Commenters Urge FCC to Expand the E-Rate Program to Connect Students During Pandemic

Public Knowledge joined Access Humboldt, Benton Institute for Broadband and Society, Consumer Reports, and New America’s Open Technology Institute (collectively PIOs) in filing comments in response to the Federal Communications Commission’s Public Notice on the use of E-Rate funds to enable remote learning. Public Knowledge supports “off-campus” use of E-Rate funds to help students studying at home access the broadband they need to stay connected to classes, student services, and their families during the pandemic. The petitioners seek emergency funding as well as relief from any restrictions on the use of E-Rate-funded services or facilities to support remote learning during this unprecedented public health emergency crisis. The petitions make a compelling case that the FCC must take action now to provide the added funding and flexibility schools need to address the challenges they continue to face— thereby ensuring the connectivity needed to mitigate the harmful impacts on educational opportunities created by the pandemic. The PIOs believe that granting all of the relief requested in the SHLB et al. Petition in particular will help meet that challenge. The PIOs emphasize in the comments below that it is crucial that the Commission provide schools and libraries with maximum flexibility to acquire the services and networking equipment they determine will best address the unique local circumstances, challenges, and opportunities they face. In addition, and consistent with past precedent, the FCC's Wireline Competition Bureau should waive any cost allocation rules with respect to remote learning to minimize the financial and administrative burden of extending access to the school’s network for educational purposes to students, staff and patrons at home or other locations. The legal authority of the FCC and of the Bureau, on delegated authority, to take the steps called for in the petitions is well-established.