Now that the Federal Communications Commission has issued a notice of proposed rulemaking that sets the stage for major changes to the E-rate program, education and technology advocates are sifting through the 175-page document to try to decipher what exactly it will mean for schools and their Web connectivity.
President Barack Obama, among others, has called for a reworking the program's priorities and increasing its funding. The notice, on the one hand, doesn't provide definitive answers on how specific E-rate policies will change. That's partly because of how the rulemaking blueprint is structured: Rather than putting forward specific proposals, it instead presents the FCC's view of perceived shortcomings in the program, and then poses a series of pointed questions to the public and the nation's school and tech communities to weigh in on it. They have until Sept. 16 to do so.
Nonetheless, advocates who monitor E-rate policy say the notice illustrates the FCC's thinking and how the program may change after the commission reviews comments and releases final rules.
A number of those observers described the notice as extremely ambitious in its scope, even if many of the ideas put forward for changing the E-rate program are not new and, in fact, have been debated almost since the program's inception, in 1996.
"It indicates to me that they're serious about a sweeping modernization of the program, and not just an incremental approach," said Evan Marwell, the CEO of Education Superhighway, a San Francisco-based organization that advocates for improved Web access for schools. "There's an openness to outside-the-box ideas."
The FCC has said the notice is focused on three overriding goals: increasing broadband capacity for schools and libraries; improving purchasing practices in order to drive down the program's costs and increase its effectiveness; and streamlining the program's administration.
Within that framework, here are a couple of the most important baskets of ideas put forward in the FCC notice, as described to Education Week by advocates and others who will be making their case to the commission in the time ahead.
Improved Broadband: How to Get There?
The notice asks for opinions about "the most efficient technological architectures that schools and libraries are likely to use for connectivity." Some say fiberoptic cable is the best option for boosting the speed of schools' Web connectivity, while also giving them the greatest ability to handle increases in demand. Others say less ambitious and costly tech upgrades are more realistic options for schools.
"They're clearly focused on broadband and making that the thrust of the program," said John Harrington, the CEO of Funds for Learning, an organization that consults applicants for E-rate funds. He prefers that the FCC give schools the flexibility to choose the kinds of wireless technology and other tools that make sense for them, rather than attempting to define what they should be using. "The more you define technologies," he said, as they evolve "the more you have to re-define them later."
The notice also asks whether the FCC should increase schools' access to funding technologies that could boost schools' broadband capabilities, but which haven't received much support or attention from schools to date. For instance, one specific change recommended in the FCC notice is to give higher funding priority for using "dark fiber," or unused fiberoptic cable, for improved connectivity, and to make the E-rate policies for paying for dark fiber more consistent.
Clearer Measures of Program Success
How should the overall performance of the E-rate program, and that of individual schools and disticts that receive funding, be measured? One way would be to set specific Internet speed targets for schools, and within schools. The FCC's notice seeks comment on that issue. It also poses a more controversial question: Should the program be measuring whether access to E-rate money improves academic outcomes?
Critics warn that classroom performances is shaped by myriad factors, and that trying to attribute students' gains or losses to support from the E-rate is a mistake. But proponents believe trying to gauge the E-rate's role in academic performance can help ensure that money is well spent, and that information on academic performance can help schools make more-informed decisions about what kind of connectivity, and how much of it, they need.
Jon Berstein, a lobbyist who represents school technology organizations, said it would be a mistake to judge a telecommunications program on academic results, given all the factors that could skew student performance other than Web connectivity.
Ultimately, there's a reason the program is "sited at the FCC, not the Department of Education," Bernstein said.
Boosting Connectivity Within Schools
The FCC notice shows a clear interest in increasing Internet connectivity within schools—not just improving schools' and districts' overall connectivity from outside telecommunications providers. The current priorities in the E-rate program have left schools "billions of dollars" short of the money they need to provide reliable connections between buildings and classrooms, the FCC contends in the notice.
To address this issue, the commissioners suggest revising the program's funding priorities. They also ask the question of whether the E-rate should set specific targets for internal Web connectivity, and if all schools' internal connections should be sufficient to meet the growing demands posed by 1:1, or one-to-one, student-to-computing device initiatives.
Changing Discount Rates, Requiring More Matching Funds
The E-rate works by providing districts and schools with discounts on telecommunications fees. The FCC asks whether it should consider reducing the discount rate, so that more funding would be available to a wider pool of applicants, and potentially increase incentives for applicants to hold down costs. The commissioners also raise the possibility of increasing the matching funds required by applicants to the program (an idea advocated by the lone Republican FCC commissioner, Ajit Pai).
The notice points out that reducing the discount helped create incentives to control costs and improved efficiency within another federal program that supports telecommunications services, the Rural Health Care program.
How Much Money is Needed?
The notice also asks whether the FCC should consider lifting the overall program cap, even temporarily, on E-rate funds, which now stands at about $2.4 billion, a step that would increase the overall money flow into the program.
The FCC does not, however, recommend specific dollar amounts and timelines for boosting E-rate funding. (Obama has called for increasing fees for a temporary, five-year-period.) Instead, the FCC asks for comments on how much funding is necessary, and whether new funding should be tied to providing specific kinds of services for broadband connectivity, or to specific applicants, such as regional consortia.
Harrington said he was glad that the FCC did not wade into the specifics of funding options, because it would distract from important questions about how to restructure the program.
Changing funding "opens it up to a lot of debate, and really, it's a whole other topic," Harrington said. "I was hoping they wouldn't tie [funding and other policies] together."
Increased Buying Power
The FCC says it wants to do more to encourage schools and districts to band together to make E-rate purchases, a step that could also prod telecommunications carriers to lower prices and encourage and coordinate services. Schools are allowed to participate in consortia already, the notice explains, but in 2011, that sort of group purchasing accounted for only about 13 percent of all E-rate money spent.
The commission is looking at incentives and other mechanisms to encourage consortia. It says it also wants to see if it can encourage "bulk buying" through state or regional buying of services that are supported by the E-rate.
That's my read on some of the notice's highlights. After you've gone through the document, give me your thoughts on what matters most to K-12 schools, and where the FCC is on, or off the mark.