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Tuesday, March 11, 2014

Tempest in a portal

One of the duties of this blog, I feel, is to be a sort of People magazine for E-Rate, posting information that you might call news, or you might call gossip.  This post has a kind of gossipy goal.  But of course, I won't gloss over details, so you'll have to dig to get to the dirt. [I can't decide if that mixed metaphor is ingenious or stupid.]

If you spend much time around ed tech, you may have heard of EducationSuperHighway (ESH).  It's an organization dedicated to "removing the roadblocks to high-speed, high-capacity Internet for America’s schools and paving the way for digital learning in every classroom."  The have a lot of high-profile donors and partners, and a really nice website.

ESH runs the SchoolSpeedTest, which Chairman Genachowski lauded.  Basically, schools were asked to identify their school, then run a simple speed test.  The test results were provided to the school, but also collected by EducationSuperHighway, which gave a summary of data to the FCC.  I think they have the best collection of data about school's actual Internet speeds.  I can't say how good their data is, though, because I don't know how many schools participated in the test.  And I can't say if I would agree with their analysis of the data, since only ESH has the data.

ESH's new initiative is the Item 21 Entry Portal (I21P).  Basically, they have provided a tool that allows you to enter your Item 21 Attachment (I2A) data on their site, then get an I2A suitable for emailing.  I took a look at the tool, and the forms are a little better than USAC's.  The I21P also has the ability to do bulk uploads of Item 21 data.  I won't be using the portal, but it could be convenient for some people.

The idea behind I21P, though, is to allow ESH to collect all the information in everybody's I2As, to build a big database of information on what schools are using and how much they're paying for it.  I think that's a good goal; I've already said the FCC should free the Item 21 Attachments.

So ESH has been sending emails to schools, encouraging them to use the I21P.  I will be kicking the decision to my clients, because I won't release their information without their OK.  I've told clients that I can't give them legal advice on the release of that info to a third party.  Certainly, some service providers won't like having their pricing info shared, but I'm not sure if their claim to privacy for proprietary info stands up against public school and library information being public.

Apparently, I was not alone in my concern.  The AASA (the Superintendents Association) and the Association of Education Service Agencies (AESA) posted a joint Q&A about the portal.  They were mostly pretty neutral, but they did have a couple of discouraging things to say.  T.H.E. Journal published some responses from ESH.

Oh, it's on!

Let's break it down, showing the two sides, and then my assessment:
Slow applications? Using the I21P "delays the issuance of Funding Commitment Decision Letters." "USAC does not have a policy that people who file using their online tool get their applications reviewed before people who file with any other manner" Neither side can prove what they say. I don't think anyone has evidence on whether apps with online I2As get funded faster than paper ones. PIA procedures are secret, so we don't know the policy on processing online I2As first.
Use of data "Participation in the ESH Item 21 Portal represents an E-Rate applicant submitting information to a private group, and that gives us and our members concern." "will use the information to publish aggregate reports at the national, state and regional level that sort of summarize the key learnings from the information. That we will provide government agencies, including the FCC the United States Department of Education, states and intermediate units, with the specific data that we gather from districts and libraries within their jurisdiction…and that we will give districts and libraries access to both that aggregate information, but also to anonymized detailed information in their region." If you give the data to the FCC and DOE, how are they going to keep it secret? ESH can't protect the data by claiming it's proprietary to ESH, so FCC and DOE would have to share, I think. The Privacy Policy does not delineate who gets what. The Privacy Policy seems to forbid ESH from giving specific data to anyone, including FCC and DOE. If everyone else gets aggregated data, ESH will have an opportunity to spin the data any way they want, and no one else will have the data to contradict them. "Knowledge is power."1
Who benefits? "the main beneficiary of the ESH portal is ESH" "there will be many beneficiaries from participating in this process": FCC, state DOEs, districts and libraries Both are right: ESH is the main beneficiary, but others will benefit.

I think ESH has a problem with their Privacy Policy.  It severely limits how they can use Personal and/or Applicant Information (PAI), which is good.  PAI is defined as "information that alone or in combination with other information may be used to readily identify, contact, or locate you or the E-rate applicant you represent," which is also good.  The problem is that price is PAI.  Price is on the 471, so if you tell me an applicant is paying $1,253.53/month for Internet access, I'll tell you in less than 5 minutes the FRN and associated 471 and 470.  (If you wanted me to tell you for every applicant in the country, it would take me a while to cook up the right query, but I could do it.)  So price transparency would violate the Privacy Policy.  They could provide price translucency by rounding pricing off to the nearest $50.  Then it would take some detective work to get to PAI, and in some cases I wouldn't be able to say for sure, but in most cases I would be able to say definitively (especially if you give some geographic info), so translucent pricing would still be PAIish.

Price transparency is a laudable goal.  But I don't think I21P is the way to get there.  At least not the way it's set up now.

1 Sir Francis Bacon, Religious Meditations, Of Heresies, 1597.

For those of you who are thinking it's about time for me to do some grammar woolgathering, I won't disappoint.  How does one acronym (or is it "acronate") "Item 21"?  I chose to just take the first digit of "21" to form "I2A"; ESH kept the whole number in their "I21P" acronym.


  1. Anonymous5:08 PM

    Another and more important issue is that ESH assumes that just because their SchoolSpeedTest indicated that a school had, for instance, a 20 Mbs bandwidth, that that is all that was available to the school and the cure was either a larger internet or WAN connection. In most instances the school has the availability of more but choses not to purchase it because their internal connections will not carry greater bandwidth or the curriculum does not drive a need for more.There will likely be little relief for internal connections until 2016 as the ESH has focused on fiber, consortiums, & broadband with little recognition that the LAN's are the real issue, not the WAN's and Internet connections.

  2. I agree. I know a district with just over 1,000 students. SETDA says they need 100 Mbps by next year, and the FCC seems to be buying into that artificial benchmark. The district currently has 20 Mbps to the Internet, and the tech director has the tech chops to know that they do not fill that pipe. Next year, they may go to 50 Mbps, just in case, but have no plans to go to 100 Mbps. And this is a district with a 90% discount, so money is no object.

    They haven't rolled out 1-to-1 to all grades yet, so they may get to needing 100 Mbps in a couple of years. They're already running VoIP over that pipe.