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EDUCAUSE participates in a flurry of comments to the FCC regarding broadband

EDUCAUSE has participated in four different sets of comments that were delivered in recent weeks to the FCC. The documents addressed three different questions before the Commission and were written and filed jointly with various partners and coalitions. Links to the full documents and their main points are as follows:

1.      Schools and Libraries Universal Service Support Mechanism (E-rate program) and the National Broadband Plan… submitted July 9, 2010. EDUCAUSE submitted comments as part of the SHLB (Schools, Hospitals, and Library Broadband) Coalition and in close cooperation with the K-12 and library community in which it stated:

a.       Support for reducing the complexity of the E-rate process;

b.      Support for greater flexibility in choosing services, especially “dark fiber”;

c.       Concern for extending the list of eligible services to include wireless beyond the classroom; and

d.      Support for permitting non-telecommunications carriers to provide services under the E-rate program (i.e. R&E networks).

2.      Schools and Libraries Universal Service Support Mechanism (E-rate program) and the National Broadband Plan…submitted July 9, 2010. EDUCAUSE submitted comments along with Internet2, National Lambda Rail and the Quilt in which it requested that:

a.       R&E networks be explicitly allowed to participate in the E-rate program to provide eligible services;

b.      Dark fiber be treated as an eligible service from any provider including R&E networks;

c.       E-rate eligible entities be allowed and encouraged to share networks with non-E-Rate eligible entities; and

d.      The application process be streamlined.

3.      Connect America Fund, National Broadband Plan, and the High-Cost Universal Service Support…submitted July 12, 2010. EDUCAUSE submitted comments as part of the SHLB Coalition in which it asked that broadband providers that receive Connect American Fund support should be required to ensure that community anchor institutions have affordable, high-capacity broadband.

4.      Framework for Broadband Internet Service…submitted July 15, 2010. EDUCAUSE submitted comments in partnership with the Association of Research Libraries and the American Library Association to show support for the FCC adopting its “Third Way” proposal for re-establishing its authority over the regulation of broadband services. It also asked that the FCC clarify that this regulation would only apply to broadband services offered to the general public, i.e. commercial providers and not to private networks.

If you have questions regarding any of these documents, or concerns regarding the positions taken, please contact me at Your insights are always welcome and there will be numerous opportunities to submit ideas and comments to the Commission over the coming months.

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