National Broadband Plan putting the squeeze on E-rate

The FCC has released the National Broadband Plan. Being the blowhard that I am, of course I'm going to give my opinion. Being an E-rate geek, most of what interests me is how the plan affects the E-rate. And being lazy, I'm going to base my opinion on the FCC's Executive Summary (if I were a bit more self-aggrandizing, I guess I could say, "And being an executive...").

This blog post will be about changes outside the E-rate program that will affect E-rate. [Stylistic note: I have gone over the the dark side, and am now not capitalizing the "R" in "E-rate" and will be using it anarthrously. Mostly.]

Changes in the neighborhood: Item 3 of how "government can influence the broadband ecosystem" is all about expanding the USF.

The FCC plans to disband the High Cost Program and use it to create a Connect America Fund (CAF) and a Mobility Fund. I'm no expert in the High Cost program, but this just looks like mission creep to me. Since the CAF will cover wireline "broadband and voice" and the Mobility Fund will cover cell phones, it looks to me like they've just added broadband to the High Cost Fund, and I've already stated my concerns that a ballooning High Cost fund is bad for E-rate.

Watch your language: the FCC plans to design the new funds in a "tax-efficient manner." First of all, the USF is technically not a tax. I'm concerned that the FCC is listing toward the old Government Accounting Office report that said the USF should be part of the Treasury, and Congressional Budget Office report that found the USF would be more efficient if it were a tax. The idea of moving E-rate into the Treasury is favored by those who want to kill the E-rate, so I'm opposed.

Biggering and biggering: Still under item 3, the FCC plans to "broaden the USF contribution base." Hmmm.... Interconnected VoIP carriers are already contributing, as are landline and cell phone carriers. Who's next? ISPs? Since they'll be a major recipient of CAF funding, it would seem to make sense.

"Expand the Lifeline and Link-Up programs": So the Low-Income program will grow, too.

A "National Digital Literacy Corps"? No. Just go down to your local library, and you'll see that someone is already offering digital literacy courses. Go to you local Senior Center. Check out your local school district's (or community college's) continuing ed program. The availability of digital literacy training is not an obstacle to adoption.

On to Item 4, where the FCC calls for "expanding reimbursement for e-care." OK, not the Rural Health Care program is going to balloon, too.

Here are two vague but threatening goals under item 4:
"Support...small business' use of broadband..."
"Support deployment of a ... public safety mobile broadband network...." I'm afraid we may see two more programs shoved into the USF.

From Long-Term Goal #4: "anchor institutions such as schools, hospitals, and government buildings." [Interestingly, in the press release, "government buildings" was replaced with "military installations."] Those mostly aren't community anchors. OK, schools do provide broadband access to students and to the community after school. My local hospital provides free wireless Internet access for visitors, but I would hardly call it an Internet anchor. Military installations don't offer community Internet access, nor should they. The only government buildings that offer public access are libraries, which should be mentioned.

All in all, it looks like what I feared is another step closer to reality: the Obama administration may kill E-rate by squeezing it out of funding with all these new programs.

2-in-5 is 0-6

Another demand estimate, another failure of the 2-in-5 Rule. Total all the Priority One requests and the Priority Two requests from applicants with a 90% discount, and you get $2.85 billion. Even with rollover of unused funds and some denials, we're not going to see funding of Priority Two requests for 80% applicants. Again.

The 2-in-5 Rule must go.

E-rate getting stronger

I've posted a couple of times lately about my feelings on the spelling of "E-Rate." Well, things seem to be taking another turn that I don't like. I always say "the E-Rate," as in: "The E-Rate is the greatest thing since sliced bread." But I'm seeing the "the" omitted more often.

Today I saw it in an old post by the Education Director of the National Broadband Plan. He said, "Thanks to E-Rate, virtually all our schools and libraries are connected." [Not at all true: the E-Rate has largely bypassed libraries and private schools, but that's another rant.] It also appeared in the FCC's Community Use Order: "In this order, the Commission waives ... rules that currently discourage public use of resources funded by E-rate." (Usually, the FCC uses the term "the E-rate program," which finesses the question of whether "E-rate" is anarthrous.)

The vanishing definite article is common government-speak. For example, Peace Corps employees don't call it "the Peace Corps." They say things like, "I work for Peace Corps," which sounds odd to anyone who doesn't work for Peace Corps. Listen to government employees talk about their agencies and programs, and you'll notice the definite article disappearing often.

The Cambridge Grammar of the English Language calls a proper noun which doesn't require an article a "strong proper noun." So at least in one way, E-rate is getting stronger.

Tech Plan, Schmech Plan

I've said before that the E-Rate program should not require a tech plan in order to get funding. Inconsistent tech plan rules cause unnecessary denials. The tech plan requirement discourages library and private school participation in the program. For most applicants, the only time they look at the plan is every 3 years, when the rules say they have to refresh the plan.

So why did I spend time even scanning the draft of the National Educational Technology Plan? I guess I always hope that something significant will be in there.

Of course I read it like the dog in the old Far Side comic about what dogs hear when we talk to them. To me, it's just "Blah blah blah E-Rate blah blah blah."

So what jumped out of the blah-blah-blah?

First of all, the USDOE consistently using the spelling "E-Rate." Huzzah! Another one on my side of the great E-Rate/E-rate debate.

On page 54, the USDOE goes off on a little anti-CIPA rant: "this requirement creates barriers to...rich learning experiences." The rant is expanded on in the sidebar on page 55. I couldn't agree more, but I'm surprised to hear the USDOE say it.

Otherwise, the E-Rate (with a capital "R") gets a couple of nice mentions (pages 60 and 62), but isn't much discussed.