E-Rate 2.0? I think I'll wait for v2.1

Hard on the heels of Sen. Rockefeller discussing E-Rate 2.0, we have Commission Rosenworcel jumping on the bandwagon in a recent speech at the Ed Tech Policy Summit.  I'll skip reading the speech and just read the official summary.

First, the Commissioner lays out two reasons we need E-Rate reform:

• E-Rate demand is roughly double the available funding
• 80% of schools and libraries say their bandwidth is not sufficient to meet current needs
• About half of E-Rate schools have Internet access speeds of 3 Mbps or less

To which I say:

• Yeah, and demand would be higher if all the applicants below 80% hadn't given up on Priority Two funding.
• Bandwidth is like salaries: ask anyone how much they need, and it will always be a little bit more than they have.
• Remember the good old days (like 5 years ago), when a T-1 (1.5 Mbps) was luxurious?  Now, 3 Mbps seems tiny.  But I'll come back to this in point 2 below.

Her proposed reforms:

1. More funding for E-Rate coming from savings in other programs.
2. By school year 2015, 100 Mbps per 1,000 students.
3. Public-private partnerships.
4. Simpler process.
5. See how the School Spots program can help close the Digital Divide.

My reactions:

1. I'm all for more funding.  But using savings from other programs doesn't work.  If the cost of the High Cost or Low Income programs goes down, USAC will cut the contribution factor.  You need to raise the E-Rate cap.
2. Actually, PARCC is already forcing schools to meet this benchmark.  So let's see, half the schools are at 3 Mbps or less, and and it looks like the median school has something like 500 students [I found the mean, but not the median], which would require 50 Mbps.  That's a serious uptick.
3. Sounds great, means nothing.
4. Hear! Hear!  Some suggestions of the top of my head:
1. Scrap the 470 (or at least exempt purchases under $10,000, like over in the Rural Healthcare program)
2. No PIA for applications under $3,000
3. Approve funding for 80% of all FRNs by the start of the funding year
4. Publish all the rules
5. Scrap the 2-in-5 Rule
6. Set the P2 denial threshold when the Eligible Services List is released
5. Why study the impact?  I can't think of any way for the FCC to alter the School Spots program to change its impact for schools.

So not earth-shaking reforms, but at least none of the suggestions are negative, unlike the last Commissioner speech I read.  Go Commissioner Rosenworcel!