The Schools, Health, Libraries Broadband Coalition (SHLB) filed comments to the FCC on September 26, 2018 in support of New York City Board of Education’s July 2018 appeal tied to “duplicative services”. In FY2014, New York City Schools was denied $760,400 in E-rate support and filed an appeal with the FCC. USAC denied New York City’s application applying the Macomb precedent from May 2007 that “…..the Commission found that applicants must select the most cost-effective service offering, and price should be the primary factor considered when determining which service offering is the most cost-effective…..requests for duplicative services, described as services that provide the same functionality for the same population in the same location during the same period of time, will be rejected…”
 
The attack on the World Trade Center in 2001 brought down the school’s only Internet service provider and the school system had similar issues in 2012 with Hurricane Sandy and sought to address these concerns in FY2014 with their E-rate applications. In support of New York’s appeal, SHLB stated, “….E-rate applicants could be similarly left without service in the event of a flood or other natural disaster, or simply because of accidental fiber cut. Due in large part to the E-rate efforts of the Commission, broadband has become a pervasive and necessary resource for our nation’s schools and libraries. It has fundamentally changed — and continues to change — the way our schools operate, communicate, perform administrative tasks, and educate our children. Particularly for schools, network reliability has become absolutely essential. Loss of Internet capability, especially during periods of intensive online testing, can leave schools without a “plan B” and waste valuable instructional time. Further, loss of services can be a school safety issue as well. Many schools and libraries now may rely on the same lines and Internet access to receive VoIP telephone service. If the Internet is down, so are the phones, limiting a school’s ability to contact first responders in the event of an emergency….”
 
The New York City appeal can be viewed here
The SHLB Letter of Support can be viewed here