Request for Additional E-rate Funding for Internet

August 4, 2020

Attached: SECA Ltr to FCC re COVID Relief (08.03.2020)

Attached: FCC Standard Filing Instructions

I’ve received inquiries from several PA schools that have had to increase their existing Internet bandwidth due to the impact of the pandemic on your educational operations, asking whether E-rate will help pay for these increased costs.  Currently, the only way this can happen is if applicants submit a late Form 471 and then seek a waiver from the FCC.  Unless the FCC changes its waiver policy such a request is not likely to be approved under the current rules.

Pennsylvania schools are by no means alone in this predicament.  Recognizing this nationwide need, the State E-rate Coordinators’ Alliance (SECA) – an active, grassroots organization comprised of my fellow state E-rate coordinators in 46 states – sent a letter to FCC Chair Ajit Pai requesting the FCC to grant relief.  The letter requested that schools be permitted to submit supplemental FY 2020 E-rate applications to request funding to help defray the cost of on-campus, additional E-rate eligible Internet that schools have purchased or will be purchasing due to COVID-19.  The letter explains that schools did not anticipate that such bandwidth increases would be needed when they originally applied for E-rate funding during the Form 471 application window, and that there is precedent for such relief from previous national emergencies such as hurricanes and floods.  SECA lays out several ways the FCC could administer the additional requests (appeals, late-filed 471s, or a special new 471 window) but no matter which option is selected, the bidding requirements would need to be waived because schools have increased or augmented their Internet bandwidth without conducting an E-rate competitive bidding procurement using the Form 470.  A copy of the SECA letter to the FCC is attached.

In order to support this effort and convince the FCC to act, I have two specific requests of schools that may already have bought additional Internet or may have plans to do so:

  1. Please take 2 minutes and complete this very brief survey - - which simply asks what additional amount of on-campus, E-rate eligible Internet you’ve purchased (or will be purchasing) due to COVID.
  2. Please consider sending letters of support to the FCC.  I realized you are all swamped with back to school preparations, but unless the FCC hears from impacted schools, they may not understand the need.  A letter explaining what additional amount of Internet bandwidth you need and why, can easily be submitted through the FCC’s online comment system by either filing a brief comment in their Express Filing System or by uploading a letter on school letterhead in their Standard Filing System (see attached example of which form fields must be completed).  In either filing system, use 02-6 as the Proceeding Number.

Please note:  the SECA letter does not ask the FCC to allow E-rate to pay for home-based Internet for students and teachers.  It is the FCC’s position that such off-campus connectivity is not eligible for E-rate and that any such authorization and/or relief must come from Congress.  In terms of whether Congress will provide such authorization and funding, that remains to be seen as we are all awaiting the final stimulus package to be negotiated.

Thanks, E-raters.  If you need help with writing or filing your comments to the FCC, please let me know.

– Julie

Julie Tritt Schell

Pennsylvania E-rate Coordinator
717-730-7133 – o

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