EBB Update/New Remote Learning & Cyber Security Funding Proposals

February 11, 2021

~ EBB live roundtable – Feb 12 at 10 am ~

Recently there have been developments in DC related to the new low-income, home Internet access program called EBB, and other new proposals that, if adopted, would help fund off-campus connectivity and cyber security.  This message provides a high-level overview of each and if you have strong opinions about any of the proposals, I encourage you to weigh in, even if just through brief comments.

Emergency Broadband Benefit (EBB) 

The December federal COVID stimulus law contained $3.2 billion to fund a new “Emergency Broadband Benefit Program” (EBB) that that will provide $50/month subsidies for Internet access services to the homes of low-income families (and a small subsidy for a laptop/tablet) during the pandemic.  In short, a household that would like the EBB subsidy will contact a participating provider that will then verify the household’s income eligibility to participate and install/turn on service.  The provider will then seek reimbursement from USAC.

The FCC is in the public comment period, with final public comments due February 16.  The FCC’s Public Notice inviting comments is available at:  https://docs.fcc.gov/public/attachments/DA-21-6A1.pdf.  Final program rules are expected to be adopted by the end of February.   Several national organizations have already submitted comments explaining that a vast majority of schools are already providing at-home financial support covering mobile hotspots, computing devices, and ongoing monthly internet services for students who would not otherwise be able to afford the necessary tools and services for remote learning.  They urge the FCC to establish final rules which allow EBB discounts to apply to the charges currently being paid by schools on behalf of eligible student households.

What You Can Do Now:

  • EBB Roundtable – February 12:  tomorrow (February 12), the FCC is holding a virtual roundtable discussion on EBB from 10 – 12:30 to gather public input on how to structure the new Emergency Broadband Benefit Program.  For a full agenda and link to the live feed, go to:  https://www.fcc.gov/news-events/events/2021/02/roundtable-emergency-broadband-benefit-program.  Questions for the panels to consider are welcome and can submitted prior to the event by email to outreach@fcc.gov.
  • Sign-Up as EBB Partner:  The FCC has just announced a website where organizations can register their interest in helping to promote this new program.  To sign-up, go to:  www.fcc.gov/broadbandbenefit.
  • Submit comments, however brief, to the FCC by February 16 explaining how you believe schools should be involved in the EBB program.  Comments may be filed electronically to the FCC at fcc.gov/ecfs (or brief comments at https://www.fcc.gov/ecfs/filings/express) in Docket No. 20-445.
  • Provide information about EBB to the low-income families in your schools so they can take advantage of the program as soon as it comes online.
  • Reach out to your local Internet companies to encourage their early participation in the EBB program.  Participation is not mandatory.

SHLB Remote Learning Petition

Two weeks ago, the national SHLB coalition and several other organizations filed a petition with the FCC, urging the agency to:

  • Clarify, for the duration of the pandemic, that off-campus use of E-rate funded services used to enable remote learning constitutes an “educational purpose” under E-rate rules.  (Meaning, if you share your E-rate funded Internet to student homes, it would be considered eligible and not have to be cost-allocated from your E-rate funding requests.)
  • Open an additional application filing window to allow applicants to apply for funding for both FY 2020 (retroactively to the extent necessary) and FY 2021 to support off-campus services for remote learning for students and staff.  (Meaning, there should be a special window to pay for currently ineligible off-campus Internet access service – like hotspots and cable modems for students that have been and will be paid for by schools – and any equipment/services needed to extend school networks off campus – like antennas, wireless receivers, etc.)  The petition proposes to use E-rate funding that is currently held in reserve for pending appeals and any available funding from prior years that was not spent.

The FCC is apparently interested in this petition because they almost immediately issued a Public Notice (DA 21-98) seeking public comments on an expedited schedule.  They are especially interested in hearing from schools that have, or are interested in, extending their networks off campus (what are the costs, is there currently no service available to those homes, etc.).  Initial comments are due February 16; reply comments are due February 23.  Comments may be submitted electronically to the FCC at fcc.gov/ecfs (or brief comments at https://www.fcc.gov/ecfs/filings/express) in Docket No. 21-31.

Proposed Emergency Connectivity Fund

This week, the U.S. Committee on Energy and Commerce released their legislative recommendations for budget reconciliation which include a proposed $7.6 billion Emergency Connectivity Fund through the FCC for provisioning support to eligible schools and libraries to provide, among other things, eligible connected devices, internet service, and hotspots to students and teachers for internet use at home during the pandemic.  Full text of the ECF proposal begins on page 6.

E-rate Funding for Cyber Security Petition

This week, the Consortium for School Networking (COSN) and several other national education and broadband organizations submitted a formal petition to the FCC, urging the agency to:

  • Define all firewall and related advanced firewall features as E-rate eligible.
  • Increase applicants’ Category 2 budget cap to support additional cyber security needs.

The petition estimates the cost to provide much-needed cybersecurity protections to U.S. K-12 school districts is $4.733B, which is based on an analysis of five-year price models for third-party hardware, software and cloud-based services used to guard schools from online attacks.  I am hopeful the FCC will seek public comment on the COSN petition in the next few weeks, and if they do, I will let you know so you can weigh in with your experiences and needs.  I would be surprised if any E-rate rules or eligibility is changed for FY 2021.

As I learn more about the EBB program and the other three proposals, I will keep you posted.  In the meantime, if you would like my assistance in filing comments, please let me know.

– Julie

Julie Tritt Schell

PA E-rate Coordinator





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