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FCC’s Emergency Connectivity Funds Ineligible for School and Library Self-Provisioned Networks

The FCC’s May 10 order said schools and libraries could not use connectivity funds to build self-provisioned networks.



Photo of John Windhausen, Executive Director of Schools, Health and Libraries Broadband Coalition

Closing the homework gap has been a top priority for Federal Communications Commission acting Chair Jessica Rosenworcel. She has a long track record advocating for Wi-Fi-enabled school buses, lamenting viral images of school children completing homework in fast food parking lots, and making the case that no child should be left offline.

At the onset of the pandemic, she pledged to use her influence at the agency to fight to increase the flexibility of the E-Rate program, saying “every option needs to be on the table.”

When the American Rescue Plan Act established the Emergency Connectivity Fund in March, a $7 billion program to connect students and library patrons to the Internet at off-campus locations, Rosenworcel had an opportunity to follow through on those promises.

She could have seized the moment to steer the program in the direction of allowing schools and libraries to build, own, and operate their own school and community networks (what the federal government refers to as self-provisioned networks). Many schools serving areas with poorly connected students already do this, but without much help from the E-rate program.

But when the rules on how to spend the money were finalized on May 10th, the FCC’s Report and Order declared that schools and libraries could not use Connectivity Funds to build self-provisioned networks, but instead could only use the funds to purchase Wi-Fi hotspots, modems, routers, and connected devices, such as laptop computers and tablets.

The one exception in which schools and libraries can use Connectivity Funds to build self-provisioned networks is in “areas where no service is available for purchase,” based on data self-reported by private ISPs.

The Report and Order indicates the agency was not convinced allowing schools and libraries to build their own networks with the funds would be consistent with the goals Congress intended for the program, as the language in the Rescue Plan states that the Connectivity Fund is limited to the purchase of eligible equipment or advanced telecommunications and information services, as defined here.

What’s striking about that FCC interpretation is that it is completely at odds with what the Biden Administration has been espousing in the American Jobs Plan: that building publicly-owned community networks and investing in future-proof infrastructure are a crucial part of closing the digital divide. This FCC decision is a recipe for cutting students off from broadband Internet access as soon as Congressional appropriations run out rather than using those funds for solutions that will operate sustainably into the future.

Not Trying to Rock the Big Telco Boat

When the Connectivity Fund was first introduced, smaller Internet Service Providers, public interest groups, and education advocates petitioned the FCC to allow for the federal funds headed to schools and libraries to be eligible for use to build school and community networks.

The Schools, Health and Libraries Broadband Coalition; the American Library Association; and the Consortium for School Networking all found that self-provisioned networks are the most cost-effective way to permanently close the homework gap. They advocated for giving schools and libraries the most flexibility to spend these dollars and maintained that local administrators are best positioned to decide how to bridge gaps in connectivity.

Instead, the Connectivity Fund is now set to give limited remote learning funds to the same corporate ISPs that gave rise to the homework gap in the first place. The program gives a strong preference to funding hotspots provided by existing wireless mobile service providers, mainly AT&T, Verizon, and T-Mobile. (In fact, AT&T, Verizon, and CenturyLink all lobbied the agency to disqualify [pdf] self-provisioning from being eligible for ECF support.)

The agency has also announced that the program will be forward-looking; therefore, lower priority will be placed on reimbursing schools and libraries for equipment purchased over the past year to expand existing networks or build new networks to serve students and library patrons.

E-Rate is a program that passed with support from big telcos because these monopoly providers have always been a prime beneficiary of the program. Any provision allowing ECF funds to be used on self-provisioned networks would eat away at what has been a guaranteed government income stream for these private ISPs.

There has been an open petition with the FCC, since before Ajit Pai was chairman, to permanently allow schools and libraries to be able to use E-Rate funds to build their own networks where it is cost-effective. If Rosenworcel wanted to permanently enact this change, and allow for schools and libraries to deploy more innovative, long-term and cost-effective technologies, she could have pushed to close that petition, and call for commissioners to vote on the issue. But with the FCC evenly split between Democratic and Republican Commissioners, it seems Rosenworcel is making a calculated decision to not rock the boat, challenging what has long been the status quo in a regulator that is frequently accused of having a revolving door with the industry it is supposed to regulate.

Self-Provisioned Networks Connecting Students Across the Country

At the onset of the pandemic, many local school administrators across the country scrambled to connect students to the Internet. In the process, those efforts suggested that self-provisioned broadband networks are a reliable and cost-effective way to connect students at home.

In Salt Lake Valley, Utah, technology supervisor for the Murray City School District, Jason Eyre, pioneered the construction of a private LTE network using CBRS spectrum the district obtained in 2019. Within four months (between January and April 2021), Eyre had engineered a network using approximately $77,000 of CARES Act funding to cover a 3-mile square home to many low-income students in the district. (District analysis showed that 13 percent of students did not have access to service from any existing ISPs.)

In one of SHLB’s ex parte filings to the FCC, Eyre explained that the private LTE network was a much more cost-effective solution than using hotspots from traditional wireless providers. The money he would have spent to purchase hotspots, which require a monthly service fee of $40/month, was enough money instead to build the private LTE network which will last for at least five years.

Similarly, a school district in California’s Central Valley, Lindsay Unified School District, found that deploying a community network in partnership with local government was by far the most cost-effective solution to get all students online.

LUSD initially considered using hotspots, but quickly discovered that recurring monthly subscription fees would cost the district almost $1 million annually to connect 2,000 students. Additionally, the signal strength hotspots provided were too irregular to support successful remote learning in the rural, agricultural community.

The district opted for an alternative solution in 2015 to “connect 75 percent of student homes using a meshed network of Wi-Fi access points mounted on schools, city property, and, as needed, student homes,” report Michael Calabrese and Amir Nasr for New America. The feasibility of the community network was demonstrated and LUSD moved to extend the network to more students by installing access points on all school buildings.

Finally, three years ago in Boulder Valley, Colorado, Andrew Moore (Chief Information Officer of the Boulder Valley School District) launched a wireless network to connect students at home with the help of a local ISP. “After the pandemic began last March, the BVSD expanded its TV White Space pilot program, called ConnectME, extending it beyond a few schools in Lafayette and Boulder to every single school in the district,” reports New America. BVSD was able to construct and expand the network without any E-Rate or ECF support.

The New America report documents still more examples of school districts using innovative solutions to connect students at home, including efforts in San Jose, California; Council Bluffs, Iowa; Maryland; and Texas.

The Hotspot Experience

Even if hotspots were a more cost-effective solution to get students online, many school administrators have reported that the devices often fail to work in more rural and impoverished communities.

Though there are benefits to using hotspots, such as the mobility they allow for and the relative ease of the distribution process, there are many drawbacks to relying on the devices.

Hotspots operate over mobile LTE networks and the reliability of the connection, along with the download and upload speeds attainable, can vary greatly depending on the user’s distance from a cell tower, the number of people using the network, and an area’s geography, reports DigitalBridgeK-12.

In the experience of the Southern Oregon Education Services District – which serves a total of 53,000 students, in 13 school districts, living across 10,000 square miles – Coree Kelly, SOESD’s chief information officer told us, “hotspots are only working well in the same areas where you already have a wired-up connection. If you don’t have a wired-up connection available in the area, then the hotspots don’t operate well either.”

According to Kelly, each one of the 13 districts tried to use hotspots (mostly provided by Verizon and U.S. Cellular) to connect students at home, and each one experienced a degree of failure.

“We tried trading them around, we tried other carriers’ hotspots,” Kelly explained. “Every single district that tried hotspots had some percentage of failure, ranging anywhere from 100 percent failure in some of our smaller school districts [located in the mountains of Southern Oregon] to around 10 percent,” adding that “it seemed like it was really impoverished areas that the hotspots didn’t work.”

This FCC order may allow districts to build networks in those areas, but individuals in the region may have difficulty proving to the Commission’s satisfaction that there is no private solution, as most areas where the hotspots failed were reported to be served with DSL connections by Verizon on the National Broadband Map.

Kelly spent the first week of May, alongside SHLB’s executive director John Windenhausen, educating FCC Commissioners on the vast shortcomings of hotspots and urging them to give schools and libraries flexibility to use anticipated ECF funds. Kelly was initially hopeful that the school districts SOESD serves would be able to utilize the funds to build out their own networks and was deeply disappointed with the FCC’s final ruling.

“It looks like it’s going to be more of the same, not open to innovation,” Kelly said, referencing the final language of the ECF Report and Order. “Really this shouldn’t be a monetary conversation for the vendors or for the ISPs, this should be an equity conversation, and everybody should be receiving the same Internet. That’s definitely not the way it goes now, because higher poverty areas get the worst connections, and nobody is ever looking to them to upgrade.”

“We’re in education. We don’t care about profit or loss. We just want to give our children a quality education,” he added.

Kelly thinks it’s time the FCC took a different approach. “We need to do something drastically different. We’ve spent a long time up to this point, and still, with all of the subsidies and programs…we still don’t have the connections out there,” he said.

In the meantime, between this FCC ruling and the Treasury rules that discourage cities from building effective networks in areas that already have cable service, the Biden Administration has decided on its own terms to narrowly interpret statutes in ways that benefit the cable lobbyists and are at odds with their own statements regarding structural solutions to the America’s broadband woes.

Editor’s Note: This piece was authored by Jericho Casper with the Institute for Local Self Reliance’s Community Broadband Network Initiative. Originally published on, the piece is part of a collaborative reporting effort between Broadband Breakfast and the Community Broadband Networks program at ILSR.

Former Assistant Editor Jericho Casper graduated from the University of Virginia studying media policy. She grew up in Newport News in an area heavily impacted by the digital divide. She has a passion for universal access and a vendetta against anyone who stands in the way of her getting better broadband. She is now Associate Broadband Researcher at the Institute for Local Self Reliance's Community Broadband Network Initiative.


Federal Communications Commission Says $5 Billion Requested for Emergency Connectivity Fund — in Just Round One!

The program is designed to help schools, libraries and students.



Acting FCC Chairwoman Jessica Rosenworcel

August 25, 2021—Two months after launching the first round of applications, the Federal Communications Commission said Wednesday that the Emergency Connectivity Fund has received more than $5 billion in funding requests.

The requests, which came from all 50 states plus the District of Columbia, American Samoa, Guam, Northern Mariana Islands, Puerto Rico, and the Virgin Islands, are for 9.1 million connected devices and 5.4 million broadband connections.

The $7-billion program, whose first round closed August 13, provides funding for schools and libraries to buy laptops, tablets, Wi-Fi hotspots, modems, routers, and general connectivity is expected to help students stay connected at school and off school premises, addressing the “homework gap” made paramount during the pandemic.

The money is to be used for said services and devices purchased between July 1, 2021 and June 30, 2022. The program will open a second round for applications due to a spike in new coronavirus cases, which will run from September 28 to October 13.

“The Emergency Connectivity Fund is the single largest effort to bring connectivity and devices to students who lack them – and this robust response from applicants shows the tremendous need in our communities,” FCC acting Chairwoman Jessica Rosenworcel said in a Wednesday press release.

“This funding is an important down payment in closing the Homework Gap so that all children, regardless of their circumstances or where they live, have access to the tools they need to succeed,” she added.

Congress authorized the program as part of the American Rescue Plan Act of 2021. The FCC has previously noted that the Emergency Broadband Benefit had proved out that there is demand for such a program and that the ECF would help fill the gap.

Breakdown by state

The FCC included a breakdown of the first-round requests by state. California was the top requester at roughly $812 million, followed by New York with $559 million, Texas with $496 million, Florida with $264 million, New Jersey with $225 million, Arizona with $200 million, Illinois at $197 million, Georgia $183 million, North Carolina with $149 million, Michigan with $108 million, Ohio with $103 million, and Puerto Rico with $102 million, and Washington rounding out the 9-digit requesters with $101 million.

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NTIA Releases Details on Connecting Minority Communities Pilot Project

The $285-million program will help connect minority educational institutions.



Secretary of Commerce Gina Raimondo

August 4, 2021–The agency managing telecommunications policy for the commerce department has released details Tuesday on eligibility for its $285-million grant program for broadband access for minority educational institutions.

The Connecting Minority Communities pilot program, announced in June, will address the lack of broadband access, connectivity and equity at historically Black colleges or universities, Tribal colleges or universities, and minority-serving institutions.

The National Telecommunications and Information Administration released a notice of funding opportunity for the program, established via the Consolidated Appropriations Act 2021, which will grant funds to eligible recipients to purchase broadband service or equipment, hire IT personnel, operate a minority business enterprise or a tax-exempt 501(c)(3) organization, and facilitate educational instruction, including remote instruction.

Eligible institutions include 501 Hispanic-serving institutions, 336 Asian American and Native American Pacific Islander-serving institutions, 104 predominantly Black institutions, 102 historically Black colleges and universities, 66 Alaska native-serving institutions and native Hawaiian-serving institutions, 37 Tribal colleges and universities, and 32 native American-serving non-Tribal institutions.

The deadline to submit applications is December 1, 2021.

“Communities of color have faced systemic barriers to affordable broadband access since the beginning of the digital age,” said Secretary of Commerce Gina Raimondo in a press release.

“The investments we make as part of the Connecting Minority Communities Pilot Program will help communities that are struggling with access, adoption and connectivity, and will inform our path forward as we seek to finally close the digital divide across the country,” she added.

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Broadband Breakfast CEO Drew Clark and BroadbandNow’s John Busby Speak on Libraries and Broadband

Friday’s Gigabit Libraries Network conversation will feature Drew Clark of Broadband Breakfast and John Busby of BroadbandNow.



July 16, 2021—Friday’s Gigabit Libraries Network conversation will feature Drew Clark, Editor and Publisher of Broadband Breakfast, joined by John Busby, Managing Director of BroadbandNow. The event will take place on July 16, 2021, at 11 a.m. ET.

Registration for the event is available on Eventbrite. The session will also be available on Zoom.

Beginning in March of 2020, the Gigabit Libraries Network has hosted a series of conversations called the “Libraries in Recovery.”

The series is ambitious in its scope, and poses the question “What is a library if the building is closed?” Over the course of its more than 50 episodes, the the series has tackled myriad topics, ranging from equity, access, and inclusion to smart cities, social infrastructure, and the future of libraries.

The series recorded its first episode on March 26, 2020—only 15 days after the World Health Organization officially declared COVID-19 a pandemic. The episode discussed the importance of internet access during a time when many questions about the pandemic were still swirling, and many of the ramifications had yet to be felt—only a week prior had the first states begun issuing lockdowns and stay-at-home orders.

Broadband Breakfast also launched its webcast series, Broadband Breakfast Live Online, around the same time. The first session of the Broadband Breakfast series was on “Coronavirus and Education – Getting Ready for Online Education.”

Broadband Breakfast Live Online Archives provides links to all events in the Broadband Breakfast series.

Many of the Gigabit Libraries conversations and initiatives surrounding digital inclusion and the digital divide have only drifted into mainstream conversation in the wake of the pandemic.

During a time when many Americans had no idea how long they would have to remain indoors, “Libraries in Recovery” was discussing methods of boosting Wi-Fi signals to make internet available in library parking lots and the importance of remote access in anticipation of a surge in demand.

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