Dear Chairman Wheeler,
Although I do not fully agree with it, I want to thank you for putting out a specific plan to reform the E-rate program. It is one thing to talk about the need for change. It is something entirely different to propose concrete steps to bring about that change. And for that effort, I applaud you and the FCC staff. No proposal will be perfect – as no new set of rules will be perfect – but I am grateful that we are finally at a point where specific rules and proposals are being debated.
Because there is a narrow window for meaningful reform to be enacted prior to the next application cycle, I want to share a few specific principles that I believe should guide this final phase of E-rate Reform.
1) Make rules that will last. The change that is implemented in July should stand on its own without an additional Public Notice and rule making. That is not to say that there will not be another round of changes; but whatever plan goes into effect should be a plan that can stand on its own indefinitely, should the need arise.
2) Keep the current eligible service list (ESL). Avoid the complexity and controversy of eliminating goods and services from the program. The structural changes you have proposed do not require it.
3) Keep the current discount matrix. Doubling the out-of-pocket expenses for schools and libraries in our nation’s poorest communities will not speed up the deployment of critical on-campus connectivity.
4) Increase the cap as much as you can. I do not pretend to understand all of the math, geopolitical factors, and regulations involved in setting the E-rate funding cap. But there are people at the FCC who do. Please find out from them the maximum feasible level of support and then set the dial at that level. I promise you, whatever the number, it will still fall below the true need that exists in today’s schools and libraries.
If I have criticisms of your plan, I will keep them productive, and every complaint I may have will come with a proposed solution — and not just one that calls for more money.
Funds For Learning stands ready to work with you and the rest of the FCC Commissioners and staff to provide whatever information, ideas and/or insights that we can to help the current debate remain fruitful and focused on the goal: a refined E-rate program, building on its past, preparing for the future, sustainable and highly effective in serving the technology needs of all schools and libraries within the United States and its territories.
John D. Harrington