T-LEAPing into the future

Great idea. Now why not make it universal. Over at the Tribal Library E-Rate Advocacy Program (T-LEAP), one of the initiatives they've taken is to accept applications year-round. You heard that right: no filing window for applicants in the T-LEAP program. The increased flexibility has, of course, increased applicant participation. 

Wouldn't it be great to increase applicant participation across the board? So why don't we allow year-round applications for all applicants? The application window was originally created because the E-Rate program always hit its cap, so not all applications could be funded. To keep the application process from turning into a race to apply, the FCC nicely set up a filing window, and said all applications filed in the window would be treated as simultaneous. Well, the program never hits its cap these days. So the filing window is unnecessary. 

The T-LEAP program shows us that we'd get more participation if we had no filing window. Applicants wouldn't be forced to sign illegal contracts. PIA's workload would be more spread out. Changing service mid-year wouldn't be a nightmare. 

As I pointed out 10 years ago, the rules as currently written, in fact, say that applications should be accepted after the close of the filing window if there's still money left. So USAC should be accepting applications year-round already. 

You may say I'm crazy, but I'm not the only one. The American Library Association (ALA) has asked the FCC to allow rolling applications for C2. But why allow year-round applications only for C2? Let C1 apps be year-round, too.

Going one step further, why do we still have C1 and C2? The two Categories (nee Priorities) of funding were only created because the program never had enough money to fund all funding requests. Now that the program has plenty of money to cover all requests....

Cybersecurity Pilot update

I'm listening to the quarterly meeting of the USAC Schools & Libraries Committee of the USAC Board, and I learned some new things about the Cybersecurity Pilot Program (CSPP). 

First, USAC expects to open invoicing by March. Also, they're running an invoicing webinar tomorrow. 

Second, all CSPP applications should get FCDLs by the end of June. For those who didn't know, 172 FCDLs were issued on December 17th. Another wave should be coming out soon. But knowing when the last FCDL will be issued is good news for those of us who have applications languishing in "Certified" status.

GAO: USAC FTW

It's a clean bill of health for the E-Rate! The GAO (Governement Accountability Office) evaluted five programs for their adherence to "nine requirements and leading practices to oversee and prevent fraud, waste, and abuse in awards...." Alone among the five programs, the E-Rate had procedures for all nine.

The GAO has taken a dimmer view of the E-Rate program in 2005, 2009, 2010 and 2017. So it's a nice change to see the program getting a clean bill of health.

A step in the right direction

 Time for the annual table to see if the FCC stuck to their rule of 60 days between the release of the ESL and the opening of the window and if the window length stayed at 70 days, the recent standard.

 As is typical since 2019, the FCC missed the 60-day mark, giving us only 35 days, but the government-wide shutdown gives them a good excuse. 

And they pushed the window back a week to give us more time with the ESL before we have to file. Of course, that makes me happy, since I think the window should close in May. 

FY	ESL release	Window open	60 days?	Window close	Window days
2026	12/17/2025	1/21/2026	35	4/1/2026	70
2025	10/25/2024	1/15/2025	82	3/26/2025	70
2024	12/18/2023	1/17/2024	30	3/27/2024	70
2023	12/14/2022	1/18/2023	35	3/28/2023	69
2022	12/17/2021	1/12/2022	26	3/22/2022	69
2021	11/30/2020	1/15/2021	46	3/25/2021	69
2020	12/9/2019	1/15/2020	37	3/25/2020	70
2019	11/15/2018	1/16/2019	62	3/27/2019	70
2018	10/5/2017	1/11/2018	98	3/22/2018	70
2017	9/12/2016	2/27/2017	168	5/11/2017	73
2016	9/11/2015	2/3/2016	145	4/29/2016	86
2015	10/28/2014	1/14/2015	78	3/26/2015	71
2014	10/22/2013	1/9/2014	79	3/26/2014	76
2013	9/27/2012	12/12/2012	76	3/14/2013	92
2012	9/28/2011	1/9/2012	103	3/20/2012	71
2011	12/6/2010	1/11/2011	36	3/24/2011	72
2010	12/2/2009	12/3/2009	1	2/11/2010	70
2009	11/21/2008	12/2/2008	11	2/12/2009	72
2008	10/19/2007	11/7/2007	19	2/7/2008	92
2007	10/19/2006	11/14/2006	26	2/7/2007	85
2006	11/22/2005	12/6/2005	14	2/16/2006	72
2005	10/14/2004	12/14/2004	61	2/17/2005	65

E-Rate, baby!

 The E-Rate got mentioned several times in a Senate hearing at which there seemed to be universal agreement that student screen time should be limited. That can't be good.

Not surprisingly, the first mention came from Sen. Cruz, chair of the subcommittee, who decried that "the Biden FCC sought to bankroll kids unsupervised internet access and undermine parental rights by expanding the E-Rate program to install Wi-Fi hotspots off-campus, including in school buses and students homes" and touted the legislation he created to revoke the eligibility of home hotspots. (20:08)

Senator Cantwell countered that "rather focusing on threatening E-Rate, connectivity for school, I think we should be passing meaningful protections for kids online privacy regardless of whether they're accessing the internet from home or school." (24:31)

Senator Luhan also came to the defense of the E-Rate, pointing out that Internet access facilitated by the E-Rate must be filtered under CIPA and cannot be unsupervised. He also asked a witness to discuss the harm if the E-Rate ended. (1:48:19)

Finally, Senator Markey talked up the E-Rate, repeating that CIPA rules prevented unsupervised access, and saying that, "The E-Rate hotspots program was a responsible, carefully crafted effort to ensure that low-income students had the same opportunities as their wealthier classmates." (1:57:18)

So not bad, one criticism and three senators in support. Typically, it fell along party lines.

Still, as I look on the horizon for threats to the E-Rate, this one looks like the most threatening currently (though it has a lot of growing to do before it's a realistic threat). In the '90s and '00s, the pendulum swung fully to the "technology good" end of the spectrum, and it's now swinging to "technology bad." Currently, the agreement is "social media bad," with a growing "cell phone bad" sentiment. So far no one's saying "E-Rate bad," but I'm afraid the E-Rate could be the baby thrown out with the social media bathwater. It's already happened to home hotspot and bus WiFi.

E-Rate sneaks in around the Kimmelspeak

Unlike the recent Senate hearing, this week's House FCC oversight session did mention the E-Rate. It felt like the Senate version back in December was all about the Fairness Doctrine and Jimmy Kimmel. The House hearing didn't neglect Jimmy K, but they found time to mention the E-Rate twice.

Commissioner Gomez led us off (timestamp 39:55) with a mention in her opening remarks about how the removal of WiFi hotspots and bus WiFi "removed one of the most effective tools we had to help people participate in the digital economy and to avoid being left behind."

Representative Cantor brought up hotspots and buses again (2:27:45). Basically, she just asked Commissioner Gomez to confirm that stripping them out of the program was bad. Representative Tonko brought them up (3:23:23) one more time, and again Commissioner Gomez said their removal was bad.

So E-Rate was only mentioned to complain about buses and hotspots getting the boot from the program.

Actually, Chairman Carr took a swipe at hotspots (50:01) without actually saying "E-Rate" or "hotspot" by saying "we're ending any unlawful expenditures that were taking place."

Everyone made nice noises about the Universal Service Fund and how important it is, but when given the chance to tell Congress how to improve the program (50:44), Chairmain Carr pretty much punted, with some vague promises to work with Congress. 

Still, a hearing where the E-Rate only gets one swipe is good hearing.