In Comments to the FCC, SIIA Identifies Specific Steps for Enhancing the E-Rate Program for Schools and Libraries

In comments submitted today to the Federal Communications Commission (FCC), SIIA strongly supported the Commission’s effort to review, modernize and enhance the E-rate program.   SIIA submitted comments in response to the FCC’s notice on “Modernizing the E-rate Program for Schools and Libraries.” The E-rate program provides schools and libraries with discounts off advanced telecommunications and information services in order to ensure their affordable access.

As part of its comments submitted today, SIIA said:

“SIIA views robust Internet access through high-speed broadband connectivity as critical to a 21st century education system, and to providing educators and students with access to technology-based tools and resources that are mission critical for teaching and learning in today’s digital age. Learning technologies are needed to increase educational opportunities, improve student engagement and enhance the personalization of learning to meet the needs of an ever more diverse student body.

“E-Rate funding has been relatively flat at $2.25 billion since its creation in 1996, while the need for, and the demand for connectivity has grown dramatically as evidenced by the $4.9 billion in applications sought for this funding year by schools and libraries. SIIA’s recently released 2013 Vision K-20 educator survey results found that, while their goal for access to robust bandwidth is 3.98 (on a 1-4 scale), educators rate their actual access as only 3.14. Similarly, their need for ubiquitous, wireless access to resources and services ranks as a 3.89, but their actual access is only a 2.64.

“SIIA supports the FCC proposal “to focus funding on those services that provide high-capacity broadband to school and library buildings and those services and equipment that disseminate the high-capacity broadband within those buildings…”

SIIA’s full comments can be found here.

SIIA outlined 10 specific recommendations in its comments to the FCC:

  1. Robust Student Connectivity. Update the E-rate’s implicit goal from basic school connectivity to robust student connectivity, focusing on advanced Internet bandwidth to the point of use (i.e., student and device) and not simply to the school building.
  2. Affordable Access. Exercise the FCC’s authority to increase E-rate funding as needed and appropriate to meet evolving and expanding demand, as authorized by Congress under the Telecommunications Act that created the E-rate program.
  3. Timely Modernization and Enhancement. Move swiftly to modernize and enhance the E-rate program in order to meet urgent demands, and if necessary, increase funding under the existing rules prior to program changes in order to expedite the increase of resources to the field.
  4. Advanced Eligible Services. Update the priorities and eligible services to ensure the program continues to meet the law’s emphasis on enhancing “access to advanced telecommunications and information services.” [emphasis added]
  5. Access Goals and Flexibility. Center E-rate program accountability around the broad goal of providing high-speed broadband access to all students, while also providing the flexibility for eligible schools and libraries to determine their precise goals and their additional goals.
  6. Educational Goals and Flexibility. Provide flexibility to determine and measure E-rate goals and impact, while not measuring E-rate effectiveness by student performance outcomes or similar learning indicators.
  7. Anytime, Anywhere Learning. Ensure that schools and libraries continue to be the primary beneficiary of E-rate funding, but provide flexibility to leverage that funding to meet the connected learning needs of students outside of the school building and school hours.
  8. Program Efficiencies. Continue to streamline the E-rate application and operational procedures, while recognizing the importance of program accountability.
  9. Program Data. Continue to enhance program data access to support program accountability and enhanced cost effectiveness, while recognizing that not all data should be made publicly available.
  10. Gift Rule. Modify and clarify E-rate gift rules to avoid unintended consequences that limit public-private partnerships and educator professional learning opportunities.

SIIA published a guide to the E-Rate for it’s members in April, 2012. Learn more here.


Mark SchneidermanMark Schneiderman is Senior Director of Education Policy at SIIA.

SIIA Applauds the FCC for its Vote Today to Modernize the E-Rate

SIIA today commended the Federal Communications Commission for its vote to open a new rulemaking aimed at updating and enhancing the E-Rate. The vote follows President Obama’s ConnectEd proposal last month to enhance highspeed broadband connectivity for the nation’s schools and libraries.

SIIA President Ken Wasch commented:

“The E-Rate program has been a critical means for the nation’s schools and students to access the digital learning opportunities necessary for their success. SIIA applauds Acting Commissioner Clyburn and the Commission for their vote today to modernize and enhance the E-Rate program to better meet today’s needs and to better support our nation’s educational and economic competitiveness. SIIA looks forward to reviewing and responding as appropriate to the proposed rules to improve program efficiency and impact.”

The E-Rate program provides discounts to public and private schools and public libraries for the purchase of telecommunications services, Internet access, and related networking equipment. The President’s ConnectEd proposal calls for leveraging the E-Rate universal service program to within five years connect 99 percent of America’s students through next-generation broadband (at speeds no less than 100Mbps and with a target of 1Gbps) to, and high-speed wireless within, their schools and libraries. E-Rate funding has been relatively flat at $2.25 billion since its creation in 1996, while the need for, and the demand for connectivity has grown dramatically.


Mark SchneidermanMark Schneiderman is Senior Director of Education Policy at SIIA.

SIIA Applauds President Obama and Senator Rockefeller for Proposal to Enhance E-Rate School Connectivity

The Senate Commerce, Science & Transportation Committee held a hearing today on the nomination of Mr. Thomas Wheeler to be Chairman, Federal Communications Commission (FCC). Chairman John D. (Jay) Rockefeller IV (WV) used the occasion to highlight the priority of ensuring that the nation’s students and schools have access to digital learning opportunities through expansion of the E-Rate program. This effort received a significant boost recently when President Obama proposed his ConnectEd initiative, calling on the FCC to take steps to improve and extend the E-Rate.

SIIA strongly supports expansion of the E-Rate program, and applauds both President Obama and Senator Rockefeller for their proposals and leadership. Expanding the E-Rate program will help transform the educational experience for the nation’s students by expanding the availability of high-quality digital learning opportunities. Swift action on this initiative is also critical to support full implementation of new college- and career-ready standards and aligned online assessments.

SIIA President Ken Wasch commented today:

“The nation’s students and schools require modern tools to compete in an increasingly digital, connected and competitive world. SIIA applauds President Obama for his proposal to enhance the E-Rate program to ensure all students and educators can realize the educational benefits made possible by technology. SIIA calls on the Federal Communications Commission to act swiftly to ensure these increased resources can quickly and effectively be directed to teaching and learning objectives.”

SIIA supports and has championed increased public investments in education targeted to both improve access to, and enhance the use of, educational technologies. Learning technologies are needed to improve educational opportunities, student engagement and the personalization of learning. Yet, SIIA’s soon to be released 2013 Vision K-20 educator survey results found that, while their goal for access to robust bandwidth is 3.98 (on a 1-4 scale), educators rate their actual access as only 3.14. Similarly, their need for ubiquitous, wireless access to resources and services ranks as a 3.89, but their actual access is only a 2.64.


Mark SchneidermanMark Schneiderman is Senior Director of Education Policy at SIIA.

FCC releases “Information Needs of Communities” report

Last week saw the release of the FCC’s report “Information Needs of Communities.” The report analyzes the current state of the media and concludes that “with the media landscape shifiting as fast as it has been, some current regulations are out of sync with the information needs of communities and the fluid nature of modern local medda markets.” Additionally, the report makes several specific policy recommendations aimed at helping to reduce the cost of reporting, enabling consumers, improving the media markets, removing obstacles to innovation, and ensuring taxpayer resources are well used.

The six broad recommendations from the report are:

1.) Information required by FCC policy to be disclosed to the public should, over time, be available online.

2.) Greater government transparency will enable both citizens and reporters to more effectively monitor powerful institutions and benefit from public services.

3.) Existing government advertising spending should be targeted more toward local media.

4.) Nonprofit media needs to develop more sustainable business models, especially through private donations.

5.) Universal broadband and an open Internet are essential prerequisites for ensuring that the new media landscape serves communities well.

6.) Policymakers should take historically underserved communitites into account when crafting strategies and rules.

While the report highlights gaps in local, community reported news, it also acknowledges the vast number of outlets and their continued exploration of business models. The report’s conclusion:

“the gaps are quite important, but they are fixable. In other words, we find ourselves in an unusual moment when ignoring the ailments of local media will mean that serious harm may be done to our communities – but paying attention to them will enable Americans to develop, literally, the best media system the nation has ever had.”

It remains to be seen what will become of the report, or the recommendations. But there’s no question that the media landscape is shifting rapidly and will continue to do so for the foreseeable future. On behalf of our members and then industry, SIIA will continue to monitor the policy proposals and developments throughout this proces.

“The Good, The Bad, and The Ugly”

In the last few weeks, federal and state officials have introduced a plethora of plans and proposals with implications for education and the role of technology that is perhaps unprecedented in scale and scope.  The latest is the “National Broadband Plan: Connecting America” released today by the Federal Communications Commission (FCC), in response to a Congressional request in the Recovery Act a year ago.  The others: the National Education Technology Plan, titled “Transforming American Education: Learning Powered by Technology” released two weeks ago,  the Obama Administration’s ESEA “blueprint for reform” and the NGA-CCSSO Common Core standards, not to mention the final Investing in Innovation (i3) rules.  The timing is largely coincidental.  The question: What does it all mean?

A few observations specific to education technology and SIIA members:

-The Obama Administration (including the independent FCC) seems to view technology as an important means to educating our students to maintain our global competitiveness.

- The Obama Administration is proposing a new federal policy path to realizing that goal, proposing to increase the E-Rate, eliminate targeted DoED funding through the Enhancing Education Through Technology (EETT) program, infuse technology in other ESEA programs, and look to “supply-side solutions” such as investment in open educational resources (OER) and interoperability as well as potentially far-reaching regulation around copyright, technology standards, etc.

- It is unclear whether the Obama Administration’s vision for transforming education through technology is a priority or sufficiently backed by “demand-side” targeted federal policies and investments (i.e., those directly supporting educational agencies and teachers around technology) needed to help lead the nation’s education system in this new direction.

- It is less clear how the U.S. Congress, not to mention education leaders, will react in that their actions are largely need to legislate and enact these policies and recommendations.  For example, “Many of the FCC’s proposals are short on details, and lawmakers and the agency can accept or reject any number of the ideas.”  [Read more...]

SIIA Files Comments in support of FCC Proposed “Open Internet Rules”

Today, SIIA came out in support of the Administration’s approach to “Network Neutrality” when it filed comments with the Federal Communications Commission (FCC) in favor of its proposed rule codifying 6 principles to “preserve the open Internet.”  In short, the goal is to preserve the level of open access over the Internet which has been critical the network’s success as an engine for creativity, innovation, and economic growth.

SIIA agrees with the FCC that without the guarantee of an open Internet that assures a level and transparent playing field for software and digital content providers, innovation and the development of new technologies and infrastructure will be significantly stifled.  Of course, this would not only be detrimental to the future of these industries, but also to consumers and business enterprise users, and the U.S. economy more broadly.

In its comments, SIIA identified two distinct risks that continued openness and transparency of the Internet faces from broadband network operators who have the technologies that allow them to distinguish different classes of traffic, to offer different qualities of services, and to charge different prices for each class.

First, there is the distinct risk that Internet access service providers may charge inefficiently high prices to content, application and other service providers that makes investing in innovative Internet content, application, and services risky.   Second, there is the real risk that, where service providers have market power, particularly relative to other services they offer, there is the incentive and ability to reduce or failure to increase transmission capacity or degrade service.   Where broadband Internet access service providers have market power and are vertically integrated or affiliated with content, application or service providers, it acts as a gatekeeper.

The proposed FCC rule provides an appropriate and carefully developed means to limit discriminatory actions by service providers that favor or disfavor content, applications or other services reaching end users, whether they be enterprises of consumers.  Importantly, the rule also provides sufficient flexibility for broadband providers to take reasonable measures to manage their networks or to address quality-of-service needs, and to provide a safe and secure Internet experience for their users, including blocking of spam, malware and the malicious traffic originating from malware.

As proposed by the FCC, the rules would not protect unlawful content, and not prevent reasonable broadband service provider practices to prevent the unlawful transfer of content, including actions to stop the unlawful distribution of copyrighted works—such unlawful distribution clearly has adverse consequence on the copyright industries, the economy and the overall broadband ecosystem.   SIIA strongly concurs with the FCC’s approach on this point.