September 12, 2018
In May, the Federal Communications Commission (FCC) proposed new rules that would substantially change Educational Broadband Service (EBS). The FCC created EBS to provide educators with an ability to better deliver on their mission. EBS is a successful program that is actively helping to close the homework gap and the digital divide. Programs made possible by EBS are also the heart and soul of Voqal. In light of this reality, Voqal recently filed comments and reply comments in the FCC proceeding to share our perspective on how the Commission should approach this rulemaking.
In Voqal’s comments, we explain that this rulemaking is an incredible opportunity for the Commission to address three of its top priorities:
- Closing the homework gap and digital divide.
- Expanding access to affordable broadband in rural areas.
- Accelerating the deployment of 5G at a time when the U.S. faces intense pressure from foreign competitors.
Voqal believes the FCC can achieve these goals in three ways — maintaining EBS rules that are working, modernizing the educational use requirements and licensing unused spectrum.
Maintaining EBS rules that are working.
Hundreds of commenters voiced strong support for maintaining current EBS eligibility and lease term rules. The current rules have promoted investment and substantial use, as is evidenced by significant deployment in the band, as well as the imminent roll out of 5G networks. The rules have also provided extensive educational benefits. The record includes abundant examples demonstrating the resounding success of EBS. These impactful projects would not be possible if EBS eligibility and lease term requirements were eliminated. While some commercial operators have filed comments supporting rule changes, they offer no compelling reason to change or eliminate current rules that are delivering on the Commission’s objective.
Modernizing the educational use requirements.
Voqal supports implementing a new educational use standard. Existing rules, which were developed for the Instructional Television Fixed Service (ITFS) video era, are outdated. Rather than simply eliminate these rules, Voqal believes the Commission should adopt new educational use rules that ensure that educational entities — including schools, libraries, community centers and nonprofits — can access affordable broadband. Developing a new educational use standard will extend greater educational benefits and further address the homework gap, one of the central goals of this rulemaking.
Licensing unused EBS spectrum by rationalizing service areas and issuing new licenses through priority filing windows.
The fundamental issue with the EBS band today is that the Commission has failed to license EBS spectrum in nearly half the United States. Voqal and many other commenters support an automatic process that would expand current service areas so that more Americans could be served by EBS. Automatic Geographic Service Area (GSA) expansion would immediately add spectrum into the wireless broadband pipeline. Making this spectrum available for 5G services in a timely manner, while at the same time allowing educational licensees to continue offering cutting-edge services, is an easy win-win for the FCC and the American people.
In the remaining areas that are not licensed, the Commission has proposed to allow educational entities to apply for new licenses as opposed to commercial auctions. Local priority filing windows would allow educational entities, nonprofits and tribal nations to obtain new EBS licenses, which have not been available since 1995. Voqal supports this plan and strongly opposes the FCC using auctions in the EBS band. Auctions are likely to fail and would result in a significant loss of educational benefits. Issuing licenses via windows rather than auction will ensure local communities can self-deploy or partner with commercial providers in a way that is economically feasible and will help solve the digital divide.
EBS is an important tool for expanding internet access to more Americans.
Far too many Americans lack access to broadband. The FCC estimates roughly 24 million Americans live in an area without broadband, including 19 million Americans in rural areas. The digital divide especially hurts students who, without broadband, lack the same opportunities as their counterparts. The FCC can help address this digital divide by preserving EBS and modernizing it for the broadband world.
To read more about the current EBS rulemaking, including comments from Voqal and others, visit saveebs.org.