The initial comment deadline for the Federal Communications Commission’s E-rate hotspot Notice of Proposed Rulemaking was January 16, 2024. The Commission received more than 60 comments during the initial comment period, with commenters showing a mixture of support and opposition for making Wi-Fi hotspot service eligible for E-rate discounts.
No arguments about the need
If there was one topic where there was near unanimous agreement among NPRM commenters, it was the clear and urgent need for student internet access off-campus. Commenters disagreed on the best way to support that need, but all seemed to agree that the necessary tools for remote learning are no longer a luxury but a necessity.
Is E-rate the solution?
Supporters of the proposal argue that the E-rate program is an efficient and effective way of addressing the homework gap using a mature program with existing checks and balances. Those who oppose the proposal argue that the laws governing the E-rate program do not allow for support outside school or library property and/or that other federal programs are more ideally suited to address at-home connectivity.
E-rate applicants support Wi-Fi hotspots
Most of the schools and libraries who submitted comments were in favor of adding Wi-Fi hotspots to the E-rate program’s Eligible Services List. Further, many advocated for broadening the scope of eligible services to include broadband technologies other than hotspots in cases where alternative modes of connectivity could be proven cost-effective.
Cost concerns
A number of commenters expressed concern about the potential cost of adding hotspot service to the E-rate program, with some supporting per-applicant device count or funding amount caps. Other commenters suggested restructuring the program’s funding prioritization mechanism to ensure that on-campus connectivity continues to be the primary focus. Funds For Learning estimates that adding hotspot service to the program would increase the total demand for E-rate funds by approximately $198 million.
A worksheet with links to all comments may be accessed here. The reply comment period for the hotspot NPRM closes January 29.
