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July 10,20 14

The Honorable Thomas Wheeler


Federal Communications Commission

445 12111 Street, NW

Washington, DC 20554

Dear Chaim1an Wheeler:

We write regarding the Commission· s July II meeting to consider a Report and Order to

modernize the E-Rate program and expand support for Wi-Fi connectivity for schools and


We urge you to take into account the objections raised to the Wi-Fi proposal in a .June 20,

20 14 letter signed by more than a dozen national education organizations representing E-Rate

program beneliciaries as well as the rural specific concerns addressed in a letter dated June 30.

20 14 signed by six organizations representing rural schools.

In addition. we hope you will give

spccial consideration to the July 8. 20 14 letter from Senators Rockefe ller and Markey. We agree

with the view·s raised in these letters.

We oppose any proposal that would change the E-Rate distribution mechanism to one

that provides funding based on a per-student or per-square foot calculation fo r Wi-Fi. Such a

formu la vvould disadvantage rural school and libraries. We also oppose modifying the program·s

poverty calculation from school-based to district-based because it is less responsive to meeting

the needs of a specific school.

We hope the Commission will make changes to the proposal in response to these

concerns bel'ore moving forward with 1->Ratc modernization.

Thank you for your consideration.


Debbie Stabeno\\'

Carl Levin

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