Give schools and libraries the flexibility to purchase the lowest-cost broadband solutions

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Recommendation #127

FCC Chapter: 11.17

Status: In progress

The Federal Communications Commission should give schools and libraries more flexibility to purchase the lowest-cost broadband solutions.

Applicants should be able to acquire the lowest-cost broadband service, whether it is a fully leased or a mixed lease/own solution. For instance, the current ineligibility of dark fiber prevents applicants from pursuing lower-cost mixed lease/own strategies for broadband infrastructure. Allowing funding for ownership or leasing of dark fiber and associated communications equipment could allow recipients to use locally underutilized commercial or governmental capacity to provide lower-cost, high-value broadband instead of leased services currently eligible for E-rate discounts.

The FCC should reexamine specific E-rate rules that appear to limit the flexibility of applicants to craft the most cost-effective broadband solutions based on the types of broadband infrastructure, services and providers available in their geographic areas.

The E-rate program already has a three-year amortization rule for "special construction" fees that E-rate applicants pay carriers that construct infrastructure to serve them. This is done to avoid front-loading the E-rate fund with expenses tied to such long-lasting projects. Extending this rule to situations where recipients receive funding for broadband solutions that may involve ownership or mixed lease/ownership of network components—such as the need to purchase equipment to light leased dark fiber—could reduce the short-term impact on the fund.

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