On January 29, 2024, Funds For Learning submitted comments to the Federal Communications Commission regarding their proposed $200 million, three year cybersecurity pilot program. Our comments focused on three areas of the FCC’s proposed pilot: the length of time the pilot should be run, the amount of funding allocated to the pilot, and the framework for determining the products and services eligible for funding.
Three years is too long
Rather than run the pilot program for a set time period of three years, we suggest the FCC run the program for a single service delivery period: twelve months for recurring services, and the useful life of an asset (observed over one year) for non-recurring services. We think this would allow for the collection of an adequate data set while speeding up the opportunity to provide support to more applicants through future E-rate rule changes.
Start with $312 million
We suggest the FCC fund the pilot with $312,432,660. Why? In our 2021 report, Funds For Learning and the Consortium for School Networking (CoSN) estimated that the average cost per applicant for robust cybersecurity funded by the E-rate program was $146,682. If we use that per-applicant cost for roughly 21,000 applicants (the number who applied for discounts in Funding Year 2023), using $312 million over a two-year period would allow for a pilot program sample size of about 5% of all applicants. This would allow for a diverse range of applicant types, sizes, and technical solutions to be evaluated.
No need for an ESL
Rather than establish a set “menu” of eligible products and services for the pilot, we suggest the FCC use the guiding principle of protecting E-rate-funded networks, along with their proposed “pre-screening” mechanism of selecting only projects determined to be targeting that goal. This would put power in applicants’ hands by allowing innovative and technologically advanced solutions to be funded and studied, while keeping the scope of projects narrow enough to review with consistency.
Having advocated for stronger network security in the E-rate program for more than ten years, we are excited that the FCC is considering a pilot to help schools and libraries while collecting data that can be used to strengthen the E-rate program in the future. But the need is urgent! We are hopeful that a balance can be found that allows for the collection of quality data while expediting much-needed E-rate modernization to protect school and library networks.
Our comments may be viewed here. What do you think? Contact us and share your thoughts today!
