9/19 Joint Filing Urging FCC to Modify E-Rate Hotspot Order to Better Serve Low-Income Students and Library Patrons

This petition for reconsideration was covered by Communications Daily and Broadband Breakfast.

The Open Technology Institute (OTI) at New America and several other public interest groups filed a petition of reconsideration at the Federal Communications Commission (FCC), requesting that the agency revise a July order—which made the off-premises use of Wi-Fi hotspots and commercially available mobile wireless internet services eligible for E-Rate funding—to better serve low-income students, staff, and library patrons.

OTI joined the Schools, Health & Libraries Broadband (SHLB) Coalition, the Benton Institute for Broadband & Society, the Consortium for School Networking (CoSN), and Common Sense Media in outlining multiple modifications that the FCC should make to its existing rules to more effectively bridge the digital divide.

Specifically, OTI and the other petitioners urged the FCC to extend E-Rate support eligibility to include the following technologies and circumstances (which are, at this time, explicitly excluded by the Order):

• cost-effective options that are functionally equivalent to commercially available mobile wireless services and Wi-Fi hotspots within the established prediscount budget (such as community anchor networks)
• the purchase of hotspots on a standalone basis if an applicant already has access to the service needed to use the hotspots
• wireless service that could be used with an applicant’s existing non-hotspot Wi-Fi-enabled equipment

While our filing echoes various points that OTI and others brought up to the FCC prior to the agency’s vote to adopt the Order in its current form, we assert in this filing that the FCC “did not fully consider the arguments raised in favor of these proposals and did not provide a sufficient, reasoned basis for rejecting them,” thereby warranting our petition for reconsideration.