Yesterday, we filed comments in the FCC’s proceeding to modernize the E-rate program to meet President Obama’s goal of bringing broadband to every classroom in America. We fully support this goal and we look forward to working with the Commission to make it happen.

The current structure of the E-rate program does not reflect the reality of today’s rapidly growing high-speed world. Therefore the program should shift from supporting basic telecom and Internet access services to supporting the expansion of high-speed broadband connections into every school and library. Not only should broadband be prioritized over other services when it comes to receiving funding, but the Commission should also put funding toward ensuring adequate internal connections within these institutions. Access to broadband is useless if you don’t have sufficient inside wiring or electronics.

An additional priority for a modernized E-rate program should be addressing the needs of those schools and libraries that currently have either inadequate or no broadband service at all. Getting high-speed broadband connections into these anchor institutions will not only have an immediate, and positive, impact on students and teachers but it will also help the surrounding communities by increasing everyone’s access. What stands to undermine this effort, however, is the proposal to put E-rate money toward the build out of private fiber networks to institutions that already have adequate access to broadband. It is wasteful, inefficient and makes no sense to fund additional, private networks where commercial providers are already making high-speed broadband available.

While there are many changes that we think should be made to the current E-rate system, there is one thing that must remain the same and that is that it continues to operate in a technology-neutral manner. Proposals to favor the use of dark fiber over other technologies to roll out high-speed broadband are woefully misguided. Wireless data, cable and satellite are just a few of the other technology platforms that can and should be considered as viable options and must receive comparable funding to dark fiber. One technology platform is not going to meet the needs of every school and library across the country. These institutions must be afforded the option of choosing the technology that enables them to get the best quality and most reliable high-capacity broadband service.

We applaud the Commission for its commitment to ubiquitous high-speed broadband in our country’s schools and libraries. Updating the current E-rate system is an enormous task. And while we don’t agree with some of the Commission’s proposals (including making bid responses and the various prices schools and libraries pay public, or carving out some applicants or service providers from compliance audits), we appreciate the opportunity to weigh in and we look forward to continuing to work with the Commission to ensure that all students in this country are brought into the digital age and given the tools they need to succeed in the 21st Century.

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