FCC Has No Basis for Setting Arbitrary E-Rate Broadband Speed Goals

Today, TechFreedom and the International Center for Law & Economics filed Reply Comments on the Federal Communications Commission’s proposal to modernize the E-Rate Program, created in 1996 to fund telecommunications services for schools and libraries across the country. In June, President Obama announced the ConnectED initiative, with the goal of bringing high-speed broadband to nearly every school and library in America within five years. The FCC’s Notice of Proposed Rulemaking proposes “bandwidth targets” of “at least 100 Mbps per 1,000 students and staff (users) by the 2014-15 school year and at least 1 Gbps Internet access per 1,000 users by the 2017-18 school year” and “a minimum of 1 Gbps Internet connectivity by 2020” for libraries.

In September, TechFreedom and ICLE filed Comments on the NPRM questioning the basis for setting specific speed targets, and whether e-Rate’s limited funding would better be directed towards other needs. The following is an excerpt from our Reply Comments:

In our review of the comments filed in this proceeding, we can find no response to our questions: What analytical basis, if any, is there for these speed targets? What are the actual current and expected near-term bandwidth demands of schools and libraries? Or, more generally, how should policymakers weigh the trade-off between funding higher speeds and funding other telecommunications needs of schools and libraries (connectivity, devices, etc.), or other related needs (training, IT support, etc.)? …


Essentially, school districts and systems across the country are singing the same tune, but in different octaves: “We aren’t sure that arbitrary broadband targets are going to fit our needs; instead, we need flexibility to direct funding to meet our particular telecommunications needs.” The FCC should listen.


Imposing speed thresholds would miss the more important goal of the E-Rate program: connecting the neediest schools. The record simply does not support imposing any kind of speed requirement or even target because no one has demonstrated that such targets will actually benefit students more than other potential uses of limited resources.


The FCC should issue a Further Notice of Proposed Rulemaking that returns to the question buried in the NPRM that should have been central to this proceeding: “Is there a way to measure how success in the classroom is affected by access to E-rate funding or services supported by E-rate?” So far the answer appears to be “no.”

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