Over 800 stakeholders filed comments in response to the FCC’s E-rate Notice of Proposed Rulemaking (NPRM) and reply comments are due by October 16, 2013. After reviewing the initial comments, it is clear that stakeholders are urging the FCC to increase the funding cap from $2.3 billion to at least $4.5 billion as the demand for E-rate continues to grow each year. So, for the sake of argument, let’s assume the FCC does increase the funding cap. Who would really benefit?
The overall requested amount for FY 2013 was $5 billion and $2.7 billion of this was for Priority One services. In fact, Priority One requests were $400 million over the current funding cap. If not for the unused funds from previous years, the SLD would not have been able to fund all of the Priority One applications. The 90% applicants requested $1.7 billion for Priority Two projects and when combined with the Priority One requests, this comes out to nearly $4.5 billion.
So back to our scenario and let’s assume that the overall cap is increased to $4.5 billion. This would certainly benefit the 6,700 90% applicants who applied in FY 2013 for Priority Two funds. In reality, the only applicants who would really benefit from a funding cap increase would be these 90% applicants who account for only 25% of the total E-rate K-12 and library community. This begs the question of is it truly equitable to the other 75% of applicants who also need Priority Two dollars in order to meet their infrastructure and networking needs?
Funds For Learning has another approach, and although we are advocating for more funds to be infused into the program, we realize this alone would not be enough. Tinkering with the discount matrix may be a short term fix, but it hurts the neediest of the schools. Another possible solution is to eliminate a few outdated solutions from the eligible services list. But this does not make a real dent in this allocation problem either.
Funds For Learning has proposed a solution that would include a budget for each applicant. The E-rate would continue to be a discount program, but each applicant’s total annual E-rate discounts would be capped based on their overall enrollment, discount rate and location. The proposal also adds something missing in today’s E-rate program: specific measures to guard E-rate funding for small and rural schools. Additionally, the Funds For Learning proposal seeks to eliminate the FCC’s priority system, therefore allowing applicants the option to purchase anything off of the eligible services list based on their own local priorities. In fact, the eligible services list could be expanded to include new telecommunication and networking technologies.
An E-rate Reform Coalition, along with additional applicants, have submitted comments in support of the Funds For Learning proposal. These include:
Applicants can visit the Funds For Learning website to learn more about how the FFL E-rate 2.0 proposal would directly benefit their institution. We have also created the FFL 2.0 budget calculator which allows schools and libraries to see the benefit and possible increase in dollars they could have available if the FFL 2.0 budget formula were put in place. Contact us if you would like to learn more about how you can also support our reform efforts.