1/17 FCC Comments with SHLB Coalition Supporting E-Rate Funding to Help Close the Broadband ‘Homework Gap’

These comments were covered by Communications Daily and Broadband Breakfast.

The Schools, Health & Libraries Broadband Coalition (SHLB) and the Open Technology Institute at New America (OTI) submit these comments in response to the Commission’s Notice of Proposed Rulemaking regarding E-Rate support for Wi-Fi hotspots for remote learning.  SHLB and OTI are longtime advocates for cost-effective and inclusive strategies to eliminate the Homework Gap.¹ In fact, SHLB and OTI jointly filed a Petition for Rulemaking in January 2021 specifically calling for E-Rate funding to be used to support broadband access for students and library patrons lacking Internet access at home.

For that reason, SHLB and OTI applaud the Commission’s proposal to allow E-Rate support for Wi-Fi hotspots:  if adopted, this proposal will dramatically improve students’ ability to participate in remote learning and enrich their education online.

SHLB and OTI have long supported the use of E-Rate funding to serve students and library patrons outside of the school or library building.  The E-Rate program is uniquely positioned to bridge the digital divide, which disadvantages millions of students across the country.  Students who do not have home Internet access often cannot complete their homework and cannot take advantage of online educational opportunities. A May 2022 survey by the Pew Research Center found that among middle- and high-school students living in households with income under $30,000, at least 24 percent reported they were not able to complete homework assignments due to a lack of Internet access at home.

Fortunately, the Commission’s proposal to provide E‑Rate support for off-premises use of wireless services for educational purposes will allow many students to continue learning at home.  However, SHLB and OTI believe that the Commission’s proposal to limit E‑Rate support to Wi‑Fi hotspots will leave many students behind and will cost the E‑Rate program more over the long term.  To avoid this outcome, SHLB and OTI urge the Commission to incorporate the following recommendations into its final rules:

• Schools and libraries that have no commercially available mobile carrier services should be able to receive E-Rate funding for off-premises Internet access using other wireless solutions.
• Instead of limiting funding to commercially available Wi‑Fi hotspot devices and mobile carrier service, the Commission should allow funding for any wireless service that provides comparable Internet access to student homes and library patrons, as long as it is the most cost-effective option, because other wireless options can be less expensive and provide better service for some schools and libraries.  
• Rather than limit eligibility to a single wireless technology, the Commission should apply the E‑Rate competitive bidding requirements and the requirement that applicants pay the non-discounted share to the newly eligible off-premises services, which will ensure that whatever wireless solution an applicant chooses will be the most cost-effective option.
• The Commission should waive or eliminate the E-Rate cost-allocation requirement for off-campus services that enable remote learning.  This would allow schools and libraries to use the E‑Rate supported services at the school/library location to distribute Internet access through a private LTE or similar service without receiving additional E-Rate support but without losing E-Rate support they would otherwise be eligible for—a Homework Gap “community use” rule, essentially. 
• The Commission should apply certain existing E-Rate rules to the off-campus services.
• The Commission should ensure that any additional requirements are not burdensome, so that applicants are not discouraged from participating in the program.

Footnotes

¹ SHLB is a broad-based public interest coalition of more than 330 organizations that share the goal of promoting open, affordable, high-quality broadband for anchor institutions and their communities.  SHLB members include schools, libraries, representatives of health care providers and telehealth networks, state broadband offices, private sector companies, state and national research and education networks, consulting firms and consumer organizations.  For a current list of SHLB members, see http://shlb.org/about/coalition-members.  OTI works at the intersection of technology and policy to ensure that every community has equitable access to digital technology and its benefits, including universal and affordable access to communications technologies that are both open and secure.  More information can be found at https://www.newamerica.org/oti/about/.