In the Matter of ) )
Modernizing the E-rate Program ) WC Docket No. 13-184 for Schools and Libraries )
COMMENTS BY CONNECTED NATION, INC.
Connected Nation, Inc. supports the Wireline Competition Bureau’s proposal to fundamentally shift the prioritization of E-rate funds toward greater and immediate support of high-speed broadband connectivity to school and library premises and within those campuses. The Public Notice (“Notice”) released by the Bureau on March 6, 2014, offers several suggestions regarding how to effectuate this new vision for the E-rate fund.1 Connected Nation commends the Bureau for advancing the debate beyond whether to make the long-needed shift in E-rate prioritization into a discussion of how to implement this transition in a timely fashion. This is a strong first step in transforming E-rate into a program that better supports school and library connectivity and encourages emerging technology-enabled learning models.
However, the Commission must recognize that this is only one step – an important and immediate step – albeit an insufficient one.
For the Commission to truly recognize the promise of technology-enabled learning models – models outlined by the U.S. Department of Education Educational Technology Plan, the FCC and Department of Education Digital Textbook Playbook, and countless other education technology experts – E-rate must address the off-campus connectivity challenges that many of our nation’s learners face.2
1
Wireline Competition Bureau Seeks Focused Comment on E-rate Modernization, WC Docket No. 13-184, Public Notice, Wireline Competition Bureau, Federal Communications Commission, March 6, 2014.
2
U.S. Department of Education, National Education Technology Plan 2010, available at
http://www.ed.gov/sites/default/files/netp2010.pdf, The Digital Textbook Collaborative, DIGITAL TEXTBOOK PLAYBOOK (Feb. 1, 2012), available at http://transition.fcc.gov/files/Digital_Textbook_Playbook.pdf (“DIGITAL TEXTBOOK PLAYBOOK”).
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In speeches, FCC Commissioners have repeatedly articulated the plight of students who must sit in library parking lots late into the evening or depend on local coffee shops with free Wi-Fi to do
homework. Yet, the E-rate modernization proposals outlined in the Notice would do absolutely nothing to solve these challenges as the prioritization framework only addresses the connectivity needs of student devices while on school or library campuses.
Technology-centered advances in education, epitomized by the trend toward 1:1, blended, and flipped classroom models, require not only high-capacity broadband in and throughout school and library buildings, but also off-campus connectivity that allows students to continue to research, review,
contribute to classroom content, and access educational applications through the school-provided devices once they leave school. Off-campus connectivity for these devices is as important to the success of a 1:1 education initiative as in-school access.
However, under the current framework, once students without home broadband leave school they are immediately at a significant disadvantage to their peers. Failing to address the off-campus
connectivity challenge under E-rate could have the unintended consequence of transforming the pervasive broadband adoption gap into a deeper educational achievement gap, particularly across low-income communities where home broadband adoption remains dangerously low. Not addressing the off-campus access challenge could also trigger unintentional market trends that would hinder, instead of encourage, implementation of effective mobile learning models across the nation’s most vulnerable communities.
In these Comments, Connected Nation reiterates its support for the Commission’s re-prioritization of the E-rate program. Connected Nation understands the need to transform E-rate in a measured, fact-based, and cost-responsible way and supports the Commission’s proposal to create a series of demonstration projects that will explore tactics to do so. Connected Nation further recommends that the Commission expand E-rate support in schools and libraries in the most vulnerable communities across the country to incorporate on- and off-campus broadband connectivity for school-supplied student devices. There are many opportunities for bulk purchasing of off-campus mobile broadband connectivity, software, and application solutions that would separate the educational purposes of institution-provided devices from other uses that the E-rate program has not explored. Connected Nation recommends that the Commission study these bulk-purchasing opportunities in student-device connectivity and related
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I. THE COMMISSION SHOULD PRIORITIZE E-RATE FUNDS TO SUPPORT
HIGH-SPEED BROADBAND TO THE SCHOOL AND LIBRARY PREMISE, WITHIN THE PREMISE AND, IN TARGET AREAS, TO OFF-CAMPUS SCHOOL-SUPPLIED STUDENT EDUCATIONAL DEVICES
In its Comments,3 Reply Comments,4 and various ex parte filings in this docket, 5 Connected Nation has proposed that, to meet the technology needs of schools and libraries over the coming decades, the Commission should modernize the E-rate program by prioritizing: (1) funding of high-speed broadband connectivity to schools and libraries; (2) wireless capacity across school premises, in particular fast, robust wireless access in every classroom; and (3) mobile wireless data connectivity for teacher and student devices both on- and off-campus.
In line with Connected Nation’s recommendations, the Notice appears focused on prioritizing E-rate funds to support very high-speed broadband access to schools and libraries premises and to provide wireless access within the campus. However, the Notice has not addressed the role of off-campus connectivity of school-supplied devices used for educational purposes. Connected Nation believes that this omission is short-sighted and recommends that the Commission reconsider inclusion of off-campus connectivity of student devices as an eligible service for targeted schools serving the most vulnerable communities across the nation. In order to fully leverage the opportunities offered by education
technology, educators will need to address all three of these connectivity challenges; E-rate should do so as well. Indeed, these three services – connectivity to the school, connectivity in the classroom, and connectivity anywhere, anytime to the student device – are the three connectivity challenges that most directly affect the modern, technology-enabled classroom experience, far more so than every other service that E-rate currently supports. Connected Nation believes that failure to support these services, even if only through a small discount for schools serving the most vulnerable communities, will result in inefficient technology choices by both educators and technologists and ultimately hamper the vision set forth by Chairman Tom Wheeler in his remarks on February 5, 2014.6
3
Connected Nation, Inc. Comments, WC Docket No. 13-184 (filed Sept. 16, 2013). 4 Connected Nation, Inc. Reply Comments, WC Docket No. 13-184 (filed Nov. 8, 2013). 5
Connected Nation, Inc. Notice of Ex Parte, WC Docket No. 13-184 (filed Sep. 10, 2013, Nov. 1, 2013, Dec. 6, 2013, Jan. 14, 2014, and Mar. 24, 2014).
6
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A. THE E-RATE RULES WILL HAVE PROFOUND IMPACT ON THE EMERGING EDUCATION
INFORMATION TECHNOLOGY INDUSTRY
The E-rate rules currently being developed by the Commission will have lasting impact on strategic decisions across the education technology (Ed Tech) industry. While E-rate accounts for only a portion of school technology budgets, it is the largest national program that funds education technology. In the transition from the traditional textbook to 1:1 mobile learning, school administrators will have strong incentive to choose the technologies and connectivity options that are supported directly through E-rate, even if those options do not necessarily provide the best or most cost-effective solution to their connectivity needs.
A broad ecosystem of education technologists is currently experimenting alongside educators to determine how IT tools can best improve educational outcomes. While innovative mobile technology solutions can improve these outcomes, the Ed Tech industry will only invest in and develop mobile technology solutions and product offerings if they are demanded by educators.
For example, in a scenario in which E-rate does not provide support for off-campus connectivity of student devices, schools adopting 1:1 learning models – particularly those serving low-income communities where home broadband adoption rates remain relatively low – will be less able to afford and, therefore, less likely to purchase devices that include LTE connectivity. If this trend is large enough, equipment vendors adjusting to market needs will be more likely to develop tablets for the education market that do not include the chips needed to enable LTE. This not only would adversely affect off-campus connectivity, but also the value of on-off-campus connectivity. Under this circumstance, a classroom wireless capacity complemented with LTE capacity would not be feasible, thereby limiting network system design options. Further, due to the absence of LTE options, other unforeseen market forces could also be impacted in the related learning management system (LMS) industry, digital content publishing, and beyond. Stated simply, E-rate could inadvertently induce the market to limit the technology choices available to schools and libraries.
Connected Nation urges the Commission to evaluate the powerful impact that E-rate will have across this market and build rules that will incent – and not hamper – a vibrant expansion of twenty-first century K-12 IT-enabled education solutions. Connected Nation believes that outright exclusion of E-rate support for off-campus connectivity of student devices would adversely impact the adoption rate of 1:1 classroom models across the country, particularly among schools serving vulnerable communities.
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B. OFF-CAMPUS CONNECTIVITY IS AN ESSENTIAL COMPONENT OF 1:1BLENDED MODELS
Off-campus connectivity to institution-provided student devices is not a luxury component of 1:1 educational models; it is a necessity if students and educators are to take full advantage of the digital learning technologies. For 1:1 learning models to be truly effective and equitable – and, therefore, viable and valuable– educators need to ensure that all students will be able to access online, interactive
educational materials within the school and once they leave the school premise.
In the past, off-campus learning meant simply taking home a textbook. In a 1:1 educational model, each student needs access to an educational device that delivers interactive content and collaborative learning while in the classroom and wherever the students do their homework. As the Commission and U.S. Department of Education specifically noted in the 2012 Digital Textbook Playbook, “digital learning cannot only happen at school. To accomplish truly ubiquitous learning, students must be able to connect outside the school walls.”7
In line with this premise, in 2010 the Commission established the “EDU2011/Learning On-The-Go” (LOGO) pilot program to explore the merits and challenges of wireless off-premise connectivity for mobile learning devices. The pilot was intended to help the Commission determine whether and how off-campus services should be eligible for E-rate support.8 In doing so, the Commission noted that its current cost allocation rules that do not fund off-campus connectivity of student devices “may prevent full utilization of the learning opportunities that portable wireless devices, such as digital textbooks, can provide off campus and outside of regular school hours.”9
Results from these pilot projects provide rich testimonials indicating that the Commission’s assertion was indeed correct.10
7
DIGITAL TEXTBOOK PLAYBOOK at 30. 8
In total, the Commission funded 20 projects across 14 states with a total of $10 million. Schools and Libraries Universal Service Support Mechanism, CC Docket No. 02-6, Sixth Report and Order, FCC 10-175 (Sep. 28, 2010) at ¶¶ 41-50.
9
Id. at ¶ 41. 10
See San Diego County Office of Education, “Summary of Interim Reports Submitted by EDU 2011 Pilot Program Schools and Libraries,” WC Docket No. 10-222 (Apr. 20, 2012), available at
http://apps.fcc.gov/ecfs/document/view?id=7021912339, and Aurora Public Schools LOGO Final Report; City School District of New Rochelle, NY EDU2011 Final Report; Foxfire Center for Student Success’ Final Report; Southern Tier Library System Learning on the Go Grant Final Report; Haralson County Schools EDU2011 Pilot Program Final Report; Mohican School in the Out-of-Doors, Inc. EDU 2011 Mobile Learning Pilot Final Report; Onslow County Schools EDU 2011 Pilot Program Final Report; Piedmont City School District E-Rate Deployed Ubiquitously (EDU) 2011 Pilot Program Final Report; Riverside Unified School District’s Learning on the Go Pilot Final Report; Sioux
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As expressed by LOGO participant Orleans Parish, “After the broadband access was made available, the observations show[ed] a marked increase in student-led learning as the teacher became comfortable assigning work to specific learners and/ or learning communities within the class that can be pursued outside of class.”11 Riverside too reported higher levels of in-school and at-home student
engagement. New Rochelle echoed these experiences, observing that the wireless devices “clearly narrowed [their district’s] digital divide,” enabling students to continue learning beyond the school day and specifically showcasing peak use of the online software tools in the evening hours.12 The San Diego Unified School District reported that “[p]rior to the LOGO Program, this innovative teaching method was not being utilized because teachers could not rely on all students having access to the internet. “Flipping” and other forward-thinking strategies can only occur if every student has broadband access to the rich digital instructional materials outside of school hours.” The project compared data usage by LOGO students and the overall district student population, reporting a significant increased consumption of school-generated digital content amongst LOGO students outside school hours. The report concludes that “[w]hen teachers know that all students have access, they are more likely to utilize the resources for after-hours assignments.”13
Experts have presented similar conclusions. On March 25, 2013, during a Commission workshop on gigabit community networks, Dr. Kecia Ray, Executive Director of Learning Technology for the Metropolitan Nashville Public Schools and President of the Board of the International Society for Technology in Education (ISTE), argued that “access to online content and lessons 24/7” via gigabit connectivity is essential for sustainable blended learning models. Dr. Ray also stressed that
City Community Schools E-Rate Deployed Ubiquitously (EDU) 2011 Pilot Program Final Report; Westwood Community School District EDU2011 Pilot Program Final Report; Katy Independent School District LOGO Final Report; San Diego Unified School District LOGO Final Report; Orleans Parish School Board LOGO Final Report; Clay Hill Elementary EDU2011 Final Report, in WC Docket No. 10-222 (posted Oct. 22, 2013).
11
San Diego County Office of Education, “Summary of Interim Reports Submitted by EDU 2011 Pilot Program Schools and Libraries,” WC Docket No. 10-222 (Apr. 20, 2012), available at
http://apps.fcc.gov/ecfs/document/view?id=7021912339
12 City School District of New Rochelle, NY, “EDU 2011 Final Report,” WC Docket No. 10-222 (Apr. 30, 2013), available at http://apps.fcc.gov/ecfs/document/view?id=7520949320
13
San Diego Unified School District “LOGO Final Report,” WC Docket No. 10-222 (Oct. 22, 2013), available at
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“[c]onnectivity must extend beyond the school to all homes in order for students to have appropriate access.”14
These testimonials showcase only a preview of the looming education, social, and policy challenges faced by the nation as 1:1 blended education models expand across school systems. While ‘build it and they will come’ will be true for many schools, for others the off-campus student connectivity challenge could be prohibitive of 1:1 blended learning implementation. Where schools are unable to resolve and finance the connectivity needs of 1:1 models both within and beyond the school premise, school administrators will have no choice but to forego, delay, or only partially implement 1:1 blended models and their associated benefits.
Unfortunately, this scenario is more likely to occur in districts serving low-income communities where the home broadband adoption gap remains acute. Nationwide, 30% of households do not subscribe to broadband service at home, and in low-income communities the adoption rate is far lower. Connected Tennessee, a subsidiary of Connected Nation, estimated that in Metro Nashville Public Schools, a district with a large low-income and minority population, only fifty-six percent (56%) of the students had broadband at home.15 Among such digital inequities, there is little wonder that educators will be reluctant to embrace educational technology until all students can equally benefit from it.
At the same time, districts in well-off communities (where robust home broadband adoption can safely be assumed) will continue to move forward with 1:1 educational initiatives. As a result, in time, a pervasive broadband adoption gap among low-income populations could become an educational
achievement gap; precisely the type of gap that E-rate was designed to bridge.
14
Education Institutions Need for Gigabit Connectivity, Presentation by Dr. Kecia Ray, Mar. 27, 2013, available
http://transition.fcc.gov/presentations/03272013/Kecia-Ray.pptx (emphasis in original). Associated workshop video available at http://www.fcc.gov/events/gigabit-workshop-1.
15
Jamie McGee, Google Fiber to study bringing high-speed Internet to low-income areas in Nashville, THE TENNESSEAN, Mar. 22, 2014, available at http://www.tennessean.com/story/money/tech/2014/03/17/google-fiber-to-study-bringing-high-speed-internet-to-low-income-areas-in-nashville/6548365/.
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C. FAILURE TO SUPPORT OFF-CAMPUS CONNECTIVITY IN TARGET AREAS UNDER E-RATE
COULD TRIGGER A PERVERSE INVESTMENT CYCLE THAT WILL WORK AGAINST THE
STATED CHAIRMAN GOALS FOR E-RATE AND THE WHITE HOUSE CONNECTEDINITIATIVE
Adoption of 1:1 educational models will incentivize schools to prioritize funding that
complements the E-rate goals set by Chairman Tom Wheeler in February of this year,16 in line with the White House ConnectED initiative.17 However, the decision some districts encounter to forego or delay 1:1 learning models will impact the value of high-speed capacity broadband connectivity to and within the local school premises, and the resulting willingness to pay for those services. As a result, failure to support off-campus connectivity in target areas through E-rate could trigger a perverse investment cycle that will work against the stated goals for E-rate and ConnectED.
Once a school embraces 1:1 blended models, ubiquitous broadband capacity to support educator and student devices on the school premise becomes a must-have commodity not only to support Common Core testing requirements, but also for every-day, all-the-time learning. As a result, school districts embracing 1:1 blended models will more readily shift budgetary priorities to complement E-rate funding for very fast broadband to and within the school premise.
By contrast, schools that lag behind in implementing 1:1 educational models will perceive less value from very high-speed broadband to and within the school premise and, accordingly, will be less likely to shift other school resources to support those services. As a consequence, factors that delay adoption of 1:1 blended models will also delay adoption of the aspirational connectivity levels that the Chairman and the White House have set as for all schools.
A perverse cycle could emerge: schools faced with an off-campus student connectivity challenge – typically schools serving low-income, both rural and non-rural, communities – will lag behind in implementing 1:1 educational models. This lag will lengthen the need for textbooks and other traditional educational models, and ultimately will shrink the funds available to support subscription to high-speed broadband to and within the school premise.
16
PREPARED REMARKS OF CHAIRMAN TOM WHEELER, Federal Communications Commission, Feb. 5, 2014. 17
THE WHITE HOUSE, CONNECTED:PRESIDENT OBAMA’S PLAN FOR CONNECTING ALL SCHOOLS TO THE DIGITAL AGE
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From an economic standpoint, the model is simple. Off-campus connectivity, along with very fast, robust, and safe broadband across the school premise are all essential connectivity inputs necessary to implement twenty-first century, 1:1 educational models. Where one or all of these inputs are lacking, implementation of 1:1 models will lag behind. In turn, where such models are delayed, local school funds to support those services will also lag behind, completing a vicious cycle that will work against the objectives laid out by the White House and the FCC Chairman for the broadband connectivity across the nation’s schools and libraries. The result: less money to support school broadband connectivity overall, and an increased burden on E-rate to help achieve stated goals.
In an economic environment such as this, policy makers have multiple tools to incentivize behavior and affect final outcomes. If the Commission wants to incentivize rapid expansion of very fast broadband access available to schools and libraries and encourage lower costs of the service, it can take one of two approaches: (1) lower the effective price of connections to and within the premise paid by schools, which can be achieved by either deepening the subsidy received by schools or encouraging lower overall costs of the service, or (2) help lower the cost of off-campus connectivity, a key connectivity complement essential for implementation of 1:1 blended models, fitting within the E-rate statutory mandate.18 By supporting this complementary service, the Commission would accelerate implementation of 1:1 models, thereby rendering the service of all broadband connections within the school more
valuable, and incenting a greater portion of schools’ resources to support the stated goals for E-rate.
II. THE COMMISSION SHOULD IMPLEMENT DEMONSTRATION PROJECTS TO
ADDRESS REMAINING QUESTIONS REGARDING SUPPORT FOR OFF-CAMPUS CONNECTIVITY OF SCHOOL-SUPPLIED STUDENT DEVICES
Connected Nation recommends that the Commission carefully assess the implications in the education technology market of excluding off-campus connectivity from E-rate funding. As discussed previously, Connected Nation believes that such a decision would trigger disincentives to investment in 1:1 blended models among schools that are faced with significant challenges regarding student
18
For a full consideration of the Commission’s statutory authority to expand E-rate funds to support off-campus connectivity of student devices for educational purposes, see Connected Nation Ex Parte Letter, WC No. 13-184 (filed Mar. 24, 2014), available at http://apps.fcc.gov/ecfs/document/view?id=7521095055.
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campus connectivity. Data shows that these schools, for the most part, serve low-income, both rural and non-rural, communities.
At the same time, Connected Nation understands the budgetary pressures currently faced by the E-rate program. The art of policy-making often implies choosing how to allocate scarce resources amongst competing priorities. The Commission appears poised to redefine those priorities for E-rate by focusing first and foremost on the connectivity to and within the schools and libraries. Connected Nation has consistently supported this on the record. In the short term, this makes sense. However, as stressed during the first comment cycle in this proceeding, Connected Nation urges the Commission not to let short-term budgetary constraints and other pressures cloud its long-term strategic vision for an effective E-rate program. E-rate can and must support broadband connectivity needs to schools, within schools, and beyond schools as they implement education solutions enabled by twenty-first century technology, especially across the most vulnerable communities across the country.
For this reason, Connected Nation encourages the Commission to develop E-rate rules that include off-campus connectivity of school-supplied student devices used for educational purposes to be an eligible service, even if such a “bucket” of services is only minimally funded in the short term. Funding decisions for this service could be adjusted as the broadband access gap to school and library premises is closed, and need for off-campus access to school-provided student devices grows.
In the short run, the Commission could implement demonstration projects aimed at identifying and testing different approaches to meeting schools’ connectivity needs for student devices outside of the school premise in two ways. First, a demonstration project should explore whether certain types of purchasing options (such as bulk buying) for off-campus wireless access can reduce connectivity costs. The hypothesis to test here would be whether the market price for off-campus connectivity (such as LTE) of student devices is markedly different from the retail market for mobile broadband services when E-rate funded service are purchased through large bulk-buying processes including multiple school districts at the state, cross-state, and even national levels. Second, a demonstration project should explore whether deployment or incorporation of certain types of access management software onto the school-supplied device or network configurations help lower the cost or improve the quality of off-campus connectivity. In both cases, the Commission would also test the impact of independent technical assistance to schools as they contemplate increasingly complex connectivity choices that include solutions for the off-campus connectivity challenges faced by individual schools.
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In these demonstration projects, E-rate would fund a portion of the cost of the off-campus connectivity to student devices directly used to support educational purposes. Connected Nation suggests that participants would need to demonstrate a significant off-campus connectivity challenge across their student population as a condition of participation. In addition, participants would need to collaborate in an approved bulk-purchasing consortium or bulk-billing arrangement for that connectivity. Participants also would be expected to deploy software solutions that track student off-campus use of the device so as to verify and quantify educational versus other uses. In this type of project, the E-rate program can spur the development of these bulk purchasing arrangements and software tools in a way that would lower costs and help applicants provide innovative 1:1 solutions to learners.
III. CONCLUSION
Having submitted these Comments in response to the Public Noticed released in this docket by the Wireline Competition Bureau, Connected Nation recommends that the Commission implement the recommendations suggested herein.
Respectfully submitted, Raquel Noriega
Lindsay Shanahan
Thomas M. Koutsky, Counsel Connected Nation, Inc. P.O. Box 43586 Washington, DC 20010 1-877-846-7710 April 7, 2014
