Why is Microsoft weighing in on E-Rate 2.0? Maybe they want to change the name to E-Rate Vista? Let's see....
OK, it starts with a nice bit of self-promotion, using colored boxes that evoke the Windows® logo. Except that's the old Windows logo. Then a section on the importance of increased connectivity. Then another section on how much Microsoft is doing for our schools and libraries.
The next section has some meat, encouraging the FCC to look at local caching, multicasting and leveraging regional networks. Does Microsoft still have a caching product? They no longer sell Forefront (f.k.a. ISA Server f.k.a. MS Proxy Server). And while I'm sure Media Server can multicast, no one's decision to buy one is going to be influenced by E-Rate. Is this whole section completely lacking in self-interest?
I have to take issue with Microsoft's reasoning in support of regional education networks (RENs). I think their diagram correctly identifies the bottlenecks in access to content: the last mile to the school and, if a school relies on WiFi internally, the WLAN. MS claims that RENs will be able to get substantially cheaper Layer 1 or 2 connections, rather than Layer 3. Apples and oranges. They're comparing a Layer 1 or 2 WAN connection to a Layer 3 Internet connection. The connection to the REN is cheaper, but somewhere there's going to be an additional charge to connect the REN to the Internet. Latency on the REN would be lower than over the Internet, so if the REN also provides hosted VoIP, the quality would be better, assuming that the REN has the facilities and expertise of an actual telco. But that's a big assumption. Also, I'm not buying the claim that "individual schools needn’t maintain individual IT expertise." The need for local IT staff might decrease, but as long as there are Microsoft products in a school, someone's going to have to touch them from time to time.
The next section is about rethinking the prioritization levels. There might be a bit of self-interest when an internal connections manufacturer suggests giving more funding to internal connections, but as I pointed out above, most of Microsoft's products are unlikely to benefit.
Protecting student privacy? Where did this come from? Oh, yeah, from here. Google has the ability to mine data to increase ad revenues, and uses it in its free Google Apps for Education (GAFE). Microsoft does not have the capability in Office 365. So MS wants to make Google's capability forbidden. I find the mining of student data distasteful, but I don't think the FCC should be too swayed by a competitor that would benefit from a change in the rules.
And then we're off to white-space wireless networking (which was apparently christened "super Wi-Fi" by former Chairman Genachowski, to the displeasure of the Wi-Fi Alliance, since it isn't Wi-Fi (it isn't super, either, but that's a different argument)). The idea is to put wireless networking on the unused portions of the TV frequency spectrum. It's not a bad idea, but it doesn't meet E-Rate needs. First, it doesn't help remote schools. No one is talking about pushing the range of SuperWiFi past 6 miles, and the SuperWiFi access point has to be connected to a wire or fiber; if you're running the cable anyway, why stop 6 miles away? Second, no one is talking about speeds near 100 Mbps. So while it's a nice technology, it doesn't meet the needs of ConnectED.
Am I being too cynical in thinking that this filing is a sandwich, and the meat is the attempt to use privacy concerns to remove GAFE's unsavory technological advantage in the online app suite market?
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