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This week, two of ¹ú²úÊÓƵ Foundation’s programs—the Open Technology Institute and Education Policy Program—submitted recommendations to the Federal Communications Commission (FCC), outlining ways to modernize the Commission’s to meet the 21st century needs of schools and libraries across the country.

Schools and libraries in ensuring that they are adequately connected to broadband services that enable 21st century learning. Although the E-rate program, which helps schools and libraries obtain affordable telecommunications services, has had tremendous success in helping schools get connected, upgrading capacity has become increasingly difficult in recent years. Recognizing this problem, the FCC has that govern the program and consider how both its structure and funding can be improved to better equip schools and libraries.

After a series of calls for reform and proposals were released by the , Senator , FCC Commissioner , and Commissioner , the FCC opened up a in July to begin the formal process of E-rate reform. As part of this process, the FCC invited public comment on a range of possible changes to the program. ¹ú²úÊÓƵ was among one of several hundred constituent groups that weighed in before the initial September 16 deadline.

We believe that one of the keys to modernizing E-rate to support next generation connectivity is to prioritize investment in fiber infrastructure. At the moment, only 23 percent of schools are to meet today’s broadband demands—and fewer than 10 percent have the capacity they’ll need in 2017. In general, fiber is the most future-proof technology available when it comes to delivering high-capacity broadband. In addition to offering greater capacity than copper cable at the moment, it is also much easier to increase fiber’s capacity to meet future needs. ( and you don’t have to lay new cables to upgrade infrastructure.)

We recommend that E-rate encourage significantly more community investment in fiber infrastructure. It may cost more upfront, but in the long term, fiber is a . To do this, the FCC will need to increase the amount of funding available through the E-rate program and make changes to the structure to ensure that a range of options are available for communities seeking to make fiber investments. It’s also key that schools and library buildings are not only connected to the internet, but are also able to purchase necessary equipment (like wireless routers) to spread that connectivity throughout the schools and libraries and beyond.

Broadly, fostering greater community connectivity should also be a feature of the E-rate program going forward. Schools and libraries are physical and symbolic anchors in their communities and, especially for areas with the highest need, are a central point for disseminating many needed resources. Public libraries, for example, to the public, according to the Institute for Museum and Library Services. We believe that schools and libraries should have the flexibility to maintain open Wi-Fi hotspots—not only during non-school and non-business hours, but even when school is in session and libraries are open (as long as it is not disruptive to students or library patrons).

Program parity is critical as well. E-rate funds should be distributed in a way that promotes fair and equitable service and speeds to schools and libraries of various sizes and in various locations. Some of the —such as allocating E-rate dollars to schools on a per-pupil basis—could actually lead to greater inequity because of the highly variant cost of broadband service across the country. We also caution against tying funding to specific educational outcomes (since broadband access, while critical to student success, is just one of many factors that can impact student achievement in a school). And building on Education Policy Program’s work in promoting the value of early education, we urge the FCC to look for ways to promote greater equity in E-rate’s treatment of support for our country’s youngest learners (support which currently varies by state, depending on how pre-K and elementary school are defined).

And finally, we think that data collection on the E-rate program should be improved. This process starts with simpler, better designed . But it also requires an expectation that service providers will report information alongside schools and libraries, and that this data will be made available not only to the schools and libraries themselves but also to their communities and to the public at large (the FCC last fall, but in general this type of data is not made widely available). Better data can help improve the efficiency of the fund and promote greater transparency about the services and speeds available to schools and libraries.

Of course, these are not the only changes that need to be made to the E-rate program. Now that initial comments have been submitted, the FCC will give interested parties a month to review and respond to the proposals made by others in the form of reply comments. After this, a second round of comments will be due on October 16. The FCC will conduct an extensive review of everything in the public record, hear directly from individuals, organizations, and coalitions and eventually formally release formal, updated rules to the program. Anyone interested in engaging with the FCC can file comments using the FCC’s for brief submissions.