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NPRM Info - Educational Associations Raise Concerns Over Broadband Service Misperceptions

EDUCATIONAL ASSOCIATIONS RAISE CONCERNS
OVER BROADBAND SERVICE MISPERCEPTIONS

Two groups representing the interests of Educational Broadband Service (EBS) licensees today expressed their concern about misperceptions concerning EBS. The National EBS Association (NEBSA) and the Catholic Technology Network (CTN), which represent the interests of a large number of EBS licensees, challenged recent claims that licensed EBS spectrum is underutilized and questioned the feasibility of a proposal to auction the spectrum in an effort to close the “homework gap”.

In areas of the country where EBS is licensed (areas that cover about 85% of the U.S. population) EBS spectrum is widely deployed. Existing flexible use rules have fostered a wide variety of educational uses of the band and created a robust secondary market for commercial broadband service, including 5G. At the same time, these rules have provided private funding and resources for education without reliance on federal assistance or other government funding.

EBS spectrum remains unused only in areas of the country where it has not yet been licensed. Those unlicensed areas, which are mostly rural and cover about 15% of the U.S. population, often are referred to as EBS white space. Lynn Rejniak, Chair of NEBSA said “Somehow the fact that EBS white space remains unlicensed has become conflated with the idea that licensed EBS spectrum is underutilized. That simply is not true.” The FCC has proposed a mechanism to license EBS white space through priority local filing windows, which NEBSA and CTN support.

NEBSA and CTN dispute claims that EBS is no longer necessary because many institutions holding EBS licenses do not use the spectrum directly to serve students, but instead lease their spectrum to commercial wireless service providers. David Moore, President of CTN said “Most EBS licensees lease a portion of their spectrum to commercial entities – most notably Sprint – in exchange for funding, resources and access to advanced broadband services needed for education. The FCC has encouraged such leasing, and educators have embraced that call by establishing successful public-private partnerships with commercial service providers.”

While NEBSA and CTN share FCC Commissioner Jessica Rosenworcel’s concern with tackling the homework gap, and appreciate her longstanding support for education, proposals to license EBS spectrum through a voluntary incentive auction do not appear to be workable nor is such an auction the best way to help students and families gain access to broadband. Unlike broadcast spectrum, which was successfully auctioned a few years ago, EBS spectrum is encumbered with long-term leases. Sprint has long-term lease arrangements with approximately 1,500 EBS licenses and EBS serves as the backbone of Sprint’s network, which covers 302 million people and serves over 54 million customers. Under these circumstances, most EBS licensees do not have the option of choosing to relinquish their spectrum to the highest bidder.

The best way to unleash the full potential of EBS is to license unassigned spectrum (covering about 15% of the U.S. population) to Tribal Nations and local educational entities through priority filing windows as the FCC itself has proposed. Extending the successful existing EBS model will help close the homework gap, and at the same time, put all available EBS spectrum into play for 5G.