I was at the USAC E-rate applicant training in Atlanta this week and a school E-rate administrator asked the USAC about having redundant networks funded as part of the E-rate program. Unfortunately, the answer is that redundant, spare, or excess goods and services are considered ineligible under the FCC’s Eligible Services List.
The question got me thinking about redundant services. Any technology director can tell you why it is important to build redundancy into critical networks. If an important component of a network goes down without a backup, such as a hardware failure in a backbone switch, or a cut in a fiber optic cable, communication to a school building can be lost entirely. In an educational environment where Internet access provides online learning and testing, and even has implications for campus security, the loss of all communications is simply not acceptable.
However, the FCC currently does not provide financial support for these types of services. Why? Most likely because they know that the E-rate fund is already oversubscribed. Furthermore, it is difficult to define on paper which services are mission critical and how much redundant capacity should be allowed because these factors vary from school-to-school. Regrettably, the FCC’s current position denies applicants funding for mission-critical services, and even leads to funding delays as USAC must ferret out any so-called “redundant” services from otherwise eligible funding requests.
This should not be the case. Funds For Learning believes that an E-rate applicant should be given the opportunity to select redundant services if they believe that the service is important enough to warrant their E-rate discounts. In our recent NPRM comments, we suggested a new priority system that would allow each applicant the chance to set their own funding priorities. This would eliminate many current program complexities, such as the 2-in-5 rule, discount thresholds, and the criteria for on-premise equipment. Under the Funds For Learning proposal, the FCC could expand the eligible services list. New telecommunications services and networking technologies, and, yes, even redundant Internet access, could all be requested based on the priorities of each local school and library.
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School districts have filed comments in support of the Funds For Learning proposal. If you are interested in learning more about our ideas for improving the E-rate program, we can be reached at info@fundsforlearning.com.
