It’s the beginning of a new calendar year which seems to be a fitting time for lists. Below is my E-rate wish list, divided into “Starts” and “Stops”.
STARTS
1 – Start Funding Voice Services
For schools and libraries, voice is not an app. It is a communications service. More than that, it is a critical service, in the truest sense. Removing voice services from the eligible services list has not encouraged schools to use more broadband data services (Hint: schools and libraries have plenty of incentive to reduce their monthly expenses and to increase their Internet speeds without additional “encouragement”.) The FCC is scheduled this year to assess the phase down of voice services. I am hoping they will listen to applicants and restore funding for this important service.
2 – Start Accepting E-filed Forms
The IRS started receiving electronically filed tax forms in 1986, over thirty years ago. Let that soak in for a moment. When Ronald Reagan was still President, the IRS began allowing tax preparers to electronically submit paperwork. It is time for E-rate to do the same. The FCC Modernization Order instructed USAC to create an API for electronic form submission. Currently, applicants and service providers are at their wits end trying to use USAC’s proprietary EPC system. It does not have to be this way. A small fraction of the time and money being invested in EPC could be used to publish and prepare an open standard for electronic form submission.
STOPS
1 – Stop Dictating Technology Choices
Schools and libraries do not need outsiders telling them which technology best suits their needs.
A strength of the E-rate program is the flexibility it provides individual applicants to determine their own specific technology needs. Many funding sources require applicants to bend their needs to meet a particular funding source’s flavor-of-the-month. Not so with the E-rate program. It supports connectivity into schools and libraries, but the details of how that happens is left up to the applicants themselves – or so it was originally intended. Over the past few years, a troublesome trend has developed in which applicants more and more are being influenced or outright told which technologies they must use, or what network topologies will be supported.
There is no one-size-fits-all solution for every school and library. Local decision makers know best what their needs are and how to meet them – and it should stay that way.
2 – Stop Denying Alternate Internet Access
Schools and libraries do not need outsiders deciding how much Internet bandwidth they need.
Internet access is crucial. The E-rate program already acknowledges that certain key infrastructure needs to be up and running (i.e. universal power supplies can be purchased with E-rate discounts). Therefore, why in the world, in the year 2017, are applicants denied funding for “spare” Internet connections? Presumably the rules against spare or redundant Internet access are intended to guard against excess. Guess what? The E-rate is a discount program and every dollar spent comes with some skin in the game for schools and libraries. They do not have piles of money laying around looking for ways to spend it. If an applicant believes that they need more Internet, or redundant Internet or an alternate connection, from a different vendor, or from a different side of the road, then please, save everyone the extra work, and just fund it.
3 – Stop Second Guessing Vendor Selection
Schools and libraries do not need outsiders choosing their vendors for them.
It is VERY important that applicants follow their state and local competitive bidding rules; and the FCC was wise when it designed the Form 470 process to promote competition. Schools and libraries should not waiver from these bedrock requirements.
At the same time, we should all be mindful of the fact that it is the applicants who choose the winning vendors. School Boards, Superintendents, Chief Officers, and Procurement Directors are accountable to their local communities for the decisions that they make. Their judgement, and not a third party, should be the driving force behind the vendor selection process. USAC should continue to ask the question “Did you follow the competitive bidding rules and comply with the Form 470 requirement?” But, beyond that, we should all avoid second guessing the work and judgment of school and library professionals. (The FCC’s recent Sweetwater Decision is an encouraging step in that direction.)
*****
Almost every school and library system in America depends on the E-rate program. In 2017, we should all commit to doing all that we can to help this program become stronger and to serve its constituents even more effectively.
