re: ex parte communication in in re modernizing the e-rate ... · services and therefore, e-rate...

Suite 8001919 Pennsylvania Avenue NWWashington, D.C. 20006-3401

Danielle Frappier202.973.4242 [email protected]

February 10, 2014

Marlene H. DortchSecretaryFederal Communications Commission445 12th Street, S.W.Washington, DC 20554

Re: Ex Parte Communication in In Re Modernizing the E-rate Program for Schools and Libraries, WC Docket 13-184

Dear Ms. Dortch:

Pursuant to Section 1.1206 of the Commission’s rules, 47 C.F.R. § 1.1206, the undersigned counsel hereby provides notice that on February 6, 2014, Edward Marflak, Chairman of Schoolwires, Inc. (“Schoolwires”); Kim Bayliss of Grayling; and I of Davis Wright Tremaine, met with Nicholas Degani, Legal Advisor to Commissioner Pai. We then separately met with Commissioner Rosenworcel.

During our meetings we discussed the crucial role that web hosting plays in digital learning, including as a broadband-enabling service and a critical communications tool for students, teachers, and parents. Mr. Marflak discussed a cost analysis of web hosting created by Schoolwires, which describes the cost effectiveness of web hosting as a means of promoting broadband adoption and was filed in an ex parte notice with the Commission in the above-captioned docket on February 3, 2014. Mr. Marflak also explained the important role school websites play in the process of parents engaging with their children’s education.

Finally, attached are the results of Schoolwires’ 2013 survey of school districts on the topic of their overwhelming support for continued funding for web hosting by the Schools and Libraries, or E-rate, program. Also attached is a booklet describing the results of this survey, which Mr. Marflak shared during the meetings described above.

Please contact me if you have any questions regarding this filing.

Respectfully submitted,

/s/ Danielle Frappier _

Danielle FrappierCounsel to Schoolwires, Inc.

Cc: Commissioner RosenworcelChristianna BarnhartNicholas DeganiMichael SteffenLisa HoneRegina BrownMark NadelCharles EberleJames BachtellDania AyoubiErica MyersSoumitra DasCara Voth

Attachment 1

Schoolwires, Inc. 330 Innovation Blvd., Suite 301 State College, PA 1680 schoolwires.com

Results of Schoolwires’ 2013 Web Hosting Survey

Through more than a decade of directly serving and partnering with educators, Schoolwires has made it a point to thoroughly understand the needs of the customers it serves. It also believes that when it comes to E-rate reform, the voices of school districts, individual schools, administrators and teachers are among the most valuable. For these reasons, Schoolwires surveyed its customers regarding E-rate modernization in 2010 and then, building upon the earlier survey results, again in 2013. 208 education leaders representing their districts responded to the company’s 2013 survey; 218 responded to the 2010 survey. From the survey results, it is clear that education leaders support the Federal Communications Commission’s goals of streamlining the E-rate program and making it simpler to apply for funding, while ensuring program integrity and compliance. Educators are rightfully concerned, however, that any plan to phase out E-rate funding for web hosting would have a profoundly negative effect on their school districts and the constituents that they serve. Further, it would contravene the very purpose and goals of the ConnectED initiative. A reliable and secure web hosting service is a requirement for school districts to expand digital learning and broadband adoption. “Providing reliable, secure and ongoing communications with our constituents is critical to the success of our district and our students,” says Wayde B. Byard, Public Information Office, Loudoun County Public Schools. “And the avenue for these communications is our portal supported by off-site hosting.” At the request of Commission staff and in the hope that this information can shed additional light on the needs of school districts across the country, Schoolwires presents the results of its 2013 survey (excluding any responses associated with personally-identifiable information). Each number represents an affirmative response from one of the 208 Schoolwires customers who responded to this survey.

Survey of Schoolwires Customers Relating to E-rate Support of Web Hosting

2

1. Some policy makers have suggested that E-rate funding for Web hosting should be eliminated and that

school districts should use 'free' website services instead. Many district and educational leaders have cited concerns with free website services. [Check any concerns with “free website services” that you feel apply.]

Concerns relating to advertising 194

Concerns relating to data security 186

Free services offer little to no expectation of privacy 160

Free website services are not geared for enterprise-level use 148

Free website services are not tailored to meet the needs of educational entities, nor do they provide the specialized tools needed to create and maintain the site

167

Free website services can be eliminated or otherwise canceled at any time by the provider

177

Insufficient back-up, restore and disaster recovery services 159

Insufficient support; no live support 175

Lack of awareness and compliance with industry-specific regulations such as FERPA, CIPA and Section 508

166

Lack of necessary services such as professional development/staff training, design and/or integration services

162

Legal terms and privacy policies for free website services could change at any time 153

No uptime guarantees 148


3

2. Which of the following functions do your district, school and classroom websites perform? [Check all that apply.]

District, school and classroom websites can be access points for digital learning resources and necessary for implementation of a district’s digital learning strategies

169

Enhance transparency 176

Increase ease of access to district information and data 196

Increase out-of-school learning time by providing students and parents with 24/7 access to classroom information and supplemental educational resources

155

Level the playing field across rural/urban schools by providing all students, educators, parents and community stakeholders with easy access to 21st century tools and digital learning resources

127

Make it possible for district leaders to communicate quickly and efficiently during times of crisis

164

Provide a cost-effective mechanism for sharing relevant and timely information about district and school initiatives with community members

198

Provide a forum to engage in conversation with community stakeholders, including parents, parent organizations, taxpayers, businesses and other community-based

141

194 186

160 148

167 177

159 175

166 162

153 148

0 50 100 150 200

Concerns relating to advertising

Concerns relating to data security

Free services offer little to no expectation of privacy

Free website services are not geared for enterprise-level use

Free website services are not tailored to meet the needs of…

Free website services can be eliminated or otherwise canceled…

Insufficient back-up, restore and disaster recovery services

Insufficient support; no live support

Lack of awareness and compliance with industry-specific…

Lack of necessary services such as professional…

Legal terms and privacy policies for free website services could…

No uptime guarantees

Question #1


4

organizations regarding school and school district activities, needs and priorities

Strengthen parental involvement and engagement, providing parents with instant access to district, academic, counseling and classroom information

177

169

176

196

155

127

164

198

141

177

0 50 100 150 200

District, school and classroom websites can be access points…

Enhance transparency

Increase ease of access to district information and data

Increase out-of-school learning time by providing students…

Level the playing field across rural/urban schools by…

Make it possible for district leaders to communicate quickly…

Provide a cost-effective mechanism for sharing relevant and…

Provide a forum to engage in conversations with…

Strengthen parental involvement and engagement,…

Question #2


5

3. Importance of district and school Web communications

Yes No

Does an effective family of district, school and classroom websites perform critical educational functions?

204 4

Would the elimination of E-rate funding for Web hosting result in the need to make cuts in staffing and/or other programs in order to increase IT budget to deal with the loss of the funding and service?

174 34

4. Is your Web presence (as accessed through Web browsers and mobile devices) more important or less

important to your district than it was in 2003 when Web hosting as added to the Eligible Services List as a Priority 1 Service?

More Important 201

Just as Important 5

Less Important 2

More Important 97%

Just as Important 2%

Less Important 1%

Question #4


6

5. Should web hosting remain funded within the E-rate program as a Priority 1 service?1

Response Total

Response Percent

Yes

217 100% No

1 0%

Total Respondents 218

6. Are services that promote and enable parent-teacher communication important and integral to the education of students?

Yes 205

No 3

1 Some questions in our most recent (2013) survey build upon questions that we asked in prior years. This response is from a prior survey (2010) and we believe it sheds light and helps provide additional context (particularly for questions 4 and 8).

Yes 99%

No 1%

Question #6


7

7. Methods your district uses to reach families and community members to gain input, support and buy-in for district, technology, and other initiatives. [Ranking]

Ranked #1

Ranked #2

Ranked #3

Website (through homepage articles, announcements, promotion of events using calendars, videos, blogs, discussion forums, community surveys, e-alert messages, etc.)

166 12 5

Printed newsletters and/or other printed mailings 12 131 40

Traditional media (newspapers, radio spots, magazine articles, etc.) 5 40 138

166

12

5

12

131

40

5

40

138

Website (through homepage articles, announcements,promotion of events using calendars, videos, blogs,

discussion forums, community surveys, e-alert…

Printed newsletters and/or other printed mailings

Traditional media (newspapers, radio spots, magazinearticles, etc.)

Question #7 Ranked #1 Ranked #2 Ranked #3


8

8. In addition to Web hosting, the FCC is considering the phase out of these and other eligible services. Please indicate whether you agree with the following proposals.

Yes No

No Opinion

Electronic Paging Services – With the growth of mobile technology, paging services have grown increasingly obsolete and therefore E-rate funding support should be phased out.

79 46 59

Directory Assistance – Internet search has largely replaced directory services and therefore, E-Rate funding support should be phased out.

66 57 61

Dial-up Internet Services – Most schools no longer use dial up Internet Services to access the Internet and therefore, E-rate funding support should be phased out.

89 54 41

E-mail – E-mail is no longer relevant and therefore, E-rate funding support should be phased out.

4 172 8

Local, Long Distance, and Cellular Telephone Service – E-rate funding support for local, long distance, and cellular calls should be phased out and instead transition to fund broadband initiatives.

17 145 22


9

79

66

89

4

17

46

57

54

172

145

59

61

41

8

22

0 20 40 60 80 100 120 140 160 180 200

Electronic Paging Services

Directory Assistance

Dial-up Internet Services

E-mail

Local, Long Distance, and Cellular Telephone Service

Question #8 Yes No No Opinion


10

9. Implementation of cuts – Unexpected “flash cuts” should be avoided because they can result in hardship. Any service targeted for elimination should be phased out over several years, beginning in 2015-16.

Yes 171

No 10

No Answer Entered 5

Yes 92%

No 5%

No Answer Entered 3%

Question #9


11

10. New funding for broadband – Out district supports broadband connectivity and the addition of new funding for broadband initiatives.

Yes 181

No 3

No Answer Entered 2

Yes 97%

No 2% No Answer Entered

1%

Question #10


12

11. Proposed increases in administrative and reporting burdens – The FCC has publically stated that it wants to streamline application and disbursement processes for school districts, but proposes multiple rule changes that could significantly increase administrative and reporting burdens. The FCC purposes:

Yes No

Requiring applicants to submit to USAC all competitive bidding documents, including a copy of each bid received, the bid evaluation criteria, bid sheets, a list of people who evaluated bids, memos, board minutes, or similar documents, all bids for E-rate supported services, all purchase prices and any correspondence with vendors during the bidding, evaluation, and award phase of the process. Do you support this proposed policy change?

20 164

Extending the E-rate retention requirement from five years to ten years after the last day of the delivery of services. These materials would enable USAC staff to “evaluate more fully the competitive bidding process” conducted by your school district, including in the course of an audit, ostensibly for up to 10 years after the funded services are delivered. Do you support this proposed policy change?

20 164

Requiring E-rate applicants to implement dedicated equipment to measure, collect and monitor network performance to and within each of their buildings and possibly make the collected information public. Do you support this recommendation?

27 157

20

20

27

164

164

157

0 50 100 150 200

Requiring applicants to submit to USAC all competitivebidding documents, including a copy of each bid received,the bid evaluation criteria, bid sheets, a list of people who

evaluated bids, memos, board minutes, or similardocuments, all bids for E-rate

Extending the E-rate retention requirement from five years to ten years after the last day of the delivery of services.

These materials would enable USAC staff to “evaluate more fully the competitive bidding process” conducted by your

school district, inc

Requiring E-rate applicants to implement dedicatedequipment to measure, collect and monitor network

performance to and within each of their buildings andpossibly make the collected information public. Do you

support this recommendation?

Question #11 Yes No


13

12. Impact of increased burdens – If the administrative and reporting burdens become too great, would your district consider withdrawing its participation in the E-rate program?

Yes 101

No 70

13. Potential reforms to simplify and streamline the E-rate program – We support reforms that would reduce application burdens, such as allowing a single funding request for multi-year contracts.

Yes 169

No 2

Yes 59%

No 41%

Question #12

Yes 99%

No 1%

Question #13


14

14. For small funding requests (those less than $10,000 per vendor) we support reforms to reduce administrative burdens and streamline competitive bidding processes. Competitive bidding for ALL funding requests must be (a.) fair and open and (b.) comply with all state and local procurement regulations. For small funding requests, however, the FCC should not require (a.) the submission of detailed competitive bidding documents or (b.) compliance with Federal bidding regulations. These reforms would reduce the administrative and reporting costs associated with small funding requests and, in particular, lighten the burden on small and rural schools.

Agree 165

Disagree 6

Agree 96%

Disagree 4%

Question #14

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n an

d m

aint

enan

ce o

f site

s.

Elig

ible

ser

vice

s in

clud

e in

tera

ctiv

e co

mm

unic

atio

ns fe

atur

es

t hat

bet

ter c

onne

ct m

embe

rs o

f the

sch

ool c

omm

unity

.

RAW

CO

NN

ECTI

VITY

THE

INFR

ASTR

UCT

URE

FO

R AC

CESS

AN

D

ENG

AGEM

ENT

BR

OA

DB

AN

DW

EB H

OS

TIN

G

The

irrep

lace

able

role

of w

eb h

ostin

g in

Am

eric

a’s

scho

ols

The

perv

asiv

e –

and

grow

ing

– im

port

ance

of E

-Rat

e fu

nded

web

hos

ting

cann

ot b

e ov

erst

ated

. In

a na

tiona

l sur

vey

of K

-12

adm

inis

trat

ors,

con

duct

ed a

mon

g sc

hool

dis

tric

ts o

f

a ll s

izes

and

type

s, th

e m

agni

tude

and

uni

vers

ality

of n

eed

and

supp

ort i

s ev

iden

t.

98%

100%

98%

61%

stat

e th

at w

eb h

ostin

g sh

ould

rem

ain

fund

ed a

s a

Prio

rity

One

E-R

ate

serv

ice

stat

e th

at th

eir w

eb p

rese

nce,

ena

bled

by

ente

rpris

e-gr

ade

web

hos

ting,

is m

ore

impo

rtan

t tha

n in

200

3 (w

hen

web

hos

ting

was

firs

t add

ed to

the

Elig

ible

Ser

vice

s Li

st

as a

Prio

rity

One

ser

vice

)

stat

e th

at w

ebsi

tes

leve

l the

pla

ying

fiel

d ac

ross

rura

l an

d ur

ban

scho

ols

by p

rovi

ding

eas

y ac

cess

to 2

1st

cent

ury

tool

s an

d di

gita

l lea

rnin

g re

sour

ces

stat

e th

at a

n ef

fect

ive

fam

ily o

f dis

tric

t, sc

hool

an

d cl

assr

oom

web

site

s pe

rfor

ms

a cr

itica

l ed

ucat

ion

func

tion

Prov

ides

a c

ost e

ffec

tive

mec

hani

sm fo

r sh

arin

g re

leva

nt, t

imel

y in

form

atio

n

95%

“A s

igni

fican

t maj

ority

of p

aren

ts ra

nked

sch

ool w

ebsi

tes

as th

eir

top

choi

ce fo

r driv

ing

stud

ent a

chie

vem

ent a

nd p

rovi

ding

dire

ct

acce

ss to

info

rmat

ion

and

thei

r chi

ldre

n’s

teac

hers

.”

– Pr

ojec

t Tom

orro

w S

urve

y D

ata

Repo

sito

ry

“Ove

r 80%

of m

y di

stric

t pop

ulat

ion

is in

the

Free

an

d Re

duce

d Lu

nch

Prog

ram

. Cha

nges

suc

h as

th

ese

coul

d ba

nkru

pt u

s.”

– E-

Rate

Nat

iona

l Sur

vey

Resp

onde

nt

“Tw

o th

irds

of p

aren

ts s

tate

that

they

use

sch

ool w

ebsi

tes

to

com

mun

icat

e re

gula

rly w

ith th

eir c

hild

ren’

s te

ache

rs”

– Pr

ojec

t Tom

orro

w S

urve

y D

ata

Repo

sito

ry

With

man

y di

stric

ts, i

nclu

ding

our

ow

n,m

ovin

g to

one

-to-

one

com

putin

g in

itiat

ives

, ho

stin

g re

sour

ces

are

vita

l to

the

clas

sroo

m.

– E-

Rate

Nat

iona

l Sur

vey

Resp

onde

nt

“”

Incr

ease

s ou

t-of-s

choo

l le

arni

ng ti

me

75%

80%

rank

web

site

s th

e #1

met

hod

to e

ngag

e fa

milie

s an

d co

mm

unity

mem

bers

to g

ain

inpu

t and

buy

-in fo

r di

stric

t, te

chno

logy

and

oth

er in

itiat

ives

(c

ompa

red

to ju

st 6

% fo

r prin

ted

mai

lings

and

2%

for t

radi

tiona

l

med

ia -

new

spap

ers,

radi

o, e

tc.)

As

emph

atic

ally

art

icul

ated

by

dis

tric

ts th

emse

lves

, E-

Rate

fund

ed w

eb h

osti

ng

is m

ore

esse

ntia

l tha

n ev

er–

and

inte

gral

to th

e di

gita

l inf

rast

ruct

ure

of

21st

cen

tury

lear

ning

.

Stre

ngth

ens

pare

ntal

in

volv

emen

t an

d en

gage

men

t

85%

Enha

nces

tran

spar

ency

85%

Incr

ease

s ea

se o

f ac

cess

to d

istr

ict

info

rmat

ion

and

data

94%

E-Ra

te m

ust c

ontin

ue to

inve

st in

the

infr

astr

uctu

re th

at e

duca

tors

val

ue, e

spec

ially

serv

ices

that

driv

e en

gage

men

t and

faci

litat

ene

xt g

ener

atio

n di

gita

l lea

rnin

g.–

Bob

Wis

e, P

resi

dent

, Alli

ance

for E

xcel

lent

Edu

catio

nFo

rmer

Gov

erno

r of W

est V

irgin

ia“

”D

istr

icts

, exp

erts

and

th

ough

t lea

ders

on

cont

inue

d fu

ndin

g of

web

ho

stin

g as

a P

riorit

y O

ne

E-Ra

te s

ervi

ce

“Our

web

site

is u

sed

to re

crui

t, re

tain

, inf

orm

and

so

muc

h m

ore.

Be

ing

unab

le to

reta

in fu

ndin

g fo

r the

ser

vice

put

s us

in a

ver

y ba

d po

sitio

n.”

– E-

Rate

Nat

iona

l Sur

vey

Resp

onde

nt

“It a

ppea

rs b

eyon

d di

sput

e…th

at a

web

site

pre

senc

e is

vita

lly n

eces

sary

to s

choo

ls a

nd

libra

ries.

Pha

sing

out

supp

ort f

or w

eb h

ostin

g w

ill cr

eate

a si

gnifi

cant

fina

ncia

l har

dshi

p fo

r m

any

appl

ican

ts w

ho w

ill ne

ed to

find

add

ition

al re

sour

ces

to p

ay fo

r the

ir no

n-di

scou

nted

sh

are

of b

road

band

ser

vice

s w

hich

will

unde

rmin

e th

e FC

C’s

broa

dban

d go

als.”

–

Publ

ic C

omm

ents

by

the

Stat

e E-

Rate

Coo

rdin

ator

s As

soci

atio

n

“Elim

inat

ion

of E

-Rat

e fu

ndin

g fo

r our

web

site

wou

ld re

sult

in fi

nanc

ial

hard

ship

s fo

r our

sch

ool a

nd IT

sta

ff, a

nd w

ould

elim

inat

e ou

r mai

n so

urce

for

scho

ol-to

-hom

e co

mm

unic

atio

n.”

– E-

Rate

Nat

iona

l Sur

vey

Resp

onde

nt

84%

of d

istr

icts

sta

te th

at th

e el

imin

atio

n of

E-R

ate

fund

ing

for w

eb h

ostin

g w

ould

resu

lt in

cut

s in

sta

ffing

and

/or

oth

er p

rogr

ams

in o

rder

to in

crea

se IT

bud

gets

to

offs

et th

e lo

ss o

f fun

ding

and

ser

vice

“Fre

e” w

ebsit

e se

rvic

es a

re

simpl

y no

t an

optio

n du

e to

m

ultip

le sc

hool

dist

rict c

once

rns.

“E-R

ate

fund

ing

play

s a

criti

cal r

ole

in th

e na

tion’

s sc

hool

s. T

his

need

is

espe

cial

ly c

ritic

al in

rura

l are

as, w

hich

use

ed

ucat

ion

tech

nolo

gy to

pro

vide

lear

ning

op

port

uniti

es th

at m

ight

not

oth

erw

ise

be

avai

labl

e to

thei

r stu

dent

s. W

e w

elco

me

the

chan

ce to

con

tinue

wor

king

with

the

FCC

to

ens

ure

that

the

final

cha

nges

to E

-Rat

e ba

lanc

e th

e go

al o

f mod

erni

zing

E-R

ate

with

the

flexi

bilit

y to

add

ress

the

uniq

ue

need

s of

dis

tric

ts, i

nclu

ding

opt

ions

for

web

hos

ting

and

othe

r crit

ical

ser

vice

s.”

Noe

lle M

. Elle

rson

Asso

ciat

e Ex

ecut

ive D

irect

or, P

olic

y &

Adv

ocac

yAA

SA, t

he S

choo

l Sup

erin

tend

ents

Ass

ocia

tion

Conc

erns

rela

ted

to a

dver

tisin

g93

%

89%

85%

The

impa

ct o

f red

ucin

g or

elim

inat

ing

E-Ra

te fu

ndin

g fo

r web

hos

ting

As e

ssen

tial a

s w

eb h

ostin

g co

ntin

ues

to b

e, th

e im

plic

atio

ns

o f re

duci

ng o

r elim

inat

ing

E-Ra

te fu

ndin

g fo

r the

ser

vice

are

com

men

sura

tely

sev

ere.

Dis

rupt

ion

of th

e m

ost i

mpo

rtan

t

scho

ol-to

-hom

e co

nnec

tion.

Inte

rrup

tion

of th

e pr

imar

y m

eans

for o

n goi

ng p

aren

tal e

ngag

emen

t. Lo

ss o

f the

ess

entia

l por

tal

for r

ural

, urb

an –

and

all

– di

stric

ts to

pro

vide

dig

ital l

earn

ing

reso

urce

s to

stu

dent

s.

Impo

rtan

tly, s

urve

y da

ta id

entif

ies

othe

r sig

nific

ant i

mpl

icat

ions

– fr

om p

oten

tial s

taff

ing

and

prog

ram

cut

s to

dee

p co

ncer

ns

over

sec

urit y

and

priv

acy.

The

dat

a al

so re

veal

s de

ep a

nd

perv

asiv

e co

ncer

ns a

bout

forc

ing

dist

ricts

, as

som

e po

licy

mak

ers

have

sug

gest

ed, t

o ut

ilize

“fr

ee” h

ostin

g se

rvic

es.

Conc

erns

rela

ted

to d

ata

secu

rity

Serv

ice

can

be e

limin

ated

or

canc

elle

d at

any

tim

e by

pro

vide

r

89%

85%

Web

hos

ting

repr

esen

ts

abou

t 1%

of E

-Rat

e fu

ndin

g:

just

$28

mill

ion

of $

2.38

bi

llion

. At p

enni

es p

er s

tude

nt

per w

eek,

web

hos

ting

is o

ne

of th

e m

ost c

ost-

effe

ctiv

e an

d hi

ghes

t-im

pact

ser

vice

s fu

nded

by

E-Ra

te.

Insu

ffic

ient

sup

port

; no

live

supp

ort

84%

Not

tailo

red

to th

e ne

eds

of

educ

atio

nal e

ntiti

es

Lack

of c

ompl

ianc

e w

ith in

dust

ry

regu

latio

ns s

uch

as F

ERPA

, CIP

A an

d Se

ctio

n 50

8

Litt

le to

no

expe

ctat

ion

of p

rivac

y

80%

80%

77%

No

long

er s

uppo

rtin

g w

eb h

ostin

g w

ould

be

dev

asta

ting

to o

ur d

istr

ict’s

tech

nolo

gy

initi

ativ

es in

clud

ing

blen

ded

lear

ning

.–

E-Ra

te N

atio

nal S

urve

y Re

spon

dent

“”

Insu

ffic

ient

sup

port

; no

live

supp

ort

84%

Lack

of c

ompl

ianc

e w

ith

indu

stry

regu

latio

ns s

uch

as

FERP

A, C

IPA

and

Sect

ion

508

Litt

le to

no

expe

ctat

ion

of

priv

acy

80%

77%

re: ex parte communication in in re modernizing the e-rate ... · services and therefore, e-rate...

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