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FCC Request for Comment

On November 3, the Federal Communications Commission (FCC) released Public Notice DA 09-2376 seeking comment on Broadband Needs in Education. The FCC is requesting comments on various issues related to broadband access in education and the E-rate program. Comments are due to the FCC by November 20, 2009. Reply comments are due December 11, 2009.

For more information go to the FCC website at www.fcc.gov.

All information in this survey is taken directly from this document and information gathered will be utilized to develop responses to this request.

BROADBAND DEPLOYMENT DATA

1. We seek information on the current state of broadband connectivity, device availability, and adoption in U.S. schools and classrooms. We seek statistics on the current state of network connectivity as well as information on technology deployment projects that address connectivity, access, and adoption.

We seek statistics on the current state of network connectivity as well as information on technology deployment projects that address connectivity, access, and adoption. 1a

Although kilobits/device, kilobits/classroom, kilobits/student and devices/student are metrics to consider, what metrics should be used to measure an effective balance of network, hardware, application development, training, and adoption? Please include comment on metrics, benchmarks, and results against benchmarks. 1b

What are the specific barriers to increased broadband deployment and usage for schools and libraries? Is lack of physical facilities, including, e.g., complete wireless coverage for a school district, a problem for some schools and libraries? Is cost of the monthly service or installation too expensive, even with the E-rate discounts? Is funding for services and equipment not supported by E-rate, such as computers or teacher and staff training, too expensive for schools and libraries to purchase additional bandwidth? Are internal networks insufficient to handle increased usage? 1c

BROADBAND IMPLEMENTATION

2. We seek comment on school and school system broadband initiatives including infrastructure and large-scale application deployment.

What projects have been considered successful and not successful? What were the success criteria? 2a

What have been the barriers to entry and barriers to adoption? 2b

What are the most common needs heard from classrooms and instructional leaders with regard to using broadband for instructional or other purposes? 2c

What creates demand for using broadband in education? 2d

BROADBAND AND DIGITAL CONTENT

3. We seek comment on schools’ and school systems’ online and digital content needs and uses, including content for student instruction (e.g., whole or partial textbooks or supplemental resources) as well as professional development content for educators.

What sets of instructional and operational problems are schools and school systems attempting to solve with online content solutions? 3a

Of the typical set of online content tools (e.g,: content creation, content publishing, content indexing, content management, content search) what have schools and school districts experienced when making purchasing decisions about the quality and availability of tools that meet their needs? Are there areas where needs are consistently unmet or under-served? 3b

How is digital content being integrated with traditional textbooks and other materials? Are there issues preventing this integration? 3c

DIGITAL LITERACY

4. We seek comment on digital literacy programs, standards, and content.

Please provide case studies or data relating to the use of digital literacy training to improve access and use of online systems, and the educational, social or economic impact created by such work. Where has such digital literacy work been accomplished in a traditional classroom and where has it been accomplished in an online or blended model for developing these skills? What physical locations (if any) were used (libraries, schools, etc.)? 4a

What barriers or issues have prevented implementation of such solutions? 4b

ONLINE LEARNING SYSTEMS

5. We seek comment on online learning systems.

Please provide examples of schools and school systems currently supporting blended online/offline instructional planning and delivery as well as distance learning via broadband and computer-based learning. What online content systems (e.g, online text books, resource libraries, learning management systems (LMS), distance learning programs, student portfolio systems) have been successfully implemented? How do schools and school systems align online learning systems with other traditional instructional tools (e.g., textbooks, curriculum, scope and sequence)? 5a

How do schools and school systems measure the effectiveness of online vs. blended vs. offline instruction? What are the benchmarks used to compare delivery approaches? 5b

What barriers or issues have prevented implementation of such solutions? 5c

ACCOUNTABILITY AND REPORTING SYSTEMS

6. We seek comment on schools and school system implementation of online/ASP/cloud-based student instructional data reporting systems and their impact on student achievement and school operations.

Many school systems have built Adequate Yearly Progress (AYP) systems to fulfill accountability obligations. Have schools and school districts had success building online student data reporting systems that have had a positive impact on student achievement and/or classroom/school operations? 6a

What barriers or issues have prevented implementation of such solutions? 6b

Within these systems, how do schools and school systems protect student-level data? 6c

How have student data reporting systems supported school reform movements? 6d

EDUCATIONAL DATA INTEROPERABILITY

7. We seek comment on data interoperability projects utilizing the Internet and/or wide area networks (WANs). Such interoperability projects could include student record transfer solutions between enterprise software applications within a single organization, or inter-agency data transfers.

How effective were these projects? 7a

What metrics were used to define the projects? 7b

What barriers or issues have prevented implementation of such solutions? 7c

What security systems were implemented and were they effective? 7d

COMMUNICATION AND VIDEO SYSTEMS

8. We seek comment on implementation of other online applications in schools and school systems.

How have communication tools like instant messaging and online video conferencing supported instructional program implementation? 8a

Where have live video streaming programs been implemented to scale? 8b

Where have social networking tools been implemented to support instructional goals? 8c

How have concerns of content appropriateness/content blocking been addressed in rollout to students (especially in kindergarten through grade 12)? 8d

What single sign-on and identity management tools and approaches have schools and school systems used to ensure security and seamless user experience across online tools? 8e

COLLABORATION AND COMMUNITY SYSTEMS

9. We seek comment on implementation of collaboration and best-practice-sharing online systems. For example, we have been directed to a number of systems which demonstrate features of collaboration or online community capabilities including: www.curriki.org, www.nylearns.org, www.oercommons.org, www.schooltube.com, www.boepilot.org.

Please provide examples of successful online collaboration systems rolled out to educators and/or students. How have projects measured success? 9a

If they were not successful, what were the major challenges? 9b

What subject matter(s) attracted the most use or were the most helpful for educators or students (e.g., instructional practice development, classroom management strategies, mentor/mentee relationships, administrative processes, student projects, student research)? 9c

INNOVATION IN BROADBAND AND ONLINE SYSTEMS

10. We seek comment on opportunities for government to support innovation in the education technology sector, both in terms of driving innovative program and product development, as well as driving adoption.

What are the opportunities for government to support technology literacy, access to devices, and adoption through school-based programs for students, their families, and their communities? 10a

What are the opportunities for government in setting technology standards? 10b

Name: *

What are the opportunities for government to drive innovation in schools and school systems? 10c

What are the opportunities for the government to support research and development to drive innovation to the education technology market? 10d

E-RATE MODIFICATIONS

11. As part of the national broadband plan, we seek comment on how the Commission can modify the E-rate program to more effectively meet the needs of applicants as well as whether the program can be a vehicle to stimulate the adoption of broadband throughout communities. For example, in Portugal researchers have found that the usage of broadband in schools creates “spillover” effect that leads to greater broadband adoption in the community as students increase their Internet usage at home and transfer their technology skills to other family members.8 8 Patrick Agyapong and Pedro Ferreira, Spillover Effects from Wiring Schools with Broadband: Implications for Universal Service Policy, 37th Research Conference on Communication, Information,and Internet Policy, Arlington, VA. Sept 25-27, 2009, available at http://www.tprcweb.com/images/stories/papers/AgyapongFerreira-TPRC2009.pdf (last visited Oct. 21, 2009).

Currently, schools and libraries may obtain discounts on various services that provide highspeed access to the Internet as telecommunications and Internet access (priority 1) services. We are aware that applicants may characterize their funding requests according to terminology used on the eligible services list, such as DSL, “internet access via cable modem,” ATM, frame relay, T-1, T-3, Ethernet, OC-3, OC-12, ATM, “internet access via fiber optics,” etc. We seek information that would enable us to better understand at a more granular level what broadband services eligible applicants are buying today. Overall, what percentage of priority 1 funding is subsidizing broadband services at what speed levels, and what percentage is subsidizing basic voice service (wireline or wireless)? Can we segment the applicant community that receives discounts on higher capacity broadband services based on specific characteristics (such as number of students, rural vs. urban, discount level, etc.)? 11a

When applicants develop their technology plans, what factors do they consider in determining their bandwidth needs? 11b

We seek comment on program modifications to maximize the use of broadband connections that are subsidized by the E-rate program. Recognizing that the statute requires that discounts be provided on services used for “educational purposes,” we seek information on whether, and if so, how, past interpretations of the “educational purposes” requirement have restricted demand aggregation at the community level to support higher capacity broadband.10 For example, the program could be modified to allow for use of broadband facilities at schools by the general community, rather than just by school faculty and students.11 We seek specific examples of whether and if so, how, expanding the permissible use of E-rate supported services could confer benefits to a larger community or encourage partnerships with private or public organizations to pool resources to maximize broadband utilization. What practical or operational impact would such a change have? 11c

We seek comment on any legislative changes that would expand the classes of eligible users. For example, the statute currently limits E-rate support to elementary schools and secondary schools, which are defined by each individual state. What would the impact be of modifying the statute to permit colleges, community colleges, pre-kindergarten, Headstart, or other entities to participate in the E-rate program? 11d

To what extent does the fact that the E-rate program does not currently fund computers and other end user equipment inhibit the use of broadband by schools and libraries? Likewise, to what extent does the fact that the E-rate program does not currently fund training for teachers or librarians in the use of technology inhibit the use of broadband by schools and libraries? We seek specific information regarding what types of services are not available to teachers, students and library patrons due to lack of funding for end user equipment and training. If the E-rate program were to fund computers and training, what would the projected demand be? From a policy perspective, what are the potential negative consequences if such a change were adopted? 11e

Currently, WANs are not eligible for support “to the extent that states, schools, or libraries build or purchase a wide area network to provide telecommunications services.”14 Would modifications to this rule regarding WANs, which link schools and libraries within a district or link several school districts together, result in greater broadband deployment? 11f

Are there any programmatic rules and policies that have the effect of deterring requests for broadband funding? For instance, we understand that some libraries have suggested that compliance with filtering requirements under the Children’s Internet Protection Act represents a deterrent to program participation. Are there other statutory provisions or Commission rules or policies that may reduce program participation by entities that otherwise would utilize discounts on broadband services? Commenters should be specific in identifying which current rules may create barriers to broadband deployment. 11g

We seek comment on these ideas and on other suggestions for changing E-rate eligibility to improve broadband deployment. 11h

E-RATE DISBURSEMENT

12. We seek comment on how changing the E-rate disbursement and discount methodology might maximize the deployment of broadband.

One possible modification would be to create a new priority level for schools and libraries that do not have broadband or that have extremely slow Internet speeds to permit those entities to receive funding in advance of other eligible requests, which could enable such entities to “catch up.” An alternative would be to provide increased E-rate discounts for entities that wish to implement certain levels of connectivity. We seek comment on other methods by which the Commission could implement such changes, if they were proposed. 12a

Currently, the program’s funding varies for applicants based on the number of their students who qualify for free or reduced lunch and based on their geographic location.16 Using this measure, discounts range from 90 percent to 20 percent of the pre-discount price for eligible services, with the poorest schools receiving funding to pay for 90 percent of eligible services. Some rural schools receive additional discounts.17 The Commission could recalculate these Erate discount levels to factor in not just poverty and whether the school is located in a rural area, but also whether the entity lacks broadband services. In addition, the Commission could change its priority structure to give preference for those schools that have not received funding for internal connections in several years. We seek comment on the extent to which schools that have not received funding for internal connections (Priority 2 funding) need to improve their internal connections in order to most efficiently use their broadband connections now and in the future. 12b

To what extent have current rules inhibited the development of or expansion of existing state, regional or local broadband networks? Are there changes to the Commission’s rules that would facilitate these types of networks? 12c

If the Commission established a national broadband goal for schools or libraries, what effect would that have on demand for E-rate funding? 12d

We seek comment on these issues as well as other ideas to modify E-rate disbursements and discounts to maximize the deployment of broadband. 12e

E-RATE FUNDING

13. We seek comment on the implications of modifying E-rate funding to support additional broadband deployment and how changes to the E-rate program would improve the ability of the program to meet applicant needs for broadband.

To what extent does the annual E-rate funding cap of $2.25 billion limit the extent of broadband deployment by eligible schools and libraries? What are the financial or programmatic implications of increasing the cap to fund additional services not currently covered by E-rate? What are the implications of indexing the cap to inflation? Would there be specific implementation issues that would arise related to such changes? 13a

To the extent the Commission modifies its E-rate rules to encourage additional requests for funding for broadband services under priority 1, how would that change likely impact the availability of funding for priority 2 services? 13b

To the extent that commenters believe that providing additional funding above the current cap would advance broadband deployment, we seek comment on what additional amounts would be needed to achieve specific levels of broadband connectivity. Commenters should identify all assumptions regarding their dollar estimates. 13c

The Commission could decrease the discount levels for basic telecommunications, or otherwise modify the existing discount levels, to increase the amount of E-rate funds available for broadband deployment. What would be the effect of such a change? 13d

Would eliminating some of the services currently eligible and expanding eligibility to other services result in greater levels of broadband connectivity? Commenters should specifically articulate how proposed changes in the eligible services list would enable greater broadband deployment. 13e

What other costs not currently covered under the E-rate program would be incurred if schools and libraries could purchase additional broadband capacity? Would schools and libraries have to upgrade personal computer equipment, internal wiring, servers, and other hardware? 13f

Additionally, we seek comment on suggestions for coordinating with federal or state agencies on grant programs that could supplement the Commission’s E-rate program. For example, the United States Department of Education’s Enhancing Education Through Technology State Program (Ed Tech) provides grants to state educational agencies to improve student achievement through the use of technology in elementary and secondary schools. Money from grants such as this, in combination with E-rate funds, could greatly increase a school’s broadband connectivity. 13g

Alternatively, E-rate funds could be used in conjunction with funds from other entities to support broadband projects. For example, upon a state’s recommendation, a particular project might be funded by having the state pay for the computers and training, and providing E-rate discounts for the broadband connection. Are there other specific ways the Commission could better leverage the benefits of E-rate funding through coordination with other federal, state, local or non-profit programs that seek to advance broadband deployment? 13h

We seek comment on these suggestions and other ideas to increase the amount of E-rate funds available for broadband technologies, or to more effectively use E-rate funding to improve broadband deployment. 13i

OPEN CALL

14. We seek any additional case-studies, research and other evidence that may provide additional insight into the types of questions asked in this document. This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules. Persons making oral ex parte presentations are reminded that memoranda summarizing the presentations must contain summaries of the substance of the presentations and not merely a listing of the subjects discussed. More than a one- or two-sentence description of the views and arguments presented generally is required. Other rules pertaining to oral and written ex parte presentations in permit-but-disclose proceedings are set forth in section 1.1206(b) of the Commission's rules. See 47 C.F.R. §§ 1.1200, 1.1206. See 47 C.F.R. § 1.1206(b).

Additional case-studies, research and other evidence that may provide additional insight into the types of questions asked in this document.

Submitter's Name: