FCC’s Historic Hotspot Initiative Aims to Close the Homework Gap

July 19, 2024

Authored by: Kristen Corra

Yesterday, at the July Federal Communications Commission Open Meeting, the Commission approved, on a 3-2 vote, an order to make Wi-Fi hotspots and Internet services eligible for E-rate program support for libraries and K-12 schools.  This historic decision adopts a SHLB Coalition recommendation we and others proposed over three years ago.  

In 2021, Congress created the Emergency Connectivity Fund (ECF), which provided over $7 billion to schools and libraries to lend hotspots to families in need during the Covid-19 pandemic.  This program helped millions of families purchase laptops and tablets, and gave them the option to receive free wireless internet access at home. This highly successful program expired in June 2024.  Fortunately, the FCC has now revived this program by providing ongoing funding through the E-rate program.  

“Today we have a choice. We can go back to those days when people sat in parking lots to get a signal to get online, and students struggling with the Homework Gap hung around fast food places just to get Internet access they needed to do their schoolwork. Or we can go forward and build a digital future that works for everyone,” the Chairwoman stated during the July 18 meeting. 

The proposed order (the Commission will release a final order soon, which might incorporate revisions) allows schools and libraries to apply for E-rate funds to help offset the costs of purchasing Wi-Fi hotspots and Internet services to loan to students, school staff, and library patrons for off-premises internet use.  In doing so, it also establishes parameters to safeguard the spending of limited E-rate funds, including: 

• device and service reimbursement caps, 

• a three-year budget mechanism to limit overall applicant funding requests, and 

• long-standing program requirements like competitive bidding and filtering. 

This order is the latest action in the Chairwoman’s “Learn Without Limits” initiative, an effort she first announced at the 2023 American Library Association (ALA) conference that would modernize E-rate to support students’ and library patrons’ connectivity needs wherever they are.

SHLB’s Long-Standing Support for Off-Campus Services

SHLB applauds yesterday’s step forward.  We have long understood the detriment to education when students or library patrons have poor or nonexistent internet access at home.  In fact, the SHLB Coalition led a coalition (which included ALA, CoSN, SETDA, New America’s OTI and others) in filing a Petition for Expedited Declaratory Ruling in January 2021 asking for E-rate to support remote learning during the Covid-19 pandemic.  

And the Commission’s vote couldn’t have come at a better time.  Connectivity assistance is needed now more than ever, given both the lapse of Congressional funding for the Affordable Connectivity Program and the sunset of the Emergency Connectivity Fund Program.

SHLB’s Recommendations for the Hotspot Order

Over the past year, SHLB conducted a host of Commission meetings and filed extensive comments and ex parte letters detailing what an E-rate hotspot lending initiative could look like. Among our various recommendations, we suggested the following:

Technology-Neutral Rules.  We asked that the Commission’s rules remain technology neutral so that funding isn’t limited only to traditional mobile devices and services.  

For example, we explained that schools and libraries might want to deploy (or work with a partner to deploy) their own wireless networks where traditional hotspots are inadequate.  Such solutions position schools and libraries to fund projects that better connect their communities - they can utilize equipment with stronger signal strength that is able to support video instruction in hard to reach rural areas and low-income urban neighborhoods - with a structure that can often be more cost-effective over time.  

We suggested that the Commission benchmark device and service costs associated with anchor-enabled networks against traditional mobile hotspot options.  In other words, we suggested that schools and libraries should be given the flexibility to deploy other functionally-equivalent technologies as long as they are less expensive than traditional hotspots.  

Revised Budget Mechanism.  We recommended that the Commission raise the pre-discount funding cap amounts for services and hotspot equipment to reflect current market pricing.  Alternatively, we suggested that the Commission only require an applicant to stay within its total three-year budget without also limiting the amount of E-rate support for each individual hotspot device or service.  We additionally asked that the Commission remove the provision preventing applicants from requesting more than 45% of their budget in any year to accommodate the various “readiness” levels of each school and library participating in this initiative.

Waiving the E-rate Cost Allocation Rule.  We asked the Commission to waive or eliminate the E-Rate cost-allocation requirement for off-campus services that enable remote learning. This would allow schools and libraries to use the E-Rate supported services at the school/library location to distribute Internet access to the home through a private LTE or similar service without losing E-Rate support.

View our additional suggestions in our initial comments and recent ex parte filing.