledged that under the current system only a small
percentage of E-rate recipients receive the bulk of the internal connection funding.22 We seek comment
on ways to provide more widespread access to funding for internal connections in order to enable schools
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verge of ending; demand for priority one has increased to 116 percent of cap in FY2013); Comments of Funds for
Learning, LLC, WC Docket No. 13-184, at 9 (filed Sept. 16, 2013) (FFL Comments) (applicants know there will be
no priority two funds available for them); SECA Comments at 7-8 (experienced applicants understand the futility of
applying for priority two funding unless they have a relatively high discount).
18 See, e.g., Comments of E-Rate Central, WC Docket No. 13-184, at 6 (filed Sept. 16, 2013) (E-Rate Central
Comments) (the two-in-five rule has proved ineffective and complicated and should be eliminated).
19 See, e.g., Comcast Comments at 14-15; SECA Comments at 13; Comments of CenturyLink, WC Docket No. 13-
184, at 10 (filed Sept. 16, 2013) (CenturyLink Comments).
20 See, e.g., Amplify Comments at 11; Comcast Comments at 25 (E-rate program should provide support for caching
services); Comments of Cisco Systems, Inc., WC Docket No. 13-184, at Exhibit A at 5 (filed Sept. 16, 2013);
Comments of Education Networks of America, WC Docket No. 13-184, at 26-27 (filed Sept. 16, 2013); TV Band
Comments at 2.
21 See EducationSuperHighway Comments at 8. See also ULC Reply Comments at 18 (the Commission should
provide support for network security features).
22 E-rate Modernization NPRM, 28 FCC Rcd at 11337, para. 118.
and libraries nationwide to take advantage of high-capacity broadband to their buildings with robust
internal networks. We seek particular comment on three potential ways to prioritize applications for
deployment costs in the event that the demand for internal connection funds exceeds availability.
Five-Year Upgrade Cycle14.
Consistent with the method used to prioritize priority two funding today, the Commission
could prioritize funding by discount level, with rotating eligibility to provide as many schools and
libraries as possible access to funding over a five-year upgrade cycle.23 Information in the record
demonstrates that basic Wi-Fi and LAN equipment has a useable lifespan of five to seven years.24 Given
this information, 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.
If the Commission were to adopt a one-in-five rule to replace the current two-in-five rule,
how much funding would be needed to ensure that funds were available to meet the needs of all eligible
schools and libraries? Would the Commission need to front-load support for eligible internal connections
in the first funding years to meet the existing needs of schools and libraries? Is five years the right
amount of time for such a funding cycle?25 If the Commission were to adopt this 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 buildings?
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? Should it for example,
prioritize funding for applicants within a discount level by giving preference to the applicants with the
highest percentage of students receiving free and reduced school lunches?26
Alternatively, 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. This approach is consistent with one proposed by the State E-rate
23 This approach is similar to one proposed by the State E-rate Coordinators Alliance in their June 2013 White
Paper. See Letter from Gary Rawson, State E-rate Coordinators’ Alliance, to Marlene H. Dortch, Secretary, Federal
Communications Commission, CC Docket No. 02-6, at 11-13 (filed Jun. 24, 2013) (attaching SECA’s
“Recommendations for E-rate Reform 2.0”) (SECA June 2013 White Paper). A number of commenters support this
general approach. See, e.g., Merit Comments at 8; Reply Comments of Nebraska Department of Education, WC
Docket No. 13-184, at 2 (filed Oct. 17, 2013); Comments of State of Nebraska, Office of the Chief Information
Officer, WC Docket No. 13-184, at 9 (filed Sept. 16, 2013); Reply Comments of State Consortia Group, WC Docket
No. 13-184, at 16 (filed Nov. 20, 2013) (SCG Reply Comments); Comments of South Dakota Department of
Education and Bureau of Information and Telecommunications, WC Docket No. 13-184, at 15-17 (filed Sept. 16,
24 See EducationSuperHighway Comments at 13, 21-22 (recommending that E-rate support LAN/Wi-Fi upgrades on
a five- to seven-year timeline); SECA Comments at 9-10 (citing a 2005 article by NetworkWorld stating that these
switches have an average life of five years).
25 We recognize that, to the extent we can drive down costs for eligible internal connections, we will reduce the
amount of funding needed to support high-capacity broadband in our schools and libraries. See infra Section I.C.
(seeking comment on ways to encourage cost-effective purchasing).
26 A 90 percent discount is available to the range of schools and libraries with between 75 percent and 100 percent
of students eligible for free or reduced price school lunch. Under this approach, for example, a school with 95
percent of its students eligible for free or reduced price school lunch could be prioritized ahead of a school with 85
Coordinators Alliance (SECA) and supported by other commenters.27 This approach would ensure that
all applicants are able to receive funding over time, but once they receive funding, applicants could not be
certain about when they might next be eligible for internal connections funding. We seek comment on
this tradeoff. If the Commission were to adopt this approach, applicants could have an incentive to inflate
their original requests in their first year of eligibility. What safeguards should we adopt to address this
If the Commission were to use available funds to front-load support for eligible internal
connections in funding years 2015 and 2016, would this obviate some of the drawbacks to this approach?
If so, how much support should the Commission provide in funding years 2015 and 2016, and how much
should it provide annually after that to ensure all schools and libraries have robust internal connections?
If the Commission were to adopt this approach, 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
If the Commission were to adopt this rotating eligibility approach, how should it
prioritize funding for internal connections? Should it continue to fund eligible applications at the highest
discount level first? 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?28
Annual Allocation for Internal Connections20.
As a third option, 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 methods discussed above. By making at least some
funding available annually for each applicant, this approach would prevent a small number of applicants
from disproportionately using available funding and give all schools and libraries an opportunity to
upgrade at least some of their facilities each year. In the E-rate Modernization NPRM, the Commission
sought comment on a similar allocation of funds that would apply for the entire E-rate program.29 Many
commenters were supportive,30 but many others expressed concern that this funding approach would not
fully capture the diversity of costs faced by applicants across the country.31 Are these concerns mitigated
in the context of internal connections, and particularly LAN and Wi-Fi deployments? In particular, unlike
the costs of broadband connectivity to schools, we expect that the prices of many parts of LAN and Wi-Fi
deployments (e.g., switches, routers, and wireless access points) should vary little based on the
27 See supra n.23.
28 See supra n.26.
29 E-rate Modernization NPRM, 28 FCC Rcd at 11346-48, paras. 149-162.
30 See, e.g., Comments of E-Rate Provider Services, LLC, WC Docket No. 13-184, at 12-13 (filed Sept. 16, 2013)
(EPS Comments); E-Rate Reform Coalition Comments at 9; Comments of Fairfax County Public Schools, WC
Docket No. 13-184, at 2 (filed Sept. 9, 2013); Comments of Barbara Patterson, WC Docket No. 13-184, at 1 (filed
Sept. 16, 2013); Comments of Richmond County Schools, Richmond, Georgia, WC Docket No. 13-184, at 2 (filed
Sept. 16, 2013) (Richmond, GA Comments).
31 See, e.g., AASA and AESA Comments at 4; Comments of Administrative and Technical Consulting, Inc., WC
Docket No. 13-184, at 5 (filed Sept. 16, 2013); Alaska EED and Alaska State Library Comments at 11; GCI
Comments at 12-13; K12HSN Comments at 12-14; METLA Comments at 20; Comments of National Education
Association, WC Docket No. 13-184, at 11 (filed Sept. 16, 2013); Comments of Gray Salada, WC Docket No. 13-
184, at 3 (filed Sept. 17, 2013); E-Rate Central Comments at 6; Comments of the State Consortia Group, WC
Docket No. 13-184, at 3 (filed Sept. 16, 2013); Comments of West Virginia Department of Education, WC Docket
No. 13-184, at 26 (filed Sept. 16, 2013) (WVDE Comments).
geographic location of schools and should generally scale proportionally with the size of the student body.
We seek comment on these expectations.
More specifically, 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.32 That simplified formula is attached as an Attachment. By identifying
available funds and estimating the total pre-discount requests that could be supported with those funds,
the Commission would arrive at an amount to be allocated to each applicant. Applicants would be
entitled to receive funds, applying their usual discounts, towards the purchase of eligible internal
connections up to the pre-discount allocation. Under this approach if, in order to ensure that small
schools and libraries would receive sufficient funding, the Commission were to adopt a per-applicant or
per-building minimum allocation as part of the formula, what should that minimum per-building or per-
applicant support level be? If the Commission adopts such an approach for school applicants, how should
it calculate the annual allocation for libraries?
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.33 We seek
comment on this consideration. Would funding certainty over a multi-year period create new
opportunities for up-front financing to cover equipment upgrades in a given year? We also seek comment
on how to best utilize any remaining funding if some applicants request less than their allocated amount.
Should such funding be made available to increase the allocation to other applicants in the same funding
year? Should it be held over to subsequent funding years? Or should we adopt another approach?
Finally, how should the Commission allow these funds to be spent by the applicants? 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 its district or library
Other Methods to Prioritize Internal Connections Funding23.
Are there variations on the options described above or other methods the Commission
should consider employing to prioritize funding for high-capacity internal connections? Should it, for
example, prioritize projects by the number of students impacted per dollar of funding? Should the
Commission prioritize consortia applications?
Broadband Deployment to Schools and Libraries24.
The record reflects that some schools and libraries do not have access to high-capacity
broadband connections to their buildings, and commenters have suggested that the Commission undertake
a targeted effort to help support deployment of high-capacity, scalable last-mile connections to eligible
schools and libraries that do not currently have access to connections that meet the connectivity goals laid
out in the E-rate Modernization NPRM.34
As explained in the E-rate Modernization NPRM, the E-rate program currently offers
support for broadband construction to schools and libraries.35 However, commenters have explained that
32 See FFL Comments at 26-27; E-rate Reform Coalition Comments at 8-9.
33 See, e.g., Comments of Miami-Dade County Public Schools, WC Docket No. 13-184, at 8-9 (filed Sept. 11, 2013)
(Miami-Dade Comments) (provide flexibility and predictability for planning and purchasing decisions); MMTC
Rainbow Comments at 19 (FFL’s approach would allow schools to create a technology budget and be able to
commit to projects with confidence); Weslaco ISD Comments at 9-10 (funding would be predictable).
34 See supra n.5.
35 E-rate Modernization NPRM, 28 FCC Rcd at 11325-26, paras. 71-73.
even with the current levels of E-rate support, some schools and libraries cannot afford to pay their share
of the cost of deploying last-mile high-capacity broadband.36
Scope of Services to Be Funded26.
In light of the record demonstrating that the costs of one-time construction projects, even
though already supported by the E-rate program, can be cost-prohibitive, 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. We invite stakeholders
to offer examples of projects for which they would seek funding if the Commission adopts such an
approach. Exactly what services should the Commission fund as part of this deployment effort? For
instance, 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?37
In the E-rate Modernization NPRM, the Commission sought comment on how to ensure
that broadband deployment to schools and libraries is done in a way that minimizes the recurring costs for
both applicants and the E-rate program once deployment is complete.38 While the record indicates that
new broadband deployments, once paid for, can dramatically lower recurring costs over time,39 it also
reveals situations where monthly charges have remained high even after new deployments are complete
and costs have been fully recovered. If the Commission does decide to provide some additional support
for the capital costs associated with high-capacity deployment, how can it best ensure that the recurring
costs associated with providing broadband over new connections is affordable for the applicants on a
Should the Commission change the program’s funding methodology as part of this
deployment initiative? Would it be sufficient for the Commission to simply raise the discount rate for all
applicants seeking deployment support by 10 percent or some other percentage? Or would it be better for
the Commission to adopt a flat discount rate for all applicants?40 If so, what should this flat rate be? Are
there some schools and libraries on Tribal lands, or in remote rural areas that cannot afford high-capacity
36 See, e.g., CoSN Reply Comments at 9 (noting that 59 percent of respondents agreed that capital or one-time costs
were a major barrier in increasing bandwidth); Comments of Boston Renaissance Charter Public School, WC
Docket No. 13-184, at 3 (filed Sept. 20, 2013); Reply Comments of FiberTower Corporation, WC Docket No. 13-
184, at 3-5 (filed Nov. 8, 2013) (FiberTower Reply Comments).
37 See, e.g., Reply Comments of the Schools, Health & Libraries Coalition (SHLB), WC Docket No. 13-184, at 7
(filed Nov. 8, 2013) (stating that the Commission should consider a number of technologies including lit fiber, dark
fiber, cable, and wireless); FiberTower Reply Comments at 1 (listing fiber, fixed wireless, and satellite as possible
solutions for broadband deployment); GCI Comments at 7-8 (discussing fixed wireless), Nebraska OCIO Comments
at 8 (discussing fixed wireless); ALA Comments at 12 (fiber connectivity offers the best, long-term way to ensure
that libraries will have adequate and scalable bandwidth); Comcast Comments at 10 (noting that fiber connections
are scalable to 10 Gbps).
38 E-rate Modernization NPRM, 28 FCC Rcd at 11330, paras. 88-89.
39 See, e.g., Letter from John Windhausen, Consultant, The Quilt, to Marlene H. Dortch, Secretary, FCC, WC
Docket No. 13-184, at Attachment B, Slide 18 (filed Jan. 27, 2014) (demonstrating the decrease in recurring costs
from 2012-14 resulting from an upfront investment in fiber in Missouri); Comments of the Health Information
Exchange of Montana, WC Docket No. 13-184, at 4 (filed Sept. 16, 2013) (that new fiber deployments reduced
recurring costs to health anchor institutions in the Rural Health Care program).
40 E-rate Modernization NPRM, 28 FCC Rcd. at 11347, para. 156. We note that in reforming the rural health care
support program, the Commission adopted a flat rate discount for all eligible services. See Rural Health Care
Support Mechanism, WC Docket No. 02-60, Report and Order, 27 FCC Rcd 16678, 16717-18, paras. 83-88 (2012)
(Healthcare Connect Fund Order).
broadband build-out without full support?41 Should the Commission consider full support for all
applicants seeking support for broadband connectivity? While such an approach could encourage
applicants to participate in the program and greatly increase broadband deployment to schools and
libraries, how would the Commission ensure that applicants do not enter into agreements requiring
excessive funding for broadband deployment?
Some commenters have explained that vendors often limit up-front deployment costs and
instead collect the costs over several years as part of the cost of recurring services.42 Are there instances
in which the Commission should authorize increased support for the recurring costs of broadband services
over a period of time instead of, or in addition to, increased support for up-front costs, to the extent those
recurring costs reflect time-limited recovery for capital investment? If so, over how long a period of time
and under what circumstances?
Ensuring Equitable Distribution30.
We also seek comment on how best to distribute support among the applicants for high-
speed connections to schools and libraries. In particular, if the Commission makes some additional
deployment support available to eligible schools and libraries that do not already have access to high-
speed scalable connections available at reasonable prices, how do we identify those schools and
libraries?43 Should we rely on the broadband speed targets identified by the Commission in the E-rate
Modernization NPRM and require applicants for this deployment funding to demonstrate their current
Internet access service does not meet that metric?44 Should we consider future scalability of existing
connections and/or available pricing when identifying eligible schools and libraries? Are there other
methods the Commission should consider to determine the best projects to fund?
We also seek comment on ways to prioritize applications for deployment costs in the
event that the demand for such funds exceeds availability. In the current E-rate program, when available
funds do not meet demand, the applicants with the greatest economic need (i.e., those with the highest
percentage of students that qualify for free and reduced school lunches) are funded first at the 90 percent
discount rate, then funding goes to those applicants eligible for 89 percent discount levels, and so on, until
the available funds are exhausted.45 Eligible libraries receive the discount rate of the school district in
which they are located.46 Should the Commission adopt a similar mechanism for distributing funding for
deployment of high-capacity broadband to eligible schools and libraries?
As an alternative, we seek comment on adopting one or more objective impact and/or
41 See Comments of National Indian Education Association, WC Docket No. 13-184, at 2 (filed Sept. 16, 2013)
(NIEA Comments) (schools and libraries operated by the Bureau of Indian Education, Tribal governments, or those
that predominantly serve Native Americans should be exempt from a matching requirement).
42 See, e.g., EducationSuperHighway Comments at 16; Comments of the Quilt, WC Docket No. 13-184, at 6, 8
(filed Sept. 16, 2013) (Quilt Comments).
43 See, e.g., Comments of the National Cable & Telecommunications Association, WC Docket No. 13-184, at 12
(filed Sept. 16, 2013) (recommending that the Commission only authorize fiber buildouts for schools and libraries
when (1) there are no commercial alternatives, (2) there are no more cost-effective methods to receive high-speed
broadband and (3) the applicant has the expertise to handle the operational burden of operating and maintaining a
fiber network); CenturyLink Comments at 6 (supporting deployment using fiber owned by service providers rather
than having schools and libraries dedicate resources to their own fiber IRUs or leases).
44 See E-rate Modernization NPRM, 28 FCC Rcd at 11113-15, paras. 22-27.
45 See 47 C.F.R. § 54.507(g)(1); see also USAC, Eligible Services Overview,
http://www.usac.org/sl/applicants/beforeyoubegin/eligible-services/default.aspx (last visited Mar. 5, 2014).
46 See 47 C.F.R. § 54.505(b)(2).
efficiency metrics to prioritize applications. For example, school applicants could be required to calculate
the total number of students currently in buildings without infrastructure capable of meeting Commission-
adopted speed goals. Those schools would then be upgraded to scalable, high-speed connections with E-
rate support and applications could be scored based on the total cost per-student served. Should the
Commission also consider prioritizing upgrades that do not increase the speed available to applicants, but
dramatically reduce recurring costs following new investment (for example, if applicants sought to
upgrade from Internet access using two T3s to a single 100 Mbps metro Ethernet circuit, or to purchase
WAN upgrades that allowed them to buy Internet access at a lower-priced point-of-presence)? If so, how
much weight should be given to particular levels of reductions in recurring costs? If the Commission
adopted multiple objective impact and/or efficiency metrics, how should they be evaluated together? For
example, how should applications that reduce recurring costs be scored against those that include speed
upgrades? Are there other methods the Commission could employ to prioritize funding for up-front
deployment costs in the event demand exceeds availability?
Within the existing priority one system, applicants can receive E-rate support for some
installation and special construction charges, but the cost of large projects must be prorated over three
years or more.47 This limit may disproportionately harm rural and other applicants that face the largest
deployment costs, especially because there are no exceptions for rural deployments or other unique
circumstances. Would adopting one of the prioritization approaches above for deployment funding allow
the Commission to relax this limit?
Encouraging Cost-Effective Purchasing34.
As the Commission considers how to focus E-rate funding on high-capacity connections
to and within schools and libraries, are there additional steps the Commission can take to help ensure
efficient use of E-rate funds spent on broadband projects? Below we seek comment on three possible
ways to encourage cost-effective purchasing. We also invite commenters to offer other methods to
encourage cost-effective E-rate purchasing.
Consortium purchasing and bulk buying. In the E-rate Modernization NPRM, the
Commission sought comment on encouraging consortia and other bulk purchasing programs.48 If the
Commission moves to support a more limited set of equipment and services for high-capacity internal
connections, is there an opportunity for E-rate applicants to drive down prices of the products necessary
for Wi-Fi and LAN connectivity through consortium purchasing or other forms of bulk buying? If so,
what steps can the Commission take to encourage cost-effective consortia or other bulk purchasing of
such products? Likewise, if the Commission focuses some additional funding on high-capacity
broadband deployment to schools and libraries currently unserved by broadband services, should the
Commission encourage the formation of consortia to encourage providers to offer affordable services to
groups of schools and/or libraries? If so, what steps can the Commission take to encourage the formation
of consortia that have the tools to engage in cost-effective purchasing? Are there steps the Commission
47 In a 2000 order, the Commission determined that applicants must amortize over several years non-recurring
charges that vastly exceed the monthly recurring charges. See Request for Review by Brooklyn Public Library,
Federal-State Joint Board on Universal Service, Changes to the Board of Directors of the National Exchange
Carrier Association, Inc., CC Docket Nos. 96-45 and 97-21, Order, 15 FCC Rcd 18598, 18606-07, para. 20 (2000)
(Brooklyn Order) (allowing the Brooklyn Public Library to receive funding for non-recurring charges associated
with capital investment in an amount equal to the investment prorated equally over a term of at least three years in
duration, and requiring that it recover no more than one-third of the total non-recurring charges in one funding year).
Currently, when applicants enter a multi-year contract and the upfront or non-recurring charge is $500,000 or more,
USAC requires the total charge to be prorated evenly over a period of at least three years. See USAC, Schools and
Libraries, Wide Area Networks, Capital Investment Costs,
http://www.usac.org/sl/applicants/beforeyoubegin/eligible-services/wan.aspx (last visited Mar. 5, 2014).
48 E-rate Modernization NPRM, 28 FCC Rcd at 11346-48, paras. 149-162.
can take to encourage currently successful consortia to add members, particularly eligible entities that
currently lack the kind of purchasing power enjoyed by consortia? How can the Commission help ensure
that the formation of such consortia does not unfairly disadvantage smaller providers that may be efficient
local providers of high-capacity services?49
Technology planning. Another possible approach to ensuring cost-effective purchasing
of broadband services is to require technology planning. The Commission eliminated technology plan
requirements for E-rate applicants seeking only support for priority one services in order to simplify the
application process for schools and libraries.50 The E-rate Modernization NPRM sought comment on
whether there were lessons learned from current and previous technology plan requirements and whether
these requirements should be re-instituted.51 We now ask more specifically whether the Commission
should 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.
Data collection and transparency. In the E-rate Modernization NPRM, the Commission
sought comment on how best to collect data on the speed and quality of school and library connections.52
The Commission also sought comment on what data to collect to support the proposed goal of
maximizing cost-effective purchasing.53 As the Commission considers how best to provide support for
broadband deployment within and to schools and libraries, we renew our request for comment on those
data issues and on whether price transparency for E-rate supported services will help drive down those
Streamlining the Administrative Process38.
As the Commission considers how best to support high-capacity broadband connections
to and within schools and libraries, consistent with the Commission’s proposed third goal of streamlining
the administration of the E-rate program,54 we seek additional comment on how best to minimize the
administrative burdens and overhead associated with applying for and receiving such support. Are there
for example, simple changes the Commission can make to the E-rate information collections that will ease
the administrative burdens on E-rate applicants and vendors that take advantage of a modernized E-rate
Are there changes to the invoicing deadlines the Commission should adopt to take into
account a focus on broadband deployment? Under the current program, all recurring services must be
completed during the funding year and invoices must be submitted no later than 120 days after the last
day to receive service or 120 days after the FCC Form 486 Notification Letter date, whichever is later.55
49 See Reply Comments of NTCA – The Rural Broadband Association and The Western Telecommunications
Alliance, WC Docket No. 13-184, at 16-17 (filed Nov. 8, 2013) (NTCA Reply Comments) (noting that the emphasis
on consortia could disadvantage a smaller carrier that is best suited to serve a part of a consortium, but not the entire
50 Schools and Libraries Universal Service Support Mechanism et al., CC Docket No. 02-6 et al., Sixth Report and
Order, 25 FCC Rcd 18762, 18789-91, paras. 58-63 (2010).
51 E-rate Modernization NPRM, 28 FCC Rcd at 11361, para. 218.
52 Id. at 11315, para. 30.
53 Id. at 11318, para. 43.
54 Id. at 11310, 11318-20, paras. 12, 45-51.
55 See 47 C.F.R. § 54.507(d); see also USAC, Schools and Libraries, Invoicing, http://www.usac.org/sl/service-
providers/step05/default.aspx (last visited Mar. 5, 2014).
Non-recurring charges for broadband projects, such as build-outs and special construction, must be
completed by September 30 following the close of the funding year, with some exceptions.56 Because of
the possibility that complex projects could take additional time beyond the funding year, should new
deployment be given 18 months to be completed and invoiced from the date the funds are committed?
Should complex internal connections projects be given 18 months to be completed and invoiced from the
date the funds are committed? Could invoicing deadlines be synchronized with other federal funding
programs to reduce complexity for applicants?57 Should applicants be allowed any extension of their
project deadlines? If so, under what circumstances? Currently, special construction or build-outs can
commence six months before the start of the funding year.58 Should the Commission give applicants
additional time before the funding year to begin special construction to schools and libraries, or to begin
internal infrastructure projects?
REDUCED SUPPORT FOR VOICE SERVICES40.
In the E-rate Modernization NPRM, the Commission proposed to refocus the E-rate
program on supporting high-capacity broadband connectivity to and within schools and libraries and
recognized that it needed to confront the prospect of eliminating or reducing support for voice and other
legacy services that do not advance the deployment of broadband.59 As schools and libraries increasingly
transition to voice over Internet protocol (VoIP) services, we expect the price they pay for voice services
to decrease. While many commenters expressed support for a transition from funding voice telephony
services, many such commenters also stressed the importance of phasing out support for voice services
over a number of years, with several specifically endorsing a three- to five-year phase-out period.60
Below we seek comment on several specific ways for the Commission to transition away from support for
56 47 C.F.R. § 54.507(d) (setting out September 30 deadline for non-recurring services with four exceptions, such as
for commitment letters that are issued after March 1 of a funding year).
57 Recipients of federal Title I money may spend down money in the funding cycle for which the funds were
granted or a subsequent funding cycle. See 20 U.S.C. § 1225(b). Because of this, districts often work from multiple
budgets at the same time, which creates complexity. See generally American Association of School Administrators,
School Budgets 101, http://www.aasa.org/uploadedFiles/Policy_and_Advocacy/files/SchoolBudgetBriefFINAL.pdf
(last visited Mar. 5, 2014).
58 Currently, while the service start date stays the same, applicants can start installation up to six months prior to
July 1, as long as four conditions are met: the posting of an FCC Form 470; the service must depend on the
installation of the infrastructure; the underlying service may not have a service start date earlier than July 1; and no
invoices can be dated before July 1. See USAC, Schools and Libraries, Advance Installation,
http://www.usac.org/sl/applicants/step06/installation.aspx (last visited Mar. 5, 2014).
59 E-rate Modernization NPRM, 28 FCC Rcd at 11330-36, paras. 90-114.
60 See, e.g., Alaska EED and Alaska State Library Comments at 7 (recommending a phase out of support for voice
service beginning in funding year 2015 which would require applicants to pay an increasing percentage each year
through funding year 2018, until they are carrying the full burden of the service without E-rate support); ALA
Comments at 15 (stating that support for voice services should be phased out gradually over a period of five years);
Comments of Pennsylvania Association of Intermediate Units (PAIU), WC Docket No. 13-184, at 4 (filed Sept. 16,
2013) (supporting funding voice telephony services at a flat 40 percent discount and continued funding, at least
through Funding Year 2017); METLA Comments at 11 (stating that the primary focus of the E-rate program is to
get broadband into the classroom and that other services, such as voice, that do not accomplish this should be phased
out over the next three to five years); Illinois CMS Comments at 12 (recognizing voice service as an application that
can be delivered over broadband platforms and recommending that funding for applications should be phased out);
GCI Comments at 14 (agreeing that the Commission could streamline E-rate by eliminating support for voice
services); Comments of International Association for K-12 Online Learning (iNACOL), WC Docket No. 13-184, at
14 (filed Sept. 16, 2013) (78 percent of iNACOL members surveyed would support the removal of landline
telephone services as an eligible service to expand support for broadband access).
voice services, and we invite commenters to offer other suggestions for how best to redirect E-rate
support from voice to broadband services.
Reduced E-rate Support for Voice Services41.
One way for the Commission to phase out support for voice services would be to
gradually reduce the discount rate applicants receive for voice services. For example, the Commission
could phase out support for voice services by 15 percentage points per year, beginning in funding year
2015, and continue to reduce support for such services by the same amount each year until funding for
voice services is fully phased out in funding year 2020.61 We seek comment on this approach, as well as
any other options for reducing E-rate spending on voice services. A gradual approach to reducing support
for voice services should give schools and libraries time and the incentive to find lower priced solutions,
and could also provide the Commission a period to evaluate whether it should adjust the phase out
schedule. Although such an approach will result in some applicants receiving no support for voice
services prior to funding year 2020, the most economically disadvantaged applicants — i.e. those that are
currently eligible for a 90 percent discount rate — would be eligible for a 75 percent discount on voice
telephony in funding year 2015, a 60 percent discount in funding year 2016, a 45 percent discount in
2017, a 30 percent discount in funding year 2018, and a 15 percent discount in funding year 2019.62
We expect that the diminished availability of E-rate funding for voice services will be
ameliorated by the fact that many applicants have transitioned or will transition to VoIP,63 which is
generally considered to be more cost-efficient than traditional voice services.64 Although some
61 In the E-rate Modernization NPRM, the Commission sought comment on shifting support for voice telephony
services to broadband connectivity and whether this would better serve this proceeding’s proposed priority of
connecting a majority of our nation’s schools and libraries with high-capacity broadband. E-rate Modernization
NPRM, 28 FCC Rcd at 11335, para. 105. The E-rate Modernization NPRM also sought comments on SECA’s June
2013 White Paper recommendation to implement a tiered five-year phase out of E-rate support for
telecommunications that are used only for voice communications, about the potential hardships schools and libraries
would face if voice telephone service was eliminated from the list of supported services, and whether we should
consider any statutory limitations. Id. at 11335-36, paras. 107-110. See also SECA June 2013 White Paper at 6.
62 This is similar to the tiered phase out for voice services suggested by Alaska EED and Alaska State Library in
their comments. Alaska EED and Alaska State Library Comments at 7. They suggest that, for example, beginning
in funding year 2015, applicants pay their discounted amount multiplied by 0.75, pay a discounted amount
multiplied by 0.5 in funding year 2016, pay a discounted amount multiplied by 0.25 in funding year 2017, and that
support for voice would be removed entirely by funding year 2018. Id.
63 In its recent Technology Transitions Order, the Commission recognized that the transition to Session Initiation
Protocol (SIP)/IP [SIP/IP]-based transport and signaling enables an ongoing technological transition at the
application layer. Specifically, providers and third parties are transitioning customers’ services from purpose-built
networks to new applications that can ride over more general broadband transport networks. It also noted that time-
division multiplexed (TDM)-based switched voice services are being replaced in many places by interconnected
VoIP services that rely on SIP/IP networks. See Technology Transitions et al., GN Docket No. 13-5 et al., Order,
Report and Order and Further Notice of Proposed Rulemaking, Report and Order, Order and Further Notice of
Proposed Rulemaking, Proposal for Ongoing Data Initiative, FCC 14-5, para. 17 (rel. Jan. 31, 2014) (Technology
64 In its 2013 ICT Market Review and Forecast, the Telecommunications Industry Association (TIA) states that due
to the increase in broadband penetration, the VoIP market has swelled in recent years, and its advantages over
traditional circuit-switched lines include cost savings and enhanced features that come standard with the service.
See Telecommunications Industry Association’s 2013 ICT Market Review and Forecast, at 3-45 (TIA’s 2013 ICT
Market Review and Forecast). Additionally, it states that enterprise customers experience cost savings with VoIP
not just through the lower price of the service itself, but because of the way it can be provisioned. For example,
business VoIP has evolved into a unified communications system treating all forms of communications, voice, data,
and facsimiles as pieces of data; this reduces infrastructure costs and utilizes the same management tools.
commenters have suggested that the initial costs, including the cost of new handsets, to transition to VoIP
is cost prohibitive for them,65 others indicate that they are embracing this trend.66 Our approach also takes
into consideration that the growth of competitive options for voice services, such as VoIP, should drive
down costs for voice services.67
If the Commission elects to phase out support for voice beginning in funding year 2015,
will schools and libraries have adequate time and resources to make needed adjustments? Commenters
should consider that as the E-rate program increasingly supports high-capacity broadband, applicants may
be eligible for increased levels of support for broadband services to and within schools and libraries.68
Will increased funding for these other types of services assist schools and libraries adjusting to decreasing
levels of E-rate support for voice telephony services?69 Will increased support for high-capacity
broadband networks to and within schools and libraries put applicants in a better position to transition to
VoIP, and would E-rate still be supporting voice services, albeit indirectly, by supporting the
infrastructure and services over which VoIP will ride? Would it be appropriate, therefore, to phase out
support for voice services only once a school or library has gained access to high-capacity broadband? If
so, we seek comment on whether we should adopt different voice phase-out dates on a case-by-case basis
for individual schools or libraries, such as within one year after they have broadband that meets the goals
for high-capacity broadband established in this proceeding.
We also seek comment on whether the entries for telephone services, telephone
components, and interconnected VoIP in the Eligible Services List (ESL) include all of the types of voice
services and components that should be covered by the five year phase out.70 Are there any services in
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Moreover, telephones can be connected wherever there is a broadband connection, making it less costly relocate
staff, and long-distance charges are eliminated between buildings or offices. Id. at 3-51 to 3-52. Also, the enhanced
features that come standard with many VoIP systems, such as conference calling, call forwarding, and caller ID, are
typically charged as add-on fees by the traditional telephone companies. Id. at 3-52. See also Waring, Should Your
Business Move Over to VoIP for Phone Service?, Business 2 Community, Jan. 12. 2014,
http://www.business2community.com/tech-gadgets/business-move-voip-phone-service-0738916 (last visited Feb.
65 See infra n.75.
66 See, e.g., ALA Comments at 15 (recommending a five-year phase out period for most library applicants except for
those located in areas where alternatives to POTS are either not available or cost prohibitive, but that this
“exemption” should be revisited every two years under the assumption that in due course, high-capacity broadband
will be available in all but the most remote areas of the country); Comments of the State of Hawaii, WC Docket No.
13-184, at 9-10 (filed Sept. 16, 2013) (suggesting that the transition from legacy voice services to VoIP is expected
to progress significantly in within five years); Comments of San Diego County Office of Education, WC Docket No.
13-184, at 4 (filed Sept. 13, 2013) (SDCOE Comments) (stating that the convergence of voice and data now allows
for increased efficiencies through VoIP).
67 VoIP currently provides a cost saving to business customers. See TIA’s 2013 ICT Market Review and Forecast,
Telecommunications Industry Association, The Outlook for VoIP, Chapter 3: The Landline Market at 3-56.
Average monthly spending of $64 per month per line in 2012 was less than half of the $142 average for circuit
switched lines. Id.
68 Many applicants that have received priority one support for voice telephone services, have forgone funding
requests for other projects such as internal connections because they have become accustomed to these needs going
unmet due to the high demand on the fund, and current funding prioritization rules. See supra n.17.
69 Currently, internal connections used for the delivery of voice services are supported as priority two eligible
services. Will discontinuing support for those services drive applicants to more cost-effective voice solutions?
70 See USAC, Eligible Services List, at 3, 4-5,
http://www.usac.org/_res/documents/sl/pdf/ESL_archive/EligibleServicesList-2014.pdf 2014 ESL (last visited Mar.
5, 2014) (listing interconnected VoIP, telephone services such as local, long distance, cellular, and Centrex service,
these entries that should be excluded from the phase out? Are there other types of telephone services that
are not specifically listed in the current ESL that should be subject to the phase out? Commenters should
provide details on the specific voice services for which support should be phased out and provide detailed
reasons for why certain services should be included or excluded from the list of targeted voice services.
The Commission may also decide to eliminate voice more quickly or to modify in some
other way the current approach to supporting voice services. Therefore, we also seek comment on a
number of alternative ways to approach funding for voice services, and we invite comment on the
approaches we identify below, as well as variations on or alternatives to any such options.
Elimination of voice support. As an alternative to a phase down of voice support, should
the Commission consider eliminating all support for voice services starting in funding year 2015? Such
an approach would more quickly accomplish the Commission’s goal of transitioning the E-rate program
to supporting high-capacity broadband, but would also result in a more stark loss of support for
applicants. Would it be more appropriate to provide additional time for applicants to make necessary
budgetary changes by eliminating all support for voice services, but in a later funding year?
Lower priority for voice services. In the alternative, we also seek comment on retaining
support for voice services under a lower priority. For example, SECA recommends that the Commission
establish a new priority category for particular services, including voice services, to be funded at a flat 50
percent discount and that all applicants have equal access to the services in this category.71 Would it be
more manageable for applicants to adjust to a larger reduction in funding the first year we implement a
discount reduction for voice services because they know they will continue to receive such funding in
future years?72 If we were to take such an approach, would it encourage applicants to move to more cost-
effective solutions or would we need to take additional steps to encourage such transitions?
Benchmark for VoIP support. As voice communications technologies migrate from
traditional TDM to IP should the Commission encourage this transition for schools and libraries using the
E-rate program? Some commenters suggested that rather than phasing out E-rate support for all voice
services, the Commission should continue to provide support for VoIP solutions.73 A possible middle
ground would be for the Commission to identify inexpensive VoIP solutions for schools and libraries and
use such services as a benchmark for how much support the E-rate program will provide for voice
If the Commission establishes a benchmark support amount, should the benchmark be on
a per-user basis or some other basis? If the Commission establishes a per-user benchmark, how would
applicants establish the number of users they have that provide the basis for the amount of their requested
support? If the Commission establishes a benchmark support amount, should the E-rate program use this
benchmark to support all voice services, regardless of the technology used? Or should the Commission
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and telephone components such as text messaging and directory assistance charges as services eligible for E-rate
71 SECA Comments at 22-24.
72 For example, K12HSN suggests that voice services can be transitioned to a lower priority two category assuming
the category will receive funding based on funds that are available after completing funding of the priority one
category and the funding cap will increase. K12HSN Comments at 10.
73 Comments of Broadcore, Inc., WC Docket No. 13-184, at 1 (filed Sept. 16, 2013); Comments of Carnegie Library
of Pittsburgh, WC Docket No. 13-184, at 7-8 (filed Sept. 16, 2013) (Carnegie Library Comments) (supporting a
tiered phase down of support for voice service only if VoIP service continues to be covered). However, others
argued that E-rate currently encourages applicants to pursue expensive VoIP options involving building and
operating their own systems. See Friday Institute Comments at 6.
use the benchmark derived support amount only to fund VoIP service and phase down support for all
other voice services? Does the transition to VoIP services offer applicants an opportunity to use
consortium purchasing or other forms of bulk buying to drive down the cost of services while ensuring
service quality? If so, what steps can the Commission take to encourage such purchasing?
Other Issues Related to Voice Services50.
As the Commission considers how to treat voice services as part of a modernized E-rate
program, we seek comment on several specific issues relating to the funding of voice services and invite
commenters to raise other issues.
Internal connections. We also seek comment on whether the Commission should end
support for internal connections used for the delivery of voice services which are currently supported as
priority two eligible services.74 Will discontinuing support for the internal connections used to deliver
voice discourage applicants that had been considering a transition to VoIP? If VoIP is the most cost-
effective option for voice services, we seek comment on whether the E-rate program should offer some
short term incentive to applicants to transition to VoIP. Some commenters have already explained in this
proceeding that they are reluctant to switch to VoIP for a variety of reasons.75 Would it be a sufficient
incentive for applicants to transition to VoIP if the E-rate program provided an additional, one-time
discount, such as 10 to 20 percent, to applicants in order to help defray the up-front costs necessary for
the first year of a transition to VoIP?
Rural areas or areas that lack access to broadband. If the Commission decides to
decrease support for voice services, some commenters have suggested that it continue to provide support
for traditional voice services for those schools and libraries in remote rural areas, on Tribal lands, or
elsewhere that lack access to high-capacity broadband and therefore will find it more challenging to adopt
affordable VoIP options.76 For example, Alaska EED and Alaska State Library ask the Commission to
consider extending the eligibility of voice services for locations that rely on satellite Internet service.77
74 See supra para. 10.
75 Some commenters express concern about switching costs. See, e.g., Miami Dade Comments at 6 (explaining that
its existing PBX platforms would be costly to transition to VoIP); Comments of School District of Philadelphia, WC
Docket No. 13-184, at 8 (filed Sept. 16, 2013) (explaining that to take advantage of newer VoIP technology, it
would have to rewire entire schools and purchase a new voice communications system and end-user equipment);
Comments of Clark County School District, WC Docket 13-184, at 6 (filed Sept. 16, 2013) (explaining that many
schools and libraries incur additional voice equipment and licensing costs when transitioning to VoIP). Other
commenters express concern about losing E-rate funding for POTS services dedicated to elevators, alarm systems
and for other safety-related purposes. See, e.g., Reply Comments of the Chicago Public Schools et. al., WC Docket
No. 13-184, at 5 (filed Nov. 8, 2013) (noting that landlines are required for essential safety features such as elevator
car communications in the event of a breakdown and connections of emergency services in the event of a disaster);
Comments of Council of the Great City Schools, WC Docket No. 13-184, at 10 (filed Sept. 16, 2013) (stating that
landline service is necessary for safety plans, emergency systems and telecommunications services for schools);
WVDE Comments at 42 (stating that VoIP systems go down when criminal or weather-related events take out a
network). However, the record indicates that organizations have been able to make successful transitions to VoIP
service. See, e.g., Carnegie Library Comments at 8 (stating “we utilize VoIP exclusively and have found it to not
only be a viable alternative to public-switch service, but actually provides many additional benefits that traditional
phone service cannot easily provide, such as emergency broadcasting, conferencing abilities, ease of use, faster and
more efficient customer service”).
76 Some commenters assert that reducing or eliminating E-rate support for voice telephony should not be applicable
to rural or insular areas. See, e.g., Comments of the State of Arkansas, WC Docket No. 13-184, at 15-16 (filed Sept.
16, 2013); Comments of E-rate Consultants, LLC, WC Docket No. 13-184, at 3 (filed Sept. 16, 2013); EPS
Comments at 7; iFiber Comments at 8.
77 Alaska EED and Alaska State Library Comments at 10.
We seek further comment on such an approach, and specific comment on how, if the Commission adopts
such an exemption, it should determine which applicants should qualify? Would it be sufficient, for
example, to simply require applicants to certify that there are no alternatives to POTS service in their
Above we ask whether we should adopt different voice phase-out dates for individual
schools or libraries, such as within one year after they have the high-capacity broadband that meets the
goals established in this proceeding. Should we adopt this approach for rural schools and libraries, and
require that for rural entities to qualify for an exemption from phase-out, they do not have the high-
capacity broadband meeting the goals laid out in this proceeding?78 Should waivers or exemptions for
those applicants in areas where VoIP is not available also be available for those applicants that can
upgrade to VoIP but choose not to for financial or other reasons? Are there other types of schools and
libraries that have unique needs meriting continued E-rate support for voice services at current levels?
How should we define the areas or circumstances where support for voice service would continue to be
supported under an alternative like this?
Easing Administrative Burdens54.
We seek comment on how best to reduce the administrative burden on E-rate applicants,
regardless of which approach to supporting voice services the Commission takes in modernizing the E-
rate program. If, for example, the Commission decides to phase down or phase out support for voice
services, will calculating the correct amount of support due to applicants be administratively challenging?
If so, what can the Commission do to ease the administrative burdens? Commenters have generally
supported easing the burdens for multi-year contracts for recurring services,79 is that something that
would be particularly useful in this context? Likewise, if the Commission moves to supporting voice
using a per-user cost for VoIP services as a benchmark, are there administrative challenges the
Commission should take into account, and are there things the Commission can do to ease the
administrative burden of such an approach on schools and libraries?
In the E-rate Modernization NPRM, the Commission sought comment on innovative
approaches to encouraging efficiency in the E-rate program.80 Many commenters offered examples for
how new approaches to planning and procuring services might be either (or both) more cost effective or
more administratively efficient.81 At the same time, many commenters argued that local needs vary and
local decision making has been one of the hallmarks of the E-rate program.82 As the Commission
considers how best to meet the high-capacity connectivity needs of schools and libraries cost effectively,
78 Or should the Commission use the speed goals set in other proceedings, such as in Connect America Fund – Phase
II? Connect America Fund, Report and Order, 28 FCC Rcd 15060, 15070, para. 23 (Wireline Comp. Bur. 2013)
(requiring price cap carriers accepting model-based support to certify that 95 percent or more of all peak period
measurements (also referred to as observations) of network round trip latency are at or below 100 milliseconds).
79 See, e.g., CenturyLink Comments at 24; Comcast Comments at 34-35; NIEA Comments at 3; NTCA Reply
Comments at 20; Richmond, GA Comments at 2; SDCOE Comments at 4; Comments of the Wireless Internet
Service Providers Association, WC Docket No. 13-184, at 6 (filed Sept. 16, 2013); Quilt Comments at 2-3, 10-11.
80 See E-rate Modernization NPRM, 28 FCC Rcd at 11362, paras. 220-23.
81 See, e.g., ALA Comments at 23-24 (suggesting processes to decrease burden on consortia); Comments of
Internet2, WC Docket No. 13-184, at 18-21 (filed Sept. 16, 2013) (supporting efforts to simplify the application
process for cost-effective measures).
82 See, e.g., EdLiNC Comments at 3, 8-9; Letter from Michael A. Resnick, Associate Executive Director, National
School Boards Association, to Chairman Wheeler, FCC, WC Docket No. 13-184, at 1 (filed Nov. 8, 2013).
commenters supported the use of E-rate funds for projects of broad relevance to help identify and
accelerate the development of best practices for achieving cost savings and innovation within E-rate.83
We therefore now seek further comment on providing limited funding for well-defined,
time-limited demonstration projects aimed at identifying and testing different approaches to meeting
schools’ and libraries’ connectivity needs. Like the recently adopted Technology Transitions Order that
solicited a broad set of experiments in order to develop facts and data,84 such projects would be set up as
proof of concept experiments on innovative approaches to maximizing cost-efficient use of E-rate
funding.85 These projects, although experimental, would provide needed services and equipment to E-rate
eligible participants. We seek comment on funding a number of different types of demonstration projects
based on Commission and stakeholder proposals. We also invite suggestions of other types of projects
the Commission should conduct, the amount that should spend on any individual project, and the total
budget for such projects.
As one example, the Commission sought comment on whether to allow experimentation
in bulk purchasing of E-rate eligible services and equipment. 86 We received a mixed reaction in response
to the E-rate Modernization NPRM on whether the Commission should create a formal bulk buying
program.87 While commenters expressed concern about the potential rigidity of requiring applicants to
use such a program, they supported promoting the use of statewide or consortia bulk purchasing.88 We
therefore seek further comment and proposals on how to conduct one or more initial experiments with
bulk purchasing. A structured bulk buying demonstration project could test the cost-effectiveness and
flexibility of such a program using just a small number of services or products, and would have the
benefit of providing applicants with products and services they need as part of their broadband networks.
For example, stakeholders could propose a project to gather data on bulk purchasing by a state, consortia,
or regional research and education network for certain internal connection components, commercial
internet access, or a VoIP solution that would replace traditional voice service. We seek comment on
these types of projects and how to foster innovative and scalable practices.
A demonstration project could also provide an opportunity to gather information and test
proposals for implementation of a technical assistance program. For example, a demonstration project
83 See, e.g., Comments of State Educational Technology Directors Association, WC Docket No. 13-184, at 20-21
(filed Sept. 16, 2013) (Commission’s proposals will help identify best practices that will accelerate achievement of
E-rate program goals); iFiber Comments at 10 (encouraging the use of pilot programs to test the revised paradigms
and provide lessons learned); MOREnet Comments at 10 (supporting pilot programs to determine the effectiveness
of competitive bidding and consortia proposals); Comments of Riverside Unified School District Technology
Department, WC Docket No. 13-184, at 14 (filed Sept. 16, 2013) (Riverside USD Comments) (agreeing with
proposed experiments with consortia efforts and bulk buying opportunities).
84 See generally Technology Transitions Order, FCC 14-5.
85 For example, the Rural Health Care Connect Pilot Program has demonstrated methods to drive down prices,
improve service quality, and reduce administrative overhead through bulk buying opportunities. Healthcare
Connect Fund Order, 27 FCC Rcd at 16720, para. 93.
86 See E-rate Modernization NPRM, 28 FCC Rcd at 11354, 11362, paras. 187, 221. A negotiated bulk purchase
price could also be used as a reference price for equivalent services or products.
87 Compare, e.g., Riverside USD Comments at 14 with CenturyLink Comments at 17-18.
88 See, e.g., E-rate Central Comments at 10 (supporting consortia purchasing); Gates Reply Comments at 4 (supports
coordinated state and local planning incenting consortia and bulk buying); AT&T Comments at 10; EdCo Reply
Comments at 2, 11 (requests a priority for consortia and an additional five percent discount);
EducationSuperHighway Comments at 31 (permit state organizations, public entities, and other community anchor
institutions to join schools).
could test the effectiveness of hiring technical assistance experts to assist in network design or technical
planning in a small number of districts, schools, and/or libraries whose costs fall outside a standard range
for E-rate applicants. Another could test the use of consultants who are experts on connectivity costs and
are un-affiliated with broadband providers.
We also seek comment on other proposals in the record. The American Library
Association, for example, suggested a pilot program aimed at temporarily increasing the discount level for
targeted libraries, prioritizing based on public-private partnerships, and providing technical assistance in
order to “catalyze innovation” in advancing library services.89 If we were to fund such a project, how
much funding should we provide and over what period of time? What sort of support could we expect the
private sector to bring to such a project? Are there particular needs of libraries that we should focus on?
What types of technical assistance would be particularly valuable, and to what end? What data should the
Commission collect, as part of such a pilot program, and how should we use that data to measure progress
towards success? Are there ways in which libraries’ connectivity needs differ from those of schools? Are
there other types of demonstration projects aimed at addressing the unique needs of libraries that the
Commission should fund? With respect to all proposed demonstration projects, we request commenters
be as specific as possible about the goals, the amount of funding, the process for selecting participants, the
data to be collected and the timeline for any projects they propose or support.
Commenters also contributed other ideas, such as a pilot program to link last-mile
infrastructure to BTOP funded networks,90 experiments on the use of consortia efforts,91 or projects that
target rural areas.92 Another proposed a project to implement bulk purchasing of a platform to facilitate
affordable access to advanced information services.93 We seek comment on these proposals and how
such projects could be structured to gather data and evaluate success. These examples are not meant to be
exhaustive. We welcome further ideas from stakeholders on the types of demonstration projects that can
help identify cost efficiencies and drive down the cost of E-rate supported services. Are there other
approaches used by enterprise customers to drive down their broadband costs that the Commission should
experiment with in the E-rate program?
We seek specific comment on the process for selecting such proposals. In determining
projects, should the Commission focus on experiments that examine cost impacts or consider other types
of criteria, such as innovativeness? How should the Commission prioritize project funding? Should the
length of any given demonstration project be limited to a single year? Should they be tied to specific E-
rate funding years? Should the Commission select different kinds of projects to evaluate the different
models’ effects on driving down costs of E-rate eligible services? These projects should be designed to
help the Commission gather data needed to inform decision-making and make future reforms. Therefore,
we seek detailed comment on the data goals and how to evaluate the projects during and after selection.
We also seek further ideas on how to share information and empower applicants to replicate project
successes across the country.
Numerous commenters have confirmed the importance of streamlining the administration
89 See ALA Comments at 21-23.
90 See Reply Comments of Massachusetts Broadband Institute, WC Docket No. 13-184, at 8 (filed Oct. 17, 2013).
91 See CSM Comments at 23; Riverside USD Comments at 14; Comments of Wisconsin Department of Public
Instruction, WC Docket No. 13-184, at 11 (filed Sept. 15, 2013).
92 See Comments of Vermont Agency of Education, WC Docket No. 13-184, at 2 (filed Sept. 12, 2013). The recent
Technology Transitions Order seeks to gather information through rural experiments regarding the impact of
technology transitions on community anchor institutions, including schools and libraries, which may inform these E-
rate demonstration projects. See Technology Transitions Order, FCC 14-5, para. 94.
93 See Comments of Digital Public Library of America, WC Docket No. 13-184, at 1-2 (filed Sept. 16, 2013).
of the E-rate program. Therefore, as we consider demonstration projects, we also invite experiments that
find ways to reduce the administrative burden on E-rate applicants.
Regulatory Flexibility Analysis63.
The E-rate Modernization NPRM included an Initial Regulatory Flexibility Analysis
(IRFA) pursuant to 5 U.S.C. § 603, exploring the potential impact on small entities of the Commission's
proposals.94 We invite parties to file comments on the IRFA in light of this additional notice.
Paperwork Reduction Act Analysis64.
This document seeks comment on a potential new or revised information collection
requirement. If the Commission adopts any new or revised information collection requirement, the
Commission will publish a separate notice in the Federal Register inviting the public to comment on the
requirement, as required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. 3501-
3520). In addition, pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-198,
44 U.S.C. 3506(c)(4), the Commission seeks specific comment on how it might “further reduce the
information collection burden for small business concerns with fewer than 25 employees.”
Ex Parte Presentations65.
This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the
Commission’s ex parte rules.95 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
Comment Filing Procedures66.
Comments and Replies. We invite comment on the issues and questions set forth in the
Public Notice and IRFA contained herein. Pursuant to sections 1.415 and 1.419 of the Commission’s
rules,96 interested parties may file comments on this Public Notice by April 7, 2014 and may file reply
comments by April 21, 2014.
All filings related to this Public Notice shall refer to WC Docket No.
94 See E-rate Modernization NPRM, 28 FCC Rcd at 11458-68, App. D.
95 47 C.F.R. §§ 1.1200 et seq.
96 47 C.F.R. §§ 1.415, 1.419.
by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
Filings can be sent by hand or messenger delivery, by commercial overnight courier,
or by first-class or overnight U.S. Postal Service mail. All filings must be addressed
to the Commission’s Secretary, Office of the Secretary, Federal Communications
All hand-delivered or messenger-delivered paper filings for the Commission’s
Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-
A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand
deliveries must be held together with rubber bands or fasteners. Any envelopes and
boxes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities. To request materials in accessible formats for people with
disabilities (braille, large print, electronic files, audio format), send an e-mail to firstname.lastname@example.org or call
the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
In addition, one copy of each paper filing must be sent to each of the following: (1) the
Commission’s duplicating contractor, Best Copy and Printing, Inc., 445 12th Street, SW, Room CY-B402,
Washington, DC 20554; website: www.bcpiweb.com; phone: (800) 378-3160; (2) Lisa Hone,
Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th Street, SW, Room
6-A326, Washington, DC 20554; e-mail: Lisa.Hone@fcc.gov; and (3) Charles Tyler,
Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th Street, SW, Room
5-A452, Washington, DC 20554; e-mail: Charles.Tyler@fcc.gov.
Filing and comments are also available for public inspection and copying during regular
business hours at the FCC Reference Information Center, Portals II, 445 12th Street, SW, Room CY-
A257, Washington, DC 20554. Copies may also be purchased from the Commission’s duplicating
contractor, BCPI, 445 12th Street, SW, Room CY-B402, Washington, DC 20554. Customers may contact
BCPI through its website: www.bcpi.com, by e-mail at email@example.com, by telephone at (202) 488-
5300 or (800) 378-3160 or by facsimile at (202) 488-5563.
Comments and reply comments must include a short and concise summary of the
substantive arguments raised in the pleading. Comments and reply comments must also comply with
section 1.49 and all other applicable sections of the Commission’s rules. We direct all interested parties
to include the name of the filing party and the date of the filing on each page of their comments and reply
comments. All parties are encouraged to utilize a table of contents, regardless of the length of their
submission. We also strongly encourage parties to track the organization set forth in this Public Notice in
order to facilitate our internal review process.
For additional information on this proceeding, contact James Bachtell at (202) 418-2694
or Regina Brown at (202) 418-0792, in the Telecommunications Access Policy Division, Wireline
- FCC -
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