E-Rate-Funded Networks Should Be Extendable Off-Campus for Educational Purposes

Recently, OTI and several other public interest organizations filed comments and reply comments in support of two petitions asking the Federal Communications Commission (FCC) to waive certain rules in the E-rate program (The FCC’s E-rate program helps fund broadband networks at schools and libraries.) that have prevented some schools from extending their networks to the homes of low-income students.

School districts in Boulder, Colorado, and southern Virginia receive E-rate funds to help pay for their broadband networks. Both school districts want to extend their E-rate-funded broadband service beyond campus and to the homes of low-income students nearby to provide those students free Internet access for educational purposes. In these specific cases, the schools will incur no additional charges because the equipment and labor is being donated or paid for by local housing authorities (in CO) or Microsoft (in VA).

Unfortunately, the FCC’s E-rate rules act as a disincentive for schools to extend their networks off-campus. The rules say that any off-campus use of E-rate-funded networks cannot be for educational purposes. Not only are those costs not compensable under the E-rate program, the off-campus use of the network would have to be “cost-allocated,” meaning the schools would receive fewer E-rate dollars because of the non-educational use.

However, the petitions describe plans that would allow students who lack at-home internet access to have access to the E-rate-funded network for educational purposes. The rules prevent schools and their students from realizing this benefit. Thus, the school districts asked the FCC to waive the cost-allocation rule in their situations and issue a clarification that similar networks are permitted under the E-rate rules.

OTI supports extending E-rate networks off-campus for home use by students and for educational purposes. Our comments argued the FCC should not only grant these waivers, but should issue a clarification that off-campus use of E-rate-funded networks can have educational purposes and thus expenses incurred in expanding networks for off-campus use should be a recoverable expense under the E-rate program. This type of declaration would mean that all schools, not just those with benevolent outside donors, would be encouraged to extend their networks off-campus for educational purposes because those costs would be incorporated into the E-rate subsidy.

Clarifying the rule would increase the educational value of the networks and help narrow the digital divide. For instance, it would increase the utility of E-rate-funded networks because the networks would be usable during normally-dormant periods, tapping into unused capacity. For schools that provide devices (perhaps as part of a “one-to-one” teaching program), those devices would be more useful because they could be used at home by students. Moreover, allowing schools to extend free Internet access to low-income households could reduce the cost of connectivity and help bridge the digital divide, at least for educational use, by getting more students online at home. The exposure to the internet may even encourage some disconnected low-income households to seek Lifeline subsidies to get online full-time.

Internet access for low-income households is vital. The FCC should use this opportunity to encourage schools to help bridge the digital divide by extending their networks to low-income students for educational purposes.