E-Rate 2.1?

I wasn't at the Washington Educational Technology Policy Summit to hear FCC Commissioner Rosenworcel's speech, but ISTE was nice enough to post the full text of the speech.

In general, I liked it.  She says lots of things I'm glad to hear.  But of course I'm not going to just clap.  Let's skip to the bottom of page 3 and look at the commissioner's five-point plan to reform the E-Rate:

1. More funding: Yes, of course.  But how?  Sorry, but savings from auditing the Low Income Program aren't going to top a couple hundred million, and the program needs billions, even before the Obam-E-Rate.
2. Capacity goals: Fine, if you want.  And it's a step in the right direction to have bandwidth goals tied to student population, which it wasn't in the President's speech.  But frankly, I think bandwidth needs will outpace the goals. Seven years ago, 10 Mbps would have seemed unreasonably high for most schools, and now it seems normal.  Now we're talking about 1 Gbps per 1,000 students in 7 years, which doesn't seem unreasonably high, and therefore probably too low.  In the near term, the commish calls for 100 Mbps per 1,000 students by 2015.  It doesn't matter whether she means 7/1/2014-6/30/2015, which schools call the 2015 school year, or 2015-2016, which the E-Rate calls Funding Year 2015, because the PARCC assessment (the Common Core online testing the commish mentioned on page 2) specifies 100 Mbps per 1,000 students by March 2014.  I expect the PARCC process to be put off a year as schools realize the enormity of conducting online testing of every student, but still, PARCC will force 100 Mbps before the E-Rate catches up.
3. Public-private partnerships:  So the vision is that the heads of major corporations will go to the stockholders and say that the company is going to spend money on technology that will produce a better-educated workforce in 10 years?  Stockholders don't care about 10 years from now; if the executives spend money on anything that doesn't enhance this year's bottom line, the lawsuits start.  And some astute shareholder will point out that the better-educated workforce will also aid the company's competition.  Private companies will develop educational apps and devices if they can make money off it.  Don't call that a partnership.  And if we're talking about diverting E-Rate money into content and end-user devices, then you'd better plan on scrapping all the other USF programs, because we'll need all that money to pay for it.  And then I get really snarky: private schools are, of course, private, so do they have to partner with something public?  Or can they form private-private "partnerships"?  And what about charter schools, which are publicly funded but privately run?  Can they just partner with themselves?  This phrase came from the President's speech, but it's meaningless drivel, so can we please just let it go?
4. Simpler process:  Yes!  Step 1: tell us what the process is.  Step 1a: publish a rule book; all the rules in one place.  Step 1b: publish the secret stuff; most of the rules are secret, and the uncertainty  created by all that secrecy is much more corrosive than the tedium of creating the same damn application from scratch every year.  Consortia?  Sorry, not simpler.  I'd like to see the consortium rules simplified, but there is no way a consortium is ever going to be simpler than single applicant purchases.  And really, the age of the consortium has passed; now it's all about purchasing cooperatives, which are popping up everywhere (doesn't it seem like every ESA in the country is starting one?) and coops are replacing state contracts (think PEPPM, WSCA).  Just let applicants use purchasing cooperatives as part of the bidding process; that way if a larger collective really lowers costs, the school can choose that.  If the unwieldy purchasing process of a collective turns out to raise costs, then they can pick a different alternative.  Wait, what am I saying?  You want to simplify the application process?  Scrap the Form 470 and get the FCC out of the business of regulating the purchasing practices of schools and libraries.  There is enough waste in the time-tested local and state rules, without adding another wasteful layer of half-baked federal rules on top.  And if you want federal regulation of purchasing, shouldn't the GAO handle that?  This is a clear case of federal intrusion into states' rights; how can I get it on the Supreme Court's docket?  What about private schools, you say?  Isn't the private sector supposed to be more efficient that the government?  Let private sector efficiency take care of the purchasing practices of private schools.
5. Home broadband:  Danger, Will Robinson!  I'm fine with letting kids use their schools' bandwidth after school.  I don't see why we should waste time and money studying it, since it costs nothing, but OK, study away.  The lack of broadband access in homes is a Low Income problem, not an E-Rate problem.  The main threat to this program is mission creep, and we're dealing with quite enough of that without trying to cover homes.  And can we cut it out with the "anchor institutions"?  In the open ocean of rural America, an anchor is only of use to the boat it's attached to.  No telco is going to lay fiber unless there is a dense cluster of customers, and in that case, they're going to lay it from a CO, not a school.  Those stories about kids studying at fast food restaurants don't seem "sobering" to me.  I've done it myself when I'm traveling.  Stop by any Starbucks and look at how many people are using their free Wi-Fi; how many of them are victims of the digital divide?  For me, Wi-Fi in restaurants is a public-private partnership that actually works.  I'd be happier if the free Wi-Fi was in a place that didn't serve Big Macs or Double Chocolaty Chip Frappuccinos, but the lack of healthy food alternatives is a problem way too big for the E-Rate.

Well, that got more critical than I set out to be.  I applaud Commissioner Rosenworcel for adding her suggestions to the conversation.  But sorry, I only see ideas 1 and 4 as important and worth pursuing, and I don't agree with the path she wants to go on those ideas.

As if I haven't been argumentative enough, I just want to point out to those who would put a small "r" in "E-Rate," shouldn't you then also use the spelling "Wi-fi"?  Admit it: "Wi-fi" looks dorky.  Like the "R" in "E-Rate," the "F" in "Wi-Fi" should be capitalized.