More than 90 comments have been submitted to the FCC in response to the Emergency Connectivity Fund rule making process. The Emergency Connectivity Fund (ECF) was created by Congress as part of the American Rescue Plan Act (H.R. 1319 § 7402). It provides up to $7.171 billion in reimbursement to schools and libraries who are providing students, staff and library patrons with off-campus internet access during the COVID-19 pandemic.
The FCC is set to release rules next month that will govern the program. The FCC has asked for input on such topics as who should receive support, what types of goods and services should qualify, the best method to prioritize requests, the application process and the administration of the fund, among other things.
The initial round of comments provides a range of opinions and perspectives. There is a broad recognition that communities would benefit from this support for schools and libraries, while commenters do differ in opinion on several important topics.
For example, many school and library organizations suggest that applicants be allowed to purchase network equipment to extend their Wi-Fi to off-campus locations. In contrast, many telecom service providers suggest that applicants only be allowed to subscribe to services that provide such connections.
There is also debate about service requirements. Many commenters agree with the suggestion that there be minimum performance standards for services (e.g., bandwidth) and equipment (e.g., screen size and video conferencing capabilities). Others disagree, citing the lack of necessity for standards in the current E-rate program. Closely related to this discussion are the different perspectives on support for end-users’ devices and network infrastructure. Beyond laptop hardware, should schools and libraries be allowed to license and/or purchase other required components for remote learning, such as operating software and communications platforms? Headsets and video cameras? If remote learning requires an upgrade of network components or cybersecurity resources, should the ECF provide support?
Another area with differing viewpoints is the best method to allocate support, particularly if demand exceeds the overall available funding. Most commenters cite either a “Category 2” style applicant funding cap, or a “Priority 2” style discount threshold system. Intermixed among commenters are varying opinions of price controls for individual services and/or equipment.
Below is a list of many of the comments already submitted. Reply comments are due April 23, 2021.
