Earlier this month, at the American Library Association’s national convention, FCC Chairwoman Jessica Rosenworcel announced her intention to propose a “Learn Without Limits” initiative. If adopted, this initiative would make Wi-Fi on school buses and the loan of hotspots eligible for E-rate support (see our newsletter of July 3rd). Last week, in a speech before the School Superintendents Association (“AASA”) and the Association of School Business Officers, (“ASBO”) the Chairwoman expanded upon her Learn Without Limits plan by proposing a three-year, $200 million, pilot cybersecurity program. As proposed, the pilot would be funded within the Universal Service Fund but separate from the E-rate program.
The pilot program proposal follows an FCC notice issued last December seeking public comment on whether to add advanced firewalls or other network security services as E-rate eligible services. Details of the proposed pilot have not yet been disclosed and would be subject to further comment in a Notice of Proposed Rulemaking. Interestingly, however, the pilot appears similar in scope to an earlier proposal put forth by Funds For Learning (“FFL”) and cited in last December’s notice for a three-year program to fund advanced firewalls and services including the following capabilities: intrusion prevention and detection (“IPS/IDS”); VPN; distributed denial-of-service (“DDoS”) protection; and network access control (“NAC”). FFL further proposed that in the event demand exceeds available funds — a likely case if funding is limited to $200 million over three years — that pilot funding be prioritized to the applicants with the highest discount rates.
Funding for the proposed pilot is interesting. As indicated in the FCC’s press release, the $200 million pilot program would be established “within the Universal Service Fund, but separate from the E-Rate program, to ensure gains in enhanced cybersecurity don’t come at a cost of undermining E-Rate’s success in promoting digital equity.” Coincidentally — perhaps — in a Public Notice released last May, the FCC noted that USAC had projected that $440.22 million in unused funds were available for use in E-rate funding for FY 2023. The FCC directed USAC to use only $250 million of the unused funds for FY 2023 but to reserve the remaining amount — $190.22 million — for “future use.” The $200 million cybersecurity pilot may already have been largely funded.