Initial comments on the FCC’s Public Notice on E-rate modernization (DA 14-308) were due last Monday. As of the end of last week, approximately 700 comments had been filed. Eliminating a substantial number of apparent duplicates (close to a hundred filed by one individual), the filing total was closer to 550. Of these, roughly 150 were more than simple one-pagers, usually with some substance.
To search for all filed comments in this proceeding, use the search function in the FCC’s Electronic Comment Filing System. Enter “13-184” in the Proceeding Number field, and click the “Search for Comments” button near the bottom of the screen.
Those wishing to explore a somewhat more manageable list of comments may be interested in the following:
In reviewing these comments, we believe it is important to focus on the following four key elements of the E-rate modernization proposals put forth by the FCC:
- Replacing the current two-priority system with a new two-category system, each separately funded.
- Within each category, emphasizing broadband services and phasing out support for voice and other "legacy" services.
- Considering several ways to allocate funding for broadband internal connections.
- Providing an additional $2 billion in E-rate funding for FY 2015 and FY 2016.
Based on a preliminary review of the initial comments filed in this proceeding, it appears that there is widespread agreement on basic issues and goals, but equally widespread disagreement on the detailed nature or timing of the changes required. In particular:
- Almost all agree with the Commission’s focus on broadband, and that support for broadband services must extend all the way to the classroom.
- Many agree that it would be advantageous to treat broadband internal connections as a separately funded category rather than as a lower priority.
- There appears to be no consensus as to which of the three alternative proposals for allocating internal broadband funding is best.
- All agree that E-rate funding is limited, and that, even with the addition of $2 billion over the next two years, a long-term solution will require some combination of additional funding, the narrowing of eligible products and services, and/or cuts in discount rates.
- There is a general acceptance of the need to phase out eligibility of voice and other “legacy” services, but the extent and timing of the phase-out(s) remain controversial.
Reply comments in this proceeding are due April 21, 2014.