The American Cable Association said the independent cable community stood ready as leaders in rural broadband deployment to help the Federal Communications Commission carry out its plans for an updated E-rate program for schools and libraries, assuming the agency's approach adhered to some key principles that will result in program improvements without increasing current budget amounts within the Universal Service Fund.
"The FCC's new E-rate proceeding is vital and ambitious, seeking to make much needed and far-reaching changes to an already successful program," ACA President and CEO Matthew M. Polka said. "However, prior to adopting major new initiatives for the E-rate program, the FCC needs to collect the facts, led by an the development of an inventory of existing infrastructure and broadband dependent applications and services used today by teachers and students and those that are likely to be used, and the number and types of access devices and technologies used today and those expected to be used in the near future."
ACA's set forth its views in Sept. 16 comments filed with the FCC, which in July voted unanimously to reform the E-rate program by focusing on network capacity and speed, on the collection of more and better data, and on the simplification of the application process. The E-rate program offers broadband subsidies to K-12 schools and public libraries totaling $2.25 billion annually in USF support.
In its comments, ACA asked the FCC to concentrate on four key areas that would generate the most benefits. According to ACA, the FCC should:
- Focus On High-Speed Broadband Connectivity: Because high-speed broadband services have become so essential, the FCC should re-orient E-rate support to focus on providing high-speed broadband connectivity to and within schools and libraries.
- Use Existing Infrastructure To The Maximum Extent Practical: To ensure the program achieves its objectives most efficiently, maximizes the effectiveness of its limited funding, and provides incentives for providers to continue to invest their own capital in broadband infrastructure, E-rate funding recipients should make all reasonable efforts to use existing infrastructure prior to constructing new facilities.
- Facilitate Maximum Participation By Service Providers: A key way for the E-rate fund to operate efficiently and maximize the value of its limited resources is to encourage greater participation by service providers currently participating in the program and by facilitating participation by other providers - so that schools and libraries receive multiple bids to provide infrastructure and services.
- Cap E-Rate Funding At The Current Level: Instead of increasing the total size of the E-rate fund to meet its new high-speed broadband connectivity objectives, the FCC should re-orient the fund, reducing support for certain legacy services, such as paging and voice-related services, and increasing program efficiencies.
On the need for good data, ACA said it would follow the lead of FCC acting Chairwoman Mignon Clyburn, who in recent speech remarked: "Good data drives good policy. And I'll be blunt. We need good data if we're going to get this [E-rate modernization] right. We need data when it comes to the bandwidth schools need...We need data to understand how to cut costs, increase efficiency, streamline the program, and deliver that broadband capacity to and within schools in the most cost-effective manner."
In ACA's view, the FCC's immediate task is to collect the facts and after this is accomplished, the agency will have the firm foundation required to begin to chart a course for achieving the ambitious aims for the E-rate program. In addition to collecting data, ACA said the FCC should update Form 471, which schools and libraries are required to file when applying for E-rate funding and which includes information about the nature and type of broadband facilities they are obtaining. ACA said the FCC should collect granular data from recipients about broadband supply and demand and should publish annual reports based on the aggregate data.
"The FCC has the right approach at the right time to update the E-rate program so it can advance digital learning. Yet, before adopting new policies, the FCC needs to ensure there is sufficient data upon which to base them. Only then can the FCC achieve its objectives most effectively and efficiently. ACA and its members look forward to working with the FCC as the proceeding evolves," Polka said.