Barack Obama – POTs and PANs

On July 23 the FCC released a Notice of Proposed Rulemaking in WC Docket No 13-184 that asks questions about modernizing the E-rate program for schools and libraries. The E-rate program has been around for a few decades and has been used to bring broadband to schools and libraries.

But last month President Obama announced a ConnectED initiative that has the stated goal of bringing a minimum of 100 Mbps and a goal of 1 Gbps to 99% of students within five years. This NPRM is in response to that initiative.

A 2010 FCC survey showed that only 10% of schools had speeds of 100 Mbps or greater. 48% of schools had speeds less 10 Mbps. 39% of schools reported cost as the barrier to better speeds while 27% cited the cost of installation as a barrier. And the situation is worse in our libraries. In a 2011 survey by the American Library Association only 9% of libraries have speeds of 100 Mbps or faster while 25% still have speeds of 1.5 Mbps or less.

There is clearly a need for revised E-rate funding. In the most recent year there were requests for funding from schools of over $4.9 B from a fund that is at an annual cap of $2.25 B. The E-rate program is funded today as part of the Universal Service Fund that gets fund by a surcharge put on a wide variety of telecommunications end-user bills.

The FCC has laid forth new goals for the E-rate program and also suggested a number of specific changes. The new goals include 1) That schools and libraries have affordable access to broadband in order to meet the goals of ConnectED; 2) that the effectiveness of the E-rate funding is maximized, and 3) that the administration of the program is streamlined.

The FCC seeks comments on the specific speed requirements needed for schools and libraries. They offer the target established by the State Education Technology Directors Association (SETDA) which suggests that K-12 schools should have at least 100 Mbps per 1,000 students by 2015 and 1 Gbps for every 1,000 students by 2018. For libraries they offer the State Library of Kansas recommendation that all libraries should have 1 Gbps connectivity by 2020.

One of the issues that the NPRM looks at is how to get the bandwidth around the school once it’s delivered to the side of a school. This is a significant issue because today’s wiring technologies and wireless technologies have a steep drop-off in data speeds over even short distances. So the NPRM looks for comments on how to best get the bandwidth to classrooms. The State E-Rate Coordinators Association (SECA) has suggested that this issue is of high enough importance that it ought to be at the top of the priority list for E-rate funding.

The NPRM asks questions about increasing the efficiencies of buying broadband. This includes consortium purchasing and other bulk buying opportunities. The larger school districts are able to negotiate better rates today than small school districts due to the fact that they serve a significant number of schools. There must be ways for neighboring districts to band together for efficiency (although local politics is often a barrier to this process).

The NPRM also asks what the funding should be used for. It suggests that funding be transitioned to support only broadband. The funding is currently used for a number of other purposes which were allowable under the old rules. For example, in the most recent funding year there were requests for $260 M to subsidize telephone lines.

Finally, the NPRM looks at who is eligible for the E-rate program. Today the program pays for some portion of eligible costs based upon the percentage of student enrollment that is eligible for a free or reduced price lunch in a given school. The school gets a discount based upon that factor and must then match between 10% and 80% of the cost. The NPRM looks at alternate eligibility requirements including (1) revising the discount matrix to increase certain applicants’ matching requirements; (2) providing support on a district-wide basis; (3) revising the approach to supporting rural schools and libraries; (4) incorporating a per-student or per-building cap on funding into the discount matrix; (5) providing more equitable access to priority two funding; and (6) allocating funds to all eligible schools and libraries up front.

Comments in the NPRM are due to the FCC by September 16, 2013. CCG Consulting will probably be making some comments in the Docket, so if you have anything you want to say let me know and it can be included in our filing.

English: Satellite Internet dish attached to a building in rural America (Photo credit: Wikipedia)

Earlier this month President Obama announced an initiative to get 1 Gbps or at least 100 Mbps broadband to 99% of schools within five years. The new plan is being referred to as ConnectEd and the citation takes you to a posting on the White House web site that outlines the program.

The program will have several components. The one that will be most familiar to the readers of this blog is that the program will provide improved connectivity through the E-Rate program that is part of the current Universal Service Fund. The E-Rate program for years has been providing subsidies to bring broadband to schools and libraries in the poorest communities. One has to imagine that the FCC is going to expand that program to include money to build fiber in rural communities. It’s not clear yet how it will work, but the administration has said that the NTIA (National Telecommunications and Information Administration) will take a lead in moving the program forward.

The second component of the plan will provide more training for teachers to be proficient in the technology that broadband will bring to the schools. This will be done with funding through Title II and Title VI programs through the Department of Education.

I don’t think there is anybody who can fault the goal of this plan which is to make sure that kids have access to broadband at school. Certainly students at schools that do not have broadband access will fall behind everyone else.

But for rural areas this is not enough. Over the last few years there has been a number of ‘middle-mile’ fiber networks built as part of the BTOP program using money from the 2009 Stimulus program that built rural fiber. The middle-mile projects built fiber through rural areas and also connect to ‘anchor institutions’ in those areas, meaning schools, universities, libraries and government buildings.

But in far too many cases those are the only places that got broadband out of the billions of dollars that were spent to build fiber. This is not a blanket indictment of the BTOP program because in some cases that fiber has been an incentive for carriers to build last mile fiber or wireless networks to serve rural customers. But I am also aware of many examples of BTOP fiber networks that bring fiber through a rural town, connect a school and a City Hall and nobody else.

And in many of those communities the existing broadband is poor or non-existent. It is very typical to have some sort of broadband in the towns in rural counties – generally DSL supplied by the phone company or cable modems supplied by a cable company. But in most cases the broadband in these towns is far slower than what is routinely available in big cities. But one generally only has to go a mile or two outside of these rural towns and the broadband stops. There are hundreds of counties that have this situation.

And in a lot of these areas without landline broadband there is also inadequate wireless broadband. Fiber is needed to provide broadband to cell towers if we want to use them to provide 3G or 4G data. Most rural cell towers were built along highways to serve cars and are not built where people live. And so in many rural areas there is no effective broadband.

And so it leads me to ask if there is not some way to help the communities around the schools while we bring broadband to the schools. 100 Mbps or 1 Gbps to a school is a great thing and I applaud this effort. But are we really helping rural students if once they leave school they don’t have enough broadband to do homework?

The original BTOP program that built fiber through rural communities did not go far enough. We need some way in this country to now build the rest of the fiber network and connect everybody. I would be a lot more excited about this announcement if it said that we were going to bring fiber to 99% of rural homes in five years.

I work with a lot of rural communities trying to get funding to build fiber and it is tough. These projects suffer from having a large infrastructure cost per household due to the sparse population in rural areas. These projects have a hard time getting funded through traditional funding sources like municipal bonds. If the federal government really wants to help rural areas get fiber they should be looking at ways that would help get rural fiber projects funded.

I don’t think it’s necessary for the federal government to step in and hand out the money to build rural fiber. That would probably just give us more BTOP programs and networks. But there are concrete steps the federal government could take that would make it easier to get this done. Rural communities are willing to pay for fiber themselves, but that desire is meaningless if nobody will lend them the money. So the best way to help rural America get broadband is to make it easier for rural communities to do it themselves. That is going to mean something like loan guarantees or lower interest rates for these projects.

The federal government already operates a ‘bank’ to provide rural broadband at the Rural Utility Service (RUS) that is part of the Department of Agriculture. But that money is so hard to obtain by rural governments that it might as well not exist. It would be easy to make the RUS into a functional program – it just takes the will to make it work.

In the last year we have had two big announcements at the federal level about broadband. One was to promote gigabit cities and now we will have broadband to 99% of schools. I am still waiting for the announcement that matters – to bring broadband to people.

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