The National Digital Inclusion Alliance today submitted comments to the Federal Communications Commission on proposed new rules that could reduce future allocations of “Educational Broadband Service” (EBS) spectrum to local school systems, colleges and universities, and other nonprofit and public educational users.

The FCC is considering changes in EBS rules that could redirect “underutilized” spectrum now reserved for EBS to commercial wireless companies, in the name of promoting “NextGen 5G Connectivity”. The proposed rules could also weaken or scuttle the current requirement for at least 5% of EBS spectrum use to be educational, even when the spectrum is leased by the educational license holders to wireless providers like Sprint.

NDIA’s comments highlight the growing importance of nonprofit and public EBS allocations for community digital inclusion initiatives across the U.S. EBS has enabled innovative, affordable broadband options for hundreds of thousands of  low income Americans, including $10-per-month home hotspot accounts provided by Mobile Citizen and Mobile Beacon; a growing array of library hotspot lending programs; and the use of EBS licenses to create school-owned wireless broadband networks for families in unserved and underserved communities.

NDIA’s comments conclude:

In light of the importance of existing EBS allocations and EBS spectrum leasing arrangements to digital inclusion efforts across the U.S., NDIA asks the Commission:

  • To be careful to take no actions as a result of this proceeding which will reduce the spectrum allocations available to educational institutions or, through those holders, to established local EBS licensee coalitions and nonprofit resellers such as Mobile Citizen and Mobile Beacon;
  • To give existing EBS license holders, as well as local nonprofit and public educational institutions, an unequivocal priority over for-profit entities in the allocation of underutilized EBS spectrum;
  • To retain the existing educational use requirements for EBS spectrum allocations; and
  • To explicitly identify digital inclusion – i.e., activities to ensure that all individuals and communities, including the most disadvantaged, have access to and use of computer and Internet technology – as an educational use for purposes of meeting this requirement.

You can read or download NDIA’s full comments here.

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