ECF Rules Should Mirror E-rate, Include Smartphones, Groups Say
The FCC’s Emergency Connectivity Fund was enthusiastically praised by education advocates, schools and broadband providers in comments posted Tuesday in docket 21-93. The ECF program will give schools and libraries $7.17 billion to support remote learning during the COVID-19 pandemic (see 2103110037). Many suggested that the existing E-rate program is the best model for setting up the new funding as quickly as possible. Others questioned excluding smartphones from funding support.
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The ECF is separate from the E-rate program, but the commission sought comments on leveraging the existing program to quickly scale up the new funding. New York state's E-Rate Central urged the commission to adopt funding caps using E-rate's category 2 budget factors "with a slight twist." Category 2 caps reimbursement for schools at $167 per student and libraries at $4.50 per square foot. The group proposed caps on similar rates that are "adjusted by each applicant's current discount rate.”
The State E-rate Coordinators’ Alliance suggested capping funds in rural and urban areas at $100 per student/$2 per library square foot and $150 per student/$3 per library square foot, respectively. The State Educational Technology Directors Association agreed a capped budget is “equitable, efficient, and predictable.”
Applying for ECF support should be "streamlined and clear" so schools that haven't previously participated in E-rate can get funding, said the California Department of Education. Minimize audit requirements "as much as possible," it said. The E-Rate Management Professionals Association agreed, urging a "gentle hand" approach.
Several aid packages have already included funding to expand broadband access, said NTCA, so ECF should be targeted to reach consumers that programs like the emergency broadband benefit don't. ACA Connects, AT&T and Verizon agreed. "There should be a blanket prohibition on duplicative support," said USTelecom.
The FCC proposed excluding self-provisioned networks from funding, but that's already allowed in E-rate and is "good policy," said Motorola. Schools are best suited to determine their needs, and the agency should not "arbitrarily limit their available options," said the Schools, Health & Libraries Broadband Coalition. A coalition of public advocates led by New America's Open Technology Institute agreed, saying there’s “no rational basis for excluding a proven means of providing students with internet access."
Adopt "equipment and service neutrality" to give schools the most flexibility, said Incompas. Any new network builds should be limited to current provider upgrades "to ensure that capacity to the school or library can support connectivity to the homes," the group said. Altice suggested funding for new infrastructure be allowed only in areas where no current broadband service is available and "no broadband provider is willing and able to provide service.”
The Fiber Broadband Association suggested adopting symmetrical minimum service standards, which Starry echoed in similar comments. The Wireless ISP Association, UScellular and GCI disagreed. Minimum service standards are "unnecessary,” GCI said. Schools should be allowed to select a speed that's "suited to the specific needs of their students," WISPA said.
CTIA and the Competitive Carriers Association asked the FCC to include smartphones and other wireless devices as qualified devices. The wireless industry earlier pushed unsuccessfully to include smartphones as qualified devices under the emergency broadband benefit program (see 2102230025). “Mobile devices, including smartphones with Wi-Fi hotspot capabilities and stand-alone Wi-Fi hotspots” should “broadly qualify as ‘eligible equipment,’” CTIA said: “Mobile wireless solutions have long been identified as a key part of the solution to the homework gap.”
“Many Americans, particularly in low-income families, depend on mobile devices like smartphones and tablets to connect to the internet, rather than desktop computers or even laptops,” CCA commented. “Those mobile devices provide the flexibility to attend class and do homework in different areas of a home, in common areas of larger buildings and gathering places, and outside the home.” T-Mobile offers handsets “with maximized hotspot functionality for situations in which a direct connection is preferable over a handset solution,” the carrier said: “These affordable and easy-to-distribute wireless devices ... allow educators and students a robust, direct connection to the internet.”
“Smartphones equipped with the right system capabilities can enable the type of full participation in remote learning activities,” said Samsung Electronics America. Paying for wireless broadband access “without funding the acquisition of mobile learning devices itself may not properly equip low-income students,” Qualcomm said: There's “no functional difference between a wired modem, which is eligible for E-Rate support, and a portable wireless hotspot, which may not be.” Mobile hot spots can be “used by the student whenever and wherever they are,” it said.