Through the recently enacted American Rescue Plan Act of 2021, Congress established a $7.17 billion Emergency Connectivity Fund (ECF) for broadband internet service and equipment to support remote learning during the COVID-19 pandemic. On March 16, 2021, the FCC began the rulemaking process by issuing a Public Notice seeking comment on the application process and distribution of funding to schools and libraries.
The Public Notice requested input on several aspects of the new program, including:
- Administration of the ECF
- Eligible schools and libraries
- Eligible equipment and services
- Reasonable support amount
- Application process
- Prioritization of funding
Nearly 100 initial comments and more than 90 reply comments were submitted in response to the Public Notice, with broad support for the ECF program.
Funds For Learning was among the many stakeholders filing reply comments last week. In our comments, we urged the FCC to:
- Build upon and leverage the success and resources of the E-rate program
- Ensure an efficient and equitable distribution of funding for schools and libraries
- Provide schools and libraries with flexibility to select a technology solution that best meets their needs
- Promote fiscal responsibility and safeguard limited public
We also made the following recommendations:
- In determining what amount of support is “reasonable,” a modified version of the E-rate program’s Category Two budget system should be used to calculate available funding on a per-applicant basis, with reimbursement authorized for eligible expenditures up to that amount.
Under this model, the Reasonable Amount for Reimbursement (RBAR) would be calculated using the formula below:
School RBAR
School RBAR = Student Enrollment × E-rate Discount × $157
Library RBAR (maximum of the following two equations)
Library RBAR = Square Footage × E-rate Discount × $4.50
Library RBAR = E-rate Discount × $25,000
We believe this model provides the most efficient, equitable, and predictable distribution of funds, guaranteeing access to funding for all schools and libraries while targeting those with the most need.
- Rather than limiting support to a narrow list of eligible services, ECF support should be available for any service or equipment that a school or library deems necessary for remote learning.
The objective should be to provide schools and libraries with maximum choice to select a solution that works best for them. Because schools and libraries are in the best position to determine which solution works best for them, we encouraged the FCC to empower schools and libraries to make purchasing decisions without excessive regulation and administrative complexity.
- Open a 45-day application window to ensure schools and libraries have sufficient time to plan, prepare, and submit applications.
Noting that schools and libraries will need time to prepare applications and, if necessary, conduct procurements, we encouraged the FCC to open a 45-day window rather than limiting the ECF filing window to 30 days.
- Leverage existing E-rate program oversight controls and practices to promote fiscal accountability and safeguard program funds.
Because the E-rate program has tools in place which can be used to guard against waste, fraud, and abuse, we encouraged the FCC to use these measures to ensure compliance with ECF rules with minimal disruption to program participants.
FFL’s reply comments may be viewed here.
All comments and reply comments can be viewed via the FCC’s Electronic Filing System: https://www.fcc.gov/ecfs/search/filings?proceedings_name=21-93&sort=date_disseminated,DESC
