LawFlash

FCC Seeks Comment on E-rate Modernization

March 07, 2014

The FCC is seeking additional comments on particular issues relating to the E-rate subsidy program for services used by schools and libraries, including (1) how best to focus E-rate funds on high-capacity broadband, especially high-speed Wi-Fi and internal connections; (2) whether and how the FCC should begin to phase out support for traditional voice services to focus more funding on broadband; and (3) whether there are demonstration projects or experiments that would help test new, innovative ways to maximize cost-effective purchasing in the E-rate program. Comments should be filed by April 7, 2014, and reply comments by April 21, 2014.

Broadband Deployment and Internal Connections

The FCC recognizes that support for “internal connections” needs to be changed to address the increasing need for services and equipment necessary to extend high-capacity broadband throughout schools and libraries. It seeks comment on:

  • whether to change the current priority two funding category by allocating annually a set amount of funding for LANs and Wi-Fi networks;
  • what equipment (e.g., internal wiring, switches and routers, wireless access points and supporting software) is essential for such purposes;
  • how to provide increased and more widespread access to funding for internal connections and how to prioritize requests; and
  • a proposal to (a) limit internal connections funding to once in every five years for eligible applicants; (b) limit an applicant’s ability to receive funding for internal connections to a single funding year until all other applicants have received or declined support; or (c) provide at least some support to all eligible applicants in each funding year.

It also seeks comment on deployment of last-mile connections to eligible schools; measures that can be taken to encourage cost effective purchasing, for example, through consortia or other bulk purchasing programs; and how best to minimize administrative burdens associated with applying for and receiving E-rate support.

Reduced Support for Voice Services

The FCC seeks comment on options to reduce support for voice services as schools and libraries transition to more cost-effective VoIP services, including:

  • a three- to five-year phase-out period for support;
  • a gradual reduction in the discount rate applicants receive for voice services;
  • elimination of all support for voice services beginning in 2015;
  • retaining support for voice services under a lower priority; or
  • establishing a benchmark support amount for voice services.

In addition, the FCC seeks comment on how to end support for internal connections used for voice services and whether and how to continue to provide support for voice services in remote rural areas or Tribal lands.

Demonstration Projects

Finally, the FCC seeks comment on providing limited funding for well-defined, time-limited demonstration projects or experiments that provide innovative approaches to maximizing cost-efficient use of E-rate funding (e.g., to evaluate cost effectiveness of bulk purchasing or linking last-mile infrastructure to BTOP funded networks, among others) and how to select such proposals.

Please contact Tamar Finn or Douglas Orvis with additional questions and to provide comments in this important proceeding.

This article was originally published by Bingham McCutchen LLP.