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Broad Support for Homework Gap Program

More than 90 comments have been submitted to the FCC in response to the Emergency Connectivity Fund rule making process. The Emergency Connectivity Fund (ECF) was created by Congress as part of the American Rescue Plan Act (H.R. 1319 § 7402). It provides up to $7.171 billion in reimbursement to schools and libraries who are providing students, staff and library patrons with off-campus internet access during the COVID-19 pandemic.

The FCC is set to release rules next month that will govern the program. The FCC has asked for input on such topics as who should receive support, what types of goods and services should qualify, the best method to prioritize requests, the application process and the administration of the fund, among other things.

The initial round of comments provides a range of opinions and perspectives. There is a broad recognition that communities would benefit from this support for schools and libraries, while commenters do differ in opinion on several important topics.

For example, many school and library organizations suggest that applicants be allowed to purchase network equipment to extend their Wi-Fi to off-campus locations. In contrast, many telecom service providers suggest that applicants only be allowed to subscribe to services that provide such connections.

There is also debate about service requirements. Many commenters agree with the suggestion that there be minimum performance standards for services (e.g., bandwidth) and equipment (e.g., screen size and video conferencing capabilities). Others disagree, citing the lack of necessity for standards in the current E-rate program. Closely related to this discussion are the different perspectives on support for end-users’ devices and network infrastructure. Beyond laptop hardware, should schools and libraries be allowed to license and/or purchase other required components for remote learning, such as operating software and communications platforms? Headsets and video cameras? If remote learning requires an upgrade of network components or cybersecurity resources, should the ECF provide support?

Another area with differing viewpoints is the best method to allocate support, particularly if demand exceeds the overall available funding. Most commenters cite either a “Category 2” style applicant funding cap, or a “Priority 2” style discount threshold system. Intermixed among commenters are varying opinions of price controls for individual services and/or equipment.

Below is a list of many of the comments already submitted. Reply comments are due April 23, 2021.

Comment Filer
ACA Connects
Alaska Communications
Alaska DOE & State Library
Alaska Telecom Association
Altice USA, Inc.
American Library Association
Ann Grabowski, Bena Chang
ARK Multicasting Inc.
Benton Institute
California Emerging Tech Fund
California IT in Education
Campbell Union School District
Center for Democracy & Tech
Central Texas Telephone Coop & Others
Cities of Los Angeles, Chicago, Portland, and Others
City of Waycross
Claudia Bill de la Pena
Common Sense
Competitive Carriers Association
Confederated Tribes of the Colville Reservation
Connected Nation, Inc.
Consortium for School Networking
Council of the Great City Schools
Education & Libraries Networks Coalition
Educational Service Unit #9
ENA Services, LLC
Energy Systems Network, Indiana 5G Zone
E-Rate Central
E-Rate Management Professionals Association
Fiber Broadband Association
Funds For Learning
GCI Communication Corp.
Genesee Valley/Wayne-Finger Lakes EdTech
Grand Rapids Public Museum
Hughes Network Systems, LLC
Infinity Communications & Consulting, Inc.
Internet Association
Kelly Wolfe
Kenneth H. Stone
KIPP DC Public Schools
Los Angeles Unified School District
Marie E. Bachman, Chief Technology Officer
Matt Perdew
Mayor James F. Kenney
Miami-Dade County Public Schools
Milwaukee Public Library
Motorola Solutions, Inc.
National League of Cities
National School Boards Association
Navajo Nation Telecommunications
NCTA – The Internet & Television Association
NEC Corporation of America
Next Century Cities
Norfolk State University
NTCA-The Rural Broadband Association
Oneida Nation
Oregon Department of Education
Public Interest Organizations
Qualcomm Incorporated
Samsung Electronics America, Inc.
Scott S. Brabrand, Superintendent
SHLB Coalition
Starry, Inc.
State Educational Technology Directors Assoc.
State E-rate Coordinators’ Alliance
State of South Carolina
Telecomm for the Deaf and Hard of Hearing & Others
T-Mobile USA, Inc.
Tony Thurmond
United States Cellular Corporation
USTelecom – The Broadband Association
Vector Resources dba VectorUSA
Viasat, Inc.
Virginia Department of Education
Western Governors’ Association
Wi-Fi Alliance
Wireless Broadband Alliance Ltd
Wireless Internet Service Providers Association
WTA – Advocates for Rural Broadband
ZP Better Together, LLC
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