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Dear FCC: Reject the Recommended Discount Threshold

Dear FCC,

On January 24, 2011, USAC recommended that the final discount threshold for Funding Year 2010 be set at 81%. The SLD cited their belief that they will ultimately not have enough funds to cover any Priority Two requests below this level. However, this recommendation doesn't fall in line with the reported funds available for carryover or the FCC's desire to increase the availability of Internal Connections funding for all schools.

USAC Second Quarter 2011 Report

If USAC was concerned about the availability of funds for FY2010, then the estimations they released in the USAC Second Quarter 2011 Report should relieve those concerns. According to the report, there is an estimated $400 million in unused funds available for carryover. This carryover would be more than enough to meet the demand at 80% for FY2010 Priority Two requests that currently stand at approximately $279.43 million.

The National Broadband Plan

The National Broadband Plan emphasized your desire to increase access for more applicants to secure Internal Connections dollars. If the Commission is indeed committed to helping more applicants reap some E-rate benefits for their internal connections projects, then rejecting USAC’s discount threshold recommendation would be a very simple way to demonstrate that commitment.

The Limits of Poverty Do Not End at the 80% Level

As you know, the sites that receive 90% discounts represent the applicants that serve communities with a great deal of need. However, 80% sites can have as many as 74% of their students eligible under the National School Lunch Program. The schools and libraries that populate the 80% discount band serve some of the country's most impoverished communities and the Priority Two funds are a crucial part of the continuation of meeting their broadband goals.

Historically, the 81% (or slightly higher) level for Priority Two applications has been a convenient threshold, serving as an unspoken perimeter of poverty, leaving the 80% applicants on the outside looking in.

If the Commission adopts USAC's recommendation and puts a hold on funding at 81%, the result will be more of the same. The same high-discount-rate schools and libraries that always receive E-rate funding will be the only schools and libraries that get to take advantage of the extraordinary amount of E-rate support that the Commission made available this year.

Please Reject an 81% Threshold

The USAC Second Quarter 2011 Report shows that there is more than enough money available to fund FY2010 Priority Two requests at the 80% level.

The National Broadband Plan states that the FCC would like more schools to have access to Internal Connections dollars.

There is no reason to rush this decision and the Commission should not feel pressure to decide now where to cut off funding.

There is a way and means to fund all of the 80% requests. All that is needed is the will to make it so.


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