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Tell the FCC to Save the Educational Broadband Service Spectrum

The Federal Communications Commission is considering a major rule change regarding the Educational Broadband Service (EBS) spectrum. It is proposing to remove the requirement that this spectrum be allocated to educational and nonprofit entities. This means the only remaining broadcast spectrum in the U.S. allocated for educational purposes has the potential to be auctioned off to large telecommunications carriers. This change may well leave millions of Americans on the wrong side of the digital divide.

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If these proposed changes are adopted by the FCC, they could remove the educational core of this public resource at a time when broadband access for education remains critical. The proposed rule change could cause the gradual reduction or elimination of EBS programs like TechSoup's Mobile Beacon program. These programs are currently being used to close the homework gap and provide connectivity to low-income individuals and families. They also help nonprofits and libraries serve the millions of people in the country without home broadband.

Find TechSoup's comments below. We encourage you to comment as well. Here's how:

  1. Go to the FCC comment page at https://www.fcc.gov/ecfs/filings/express.
  2. Once you are on the comment page, enter 18-120 in the Proceeding(s) item line.
  3. After you fill out your information and comment, review and submit it.

Your comments can be as simple as, "Please do not change the Educational Broadband Service. The requirement that the EBS spectrum be allocated to educational and nonprofit entities should remain in place. Currently, EBS programs are used to provide connectivity to many low-income people and families. They also help nonprofits and libraries serve the millions of people in the country without home broadband. To continue to eliminate the digital divide, we need the EBS spectrum to be maintained for use by educational and nonprofit entities, regardless of where they are located."

Your comments must be received by 11:59 p.m. tomorrow, August 8.

SUBMIT COMMENTS TO FCC

Comments of TechSoup Global to the Federal Communications Commission

TechSoup Global ("TechSoup") urges the FCC to preserve the current structure of licensing EBS spectrum to educational institutions and nonprofit organizations that serve the needs of educational institutions.

TechSoup is a San Francisco–based 501(c)(3) nonprofit organization established in 1987. TechSoup's mission is to bridge the "digital divide" that spurs inequality in communities across not just the U.S., but the globe. Working with over 66 donor partners, including major technology providers like Microsoft, Adobe, Google, and Amazon, TechSoup provides technologically underserved communities with vital technology and connectivity services. Included among such services are Internet access, funding, hardware, software, and training, including product donations to the social sector valued at over US$11.6 billion.

Researchers at Purdue University released an investigative report in March 2018 concluding that the apparent digital divide is the most critical issue of the 21st century. A crucial hurdle faced by members of almost all communities across the U.S. is the lack of access to affordable, unlimited Internet. Roughly one-third of American adults currently lack broadband Internet service at home (Pew Research Center, 2018).

This very digital divide is what inspired TechSoup in 2012 to partner with Mobile Beacon, a subsidiary of NACEPF, and the first U.S. broadband provider willing to make donations to the nonprofit sector. Mobile Beacon provides hotspot devices with Internet service to qualified 501(c)(3) schools, nonprofits, and public libraries serving their local communities. TechSoup maintains a rigorous validation process to ensure that only eligible nonprofit organizations meeting specific qualifications have access to these hotspot devices generously donated by Mobile Beacon.

The widespread need that 501(c)(3) nonprofits, schools, and libraries have for Internet access and related broadband services is reflected in the fact that Mobile Beacon's service has become one of the most requested donations among our donor partner offerings. As of June 2018, TechSoup has facilitated donation requests resulting in more than 24,000 Mobile Beacon hotspot devices and Internet service plans being distributed to 7,103 eligible 501(c)(3) schools, nonprofit organizations, and public libraries across the nation. These community-based organizations and their constituencies rely on affordable, unlimited, high-speed Internet service every day.

According to a recent survey, nearly a third of Mobile Beacon's nonprofit and educational clients rely on Mobile Beacon's service as their main Internet connection, and nearly 70 percent reported that Mobile Beacon's unlimited Internet service has enabled them to expand program services within their communities. The people served by these nonprofit and educational entities reported that their constituents most often use Mobile Beacon's Internet service for research, homework, email, and job-skills training.

The uncapped, high-speed broadband service these nonprofit organizations receive from Mobile Beacon — and the benefits they extend to the constituents they serve — is nationwide, notwithstanding Mobile Beacon's physical address in Rhode Island. We believe the number of educational and nonprofit organizations using Mobile Beacon's service, and the even greater number of their constituents served, is a far better proxy than a physical address for verifying Mobile Beacon's firm commitment to the needs of technology-disadvantaged communities across the country.

At a time when our society is becoming ever more dependent on technology and Internet access, Mobile Beacon's uncapped, mobile broadband service has been pivotal to helping nonprofits and educational institutions close the digital divide—and, notably, the "homework gap"—by sharing that broadband connectivity with the people they serve. As a powerful example of the benefits Mobile Beacon brings to communities as an EBS licensee, we can look to San Mateo County Library (SMCL). Understanding that library patrons' need for Internet access goes beyond the physical boundaries of the library, SMCL took the lead in providing free unlimited Internet access to its community by launching its "Bring the Internet Home" program in 2015. This program offers any San Mateo County library patron 18 years or older the opportunity to borrow a Wi-Fi hotspot for one week.

This new "In Luck" library service has enabled hundreds of households to continue educational activities at home, increase digital literacy skills, and take advantage of online education, health, employment, and community resources. SMCL received over 200 donated Wi-Fi hotspots through Mobile Beacon's donation program with TechSoup. Funding for this program was provided by a state grant, which helped cover Mobile Beacon's $10/month, unlimited 4G Internet data plans.

As a technology-focused charitable organization, TechSoup recognizes the importance in developing a 5G infrastructure that will serve the country for many years to come. However, we firmly believe that the proposed EBS reforms to eliminate current educational eligibility requirements for EBS, and to exclude nonprofits from obtaining future EBS licenses going forward, is not the correct path of implementation.

Without the educational eligibility and education use requirements that enabled Mobile Beacon to negotiate for the substantial number of broadband accounts and devices being used by the education and nonprofit sector, we believe thousands of anchor institutions and the hundreds of thousands of people they serve will be left behind and unable to partake in essential activities. Changing these rules will also make it impossible for other nonprofit and educational institutions to replicate Mobile Beacon's successful model.

Furthermore, through our understanding of the needs of communities across the nation, we support expanding the FCC's educational use rules from only acknowledging accredited educational institutions to including more types of legitimate nonprofit educational organizations such as those that support after-school programs, adult education, digital literacy, and workforce development. This will ensure EBS spectrum is used for lifelong learning.

For the sake of the public's best interest, we urge the FCC not to eliminate educational eligibility to hold an EBS license, and not to make nonprofits like Mobile Beacon ineligible for additional EBS licenses because of their nonprofit status or physical location. The FCC should be looking for ways to build on the widespread success of Mobile Beacon's use of its EBS spectrum rather than proposing rules that would diminish or eliminate such use.

SUBMIT COMMENTS TO FCC