New America's Open Technology Institute, the Center for Rural Strategies, the National Hispanic Media Coalition, Public Knowledge, X-Lab, and the United Church of Christ, OC Inc. (the "Public Interest Organizations," or "PIOs"), submit these comments in response to the Federal Communications Commission's ("FCC") Public Notice, Wireline Competition Bureau Seeks Comment on Petitions Regarding Off-Campus Use of Existing E-rate Supported Connectivity, seeking comment on petitions filed by (1) the Boulder Valley School District and (2) Microsoft Corporation, Mid-Atlantic Broadband Communities Corporation, Charlotte County Public Schools, Halifax County Public Schools, GCR Company, and Kinex Telecom (collectively the "Petitions").
OTI has previously supported giving greater flexibility to schools and libraries to provision their networks for the benefit of their communities. Providing Boulder and Southern Virginia, and all similarly situated school districts, such flexibility would further the goals of universal service and would further the educational purposes requirement of E-rate. The FCC should grant the Petitions and clarify that extending access to the Internet and to online school services for student and faculty off-campus can be an eligible expense under E-rate.
Read the full Comments here.