The FCC has received plenty of input from the cable industry on its proposed reform/modernization of the E-rate program, which provides subsidies to schools and libraries for advanced telecommunications.
The National Cable & Telecommunications Association said in its comments that the FCC should focus on student bandwidth needs rather than specific bandwidth targets, simplifying the process, improving outreach and working within a "firm" budget, which means balancing increased costs with savings and not prioritizing fiber deployment over other services. NCTA also advises allocating more wi fi spectrum.
The American Cable Association also wants the FCC to keep to a budget and simplify the process. It puts a premium on gathering more data before the FCC remakes the program, and on using existing facilities as much as possible.
The FCC has proposed some high-speed targets, but NCTA says that "one-size-fits-all" approach may not be the best, and could lead to insufficient funds for other important elements like teacher training and devices. The cable group points out that schools are already able to purchase service at the target speeds. "There is nothing in the current E-rate rules that prohibits schools from soliciting bids for connectivity at 100 Mbps, 1Gbps, or more," said the association. "Rather than encouraging or mandating that schools purchase particular levels of bandwidth, the Commission should focus its efforts on creating an environment where schoolsare more likely to solicit bids for those high-capacity services and more likely to have the resources to deliver faster speeds to students in the classroom."
NCTA also said the FCC cannot "divorce the question of cost" from its bandwidth goals. One way to find money within the program to fund broadband would be to cut out subsidies to stand-alone voice service, but NCTA warns a "flash cut" could hurt schools and libraries (and telecoms).
The cable group said the FCC should remove the current distinction between connections to the schools and libraries (priority one) and internal connections (priority two), which often go unfunded. That is where more Wi Fi could help: "NCTA supports targeting E-rate support to Wi-Fi services that will foster connectivity to classrooms and other areas in the school where students congregate in a cost effective manner and make it more likely that schools will be in a position to take advantage of higher capacity offerings from service providers."
If after reprioritizing and refocusing the fund and balancing costs and savings, the FCC concludes it must still expand the size of the fund, it should be clear from the outset how much it is expanding, and set a cap on the Universal Service Fund so that the expansion is paid for with savings from other parts of the USF fund, particularly the "bloated" high-cost program.
In its comments, the American Cable Association said that before the FCC does anything, it needs to gather more data, including on "existing infrastructure, broadband dependent applications and services (and their performance requirements) used today by teachers and students and those that are likely to be used, and the number and types of access devices and technologies used today and those expected to be used in the near future."
ACA's key policy proposals are that the FCC should 1) use existing facilities as much as possible, requiring certification that a school or library had made "all reasonable efforts" to receive high-speed connectivity using existing facilities; 2) capping the current fund at $2.25 billion; and 3) simplify and standardize the process.