Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL,
CONCURRING

Re:	Modernizing the E-Rate Program for Schools and Libraries, WC Docket No. 13-184, 
Report and Order
The E-Rate program is a powerful force for digital equity.  For more than two decades, it has provided support to schools and libraries across the country, helping them connect to broadband and the internet.  
But great programs like E-Rate do not thrive without continuous attention and care.  So two years ago, at my urging the Federal Communications Commission set out to update E-Rate for the digital age.  This new iteration of the program—call it E.Rate 2.0—has produced extraordinary results.  Tens of millions of more students now have the broadband and internet access they need in their classrooms.  Libraries have seen dramatic increases in support.  And rural schools and libraries have been the most prominent beneficiaries.  These results are by and large due to changes that put a new premium on fostering Wi-Fi access through what is known as category two funding.  
With this decision, the agency takes steps to strengthen the program by cementing in place essential E.Rate 2.0 reforms.  Specifically, we extend our category two funding approach to give schools and libraries certainty about future funding available for Wi-Fi.  In addition, we improve flexibility and administration by allowing schools and libraries to budget at the school district or library system level instead of on a site-by-site basis.  These are smart adjustments that will improve the program.
Though we get the broad outlines of these changes right, I think the agency misses the mark on some key details.  To this end, I am concerned that the record before us supports a greater per pupil allowance than what is adopted in this decision.  While I appreciate the effort to maintain the status quo, the evidence suggests that some schools hold back because it is impractical to seek Wi-Fi support at current levels.  In addition, I am concerned that the decision to adjust this program for inflation only once every five years is akin to a stealth cut.  It should be done annually.  I also believe that while some libraries may find additional funding opportunities for Wi-Fi are available due to adjustments to their per square footage funding, urban libraries will see their funding levels cut.  This is not right and could limit access to the internet in libraries in some of our most populated communities nationwide.  Because I think in these respects today’s decision misses the mark, I choose to concur. 
When it comes to E-Rate, the details matter.  While we have made great strides as I note above, there is still work to do.  At present only 38 percent of school districts report that they have met the E.Rate 2.0 connectivity goal of 1 Gbps per 1000 students.  In other words, the small choices we make as we amend this program can have big impact.  
Finally, it is important to note that we need to keep a close watch on emerging cyber vulnerabilities affecting schools and libraries.  The sad truth is that civic institutions nationwide have become targets for attack.  Over the last four years, there have been over 700 reported K-12 cyber incidents.  These include an attack earlier this year in Louisiana on multiple school districts, forcing the governor to issue a declaration of emergency.  In Houston County, Alabama, a cyberattack was purportedly the reason for a delay in the start of the school year.  As these problems grow more common, it is appropriate to consider what practices can help prevent school and library networks avoid the inconvenience and harm that follows in the wake of these attacks.  So I am pleased that my colleagues agree that the agency should be open to learning more about these challenges.  I hope this will help inform policies that across the board will ensure that school and library networks remain strong and secure in the future.
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