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NCTA, ACA Rate FCC E-Rate Proposal

The FCC has gotten plenty of input from the
cable industry on its proposed reform/modernization of the E-rate program,
which provides subsidies to schools and libraries for advanced

The National Cable
& Telecommunications Association said in its comments that the FCC should
focus on student bandwidth needs rather than specific bandwidth targets,
simplifying the process, improving outreach and working within a
"firm" budget, which means balancing increased costs with savings and
not prioritizing fiber deployment over other services. NCTA also advises
allocating more wi-fi spectrum.

The American Cable
Association also wants the FCC to keep to a budget and simplify the process. It
puts a premium on gathering more data before the FCC remakes the program, and
on using existing facilities as much as possible.

The FCC has proposed
some high-speed targets, but NCTA says that "one-size-fits-all"
approach may not be the best, says NCTA, and could lead to insufficient funds
for other important elements like teacher training and devices. It points out
that schools are already able to purchase service at the target speeds.
"There is nothing in the current E-rate rules that prohibits schools from
soliciting bids for connectivity at 100 Mbps, 1Gbps, or more," says the
association. "Rather than encouraging or mandating that schools purchase
particular levels of bandwidth, the Commission should focus its efforts on
creating an environment where schools are more likely to solicit
bids for those high-capacity services and more likely to have the resources to
deliver faster speeds to students in the classroom."

The association also
says the FCC cannot "divorce the question of cost" from its bandwidth
goals. One way to find money within the program to fund broadband would be to
cut out subsidies to stand-alone voice service, but NCTA warns a "flash
cut" could hurt schools and libraries (and telecoms).

NCTA says the FCC
should remove the current distinction between connections to the schools and
libraries (priority one) and internal connections (priority two), which it says
often go unfunded. That is where more wi-fi could help, it says. "NCTA
supports targeting E-rate support to wi-fi services that will foster
connectivity to classrooms and other areas in the school where students
congregate in a cost effective manner and make it more likely that schools will
be in a position to take advantage of higher capacity offerings from service

IF after
reprioritizing and refocusing the fund and balancing costs and savings, the FCC
concludes it must still expand the size of the fund, it should be clear from
the outset how much it is expanding, and set a cap on the Universal Service
Fund so that the expansion is paid for with savings from other parts of the USF
fund, particularly the "bloated" high-cost program.

In its comments, the
American Cable Association said that before the FCC does anything, it needs to
gather more data, including on "existing infrastructure, broadband
dependent applications and services (and their performance requirements) used
today by teachers and students and those that are likely to be used, and the
number and types of access devices and technologies used today and those
expected to be used in the near future."

ACA's key policy
proposals are that the FCC should 1) use existing facilities as much as
possible, requiring certification that a school or library had made "all
reasonable efforts" to receive high-speed connectivity using existing
facilities; 2) capping the current fund at $2.25 billion; and 3) simplify and
standardize the process.