Comments of ICLE & TechFreedom, In the Matter of Modernizing the E-rate Program for Schools and Libraries, FCC

Summary

“In the 1996 Telecommunications Act, Congress created a cluster of Universal Service Programs to ensure that schools, libraries, high-cost areas and the poorest Americans are connected to the telecommunications networks. As those networks have been transformed by technological change, those subsidy programs have become increasingly disconnected from the reality of modern communications technologies. The Commission’s Notice of Proposed Rulemaking on modernizing E-rate marks the next administrative step towards crafting a new framework for the USF program.

No one doubts the need for modernization, but sensible modernization requires ensuring that taxpayer dollars are used efficiently to achieve clearly conceived and effective goals. In particular, that means rigorously justifying any bandwidth “targets” in terms of actual needs, pedagogical efficacy, and tradeoffs…”