Last Wednesday was the deadline to file comments in “opposition” (or support) of the Petitions for Reconsideration filed by (a) the State E-Rate Coordinators’ Alliance (“SECA”) and (b) Infinity Communications & Consulting. As discussed in our newsletter of January 27th, the Petitions called for the FCC to amend its Category 2 Order (FCC 19-117) to (a) eliminate the requirement to allocate out of funding requests any Category 2 equipment used by standalone NIFs, and (b) reverse its decision to base Category 2 student counts on “full time” students only.
Both petitions had merit but generated little comment pro or con. Only SECA choose to file comments in support of Infinity’s request to reverse the FCC’s decision to exclude part-time students in the calculation of district Category 2 (“C2”) budgets. The basic argument is as follows:
The FCC’s original decision to set C2 budgets on the basis of a school’s full-time (“FT”) and part-time (“PT”) student enrollment made sense. Essentially, it adopted peak student count (FT + PT) as a proxy for the amount of data networking equipment required for each school. However, under the FCC’s revised C2 budget rules, effective FY 2021, school budgets are to be set on a districtwide basis counting only full-time students. On the surface, this approach would seem to simplify the budgeting process. But does the simplification make sense? That answer depends on the nature of a district’s schools.
In many districts, most students attend classes in only their home school. To the extent that a few students attend a second school for special classes, the number of PT students within a district is minimal. In such situations, the budgetary impact of ignoring the PT students in the district’s total student count is also minimal and can be justified as a reasonable simplification. But not all districts are comprised of traditional — essentially full-time student — schools.
Both Infinity’s initial petition and SECA’s comments argue that a blanket prohibition on counting part-time students does not make sense in establishing the networking needs of less traditional schools — most commonly career or other alternative education schools. The enrollment in these schools typically includes a large number of students who regularly attend classes on a half-day basis. The networking requirements of these schools — and thus of their district as well — would best be based on peak daily enrollment largely comprised of PT students. In particular:
- Not counting PT students in a district with a separate alternate-ed school understates that district’s C2 budget needs by an entire school. If, for example, a district has one alt-ed school and 20 traditional schools, the district budget shortfall would be roughly 5%.
- An even more serious problem arises with respect to independent Educational Service Agency (“ESA”) schools serving multiple districts. Without a proper definition of part-time students, an ESA district serving primarily PT students would have little or no C2 budget. In that case, the shortfall could approach 100%.
What the FCC really needs to do is to better define part-time and full-time students. This may mean continuing to recognize the peak student counts in all schools and/or adopting a measure of full-time equivalent (i.e., “FTE”) students. Hopefully we’ll see further support for this approach in reply comments on the Petitions due April 20th.