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Schools Need Support, Not Priorities

The FCC’s eligible service list (ESL) sets the parameters for the goods and services that will qualify for E-rate support. Each and every year, the FCC solicits, receives, and considers ideas about the ESL and then publishes updates. Applicants and vendors are free to comment on these changes, and in doing so, they frequently impact the FCC’s thinking. This process has worked for years and I suspect that it will continue to work, i.e. there will continue to be an eligible service list that is reviewed and updated annually.

Why then is “reform” of the ESL getting so much press? Does President Obama really need to launch an initiative to revise the ESL?

E-rate modernization should not be focused on eliminating services from the eligible services list. The framework of the ESL is NOT broken. As originally intended, the E-rate program was designed to provide discounts for the communication needs of schools and libraries. The ESL does not in any way work against the goals of the program. On the contrary, the relatively open nature of the ESL has allowed the E-rate program to adapt nimbly to the changing communications needs of schools and libraries.

Case in point: Was it necessary for the FCC to eliminate network cabling from the ESL in order to make room for WiFi equipment? Was it required that the FCC remove network hubs from the ESL to allow support for network switches? And did the FCC have to take paging service off of the ESL to encourage schools to move to cellular communications? The answer in each and every case is no.

Schools and libraries – all on their very own — are quite adept at transitioning to new and improved technologies. The professional educators and library staff that I deal with demonstrate an uncanny ability to adapt and marshal their limited resources to serve the needs of their students and community members – and they do so under intense scrutiny, knowing that the stakes are high, both for the long term enrichment of lives, as well as in the practical day-to-day (sad) reality of physically securing 110,000+ facilities nationwide.

This brings me back to the topic of E-rate reform. From my perspective, there are only two items that need reforming: (1) the amount of support available, and (2) the method of allocating that support. FCC Chairman Wheeler has promised to take a good hard look at the amount of funding available and adjust it if necessary. I believe he is sincere in this conviction and that he will make good on his promise. In which case, the main debate we need to be having today concerns the allocation of support. How does a limited supply of E-rate funding get spread out among all of our nation’s schools and libraries?

The FCC has acknowledged that its current allocation method (a.k.a. the priority system) is not working well. FCC Chairman Wheeler recently discussed the shortfalls of the system, and Funds For Learning has repeatedly illustrated its drawbacks, such as unnecessarily long application review times.

But some of the commenters in the recent NPRM seem to think that reducing the eligible services list and keeping, but shifting, priorities is the best means of allocating funds. I disagree.

Why would we continue with a two-tier system that offers undue complexity, slower funding commitments, and incentives to game the system? Why would we further complicate the program by excluding support for voice services? Shouldn’t the E-rate program be agnostic about the types of communication that it supports? Are we really going to deprioritize voice service? What does that even mean? Are videos and email more important than voice?

A nationwide transition away from analog plain old telephone service is under way. It is only a matter of time until older voice technologies go the way of the 8-track cassette tape; but it is not the job of the E-rate program to advance the agenda of the big telecommunications companies. Schools will make the switch at the right time, just like every other consumer, as their needs and opportunities dictate. Furthermore, our long history with the current priority system illustrates the profound weakness of a funding allocation mechanism built on homogenizing the priorities of a group of stakeholders as diverse as E-rate applicants.

I believe that funding support should be weighted based on applicant need (i.e. discount rate), not the level of technology that they possess. Stripping away support from the schools that have the least technology resources hardly seems to be an equitable approach. The Funds For Learning E-rate 2.0 proposal maintains the current discount matrix, eligible services list, and application review process. It provides specific protection for small and rural schools, while giving every applicant the opportunity to receive discounts annually based on their own specific needs and priorities.


I was invited to speak on an E-rate panel this past week at the CoSN annual conference in Washington, DC. I spent most of the week there talking with the best and brightest practitioners from around the country (and the world.)  As always, I was blown away by the hard work and innovation of the EdTech community. As I flew home Friday night, I walked away with a renewed sense that schools and libraries do not need the FCC telling them what their priorities should be – all they really need is the FCC’s continuing support (and more of it!)

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