Speak Up to Save Educational Broadband Service
Chairman Ajit V. Pai
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554


WC Docket No. 18-120

Dear Chairman Pai:

On behalf of the undersigned that work directly with and advocate for educators, students, community anchor institutions, low-income Americans, minorities, seniors, persons with disabilities, veterans, and consumers in rural areas, we urge you to retain educational eligibility requirements to hold an EBS license and to license much-needed EBS white spaces through priority windows to tribal and educational entities that will use this spectrum to reach millions of Americans who are unserved or underserved by the commercial sector.

EBS provides substantial educational benefits and must be protected

Today, EBS is connecting tens of thousands of schools, libraries, and other anchor institutions and, through them, students, families, and lifelong learners who are not otherwise reached by comparable commercial broadband offerings. Tremendous opportunities exist for EBS to serve under-connected students and communities especially at a time when internet access has never been more important as a platform for learning and opportunity.

The Commission should resist efforts to commercialize the band. Doing so would abandon the band’s long educational legacy, undermine the educational EBS services being provided today, and foreclose on the opportunity this proceeding presents to modernize EBS to help solve some of our nation’s most pressing broadband challenges—the digital divide and the homework gap.

EBS is one of the few tools the Commission has to address the homework gap

The Commission has repeatedly expressed concern about the homework gap—the systematic inequality arising from a student’s inability to access the high-speed internet connectivity needed to complete homework, out-of-school projects, and other activities that have become crucial parts of modern education. An estimated 70% of teachers assign homework that requires access to broadband, even as 12 million American students go home at the end of each school day to a household that lacks a high-speed internet connection.

Today EBS spectrum is being harnessed to combat these inequities. Some EBS licensees have used their spectrum to build county-wide broadband networks that connect students both in the classroom and in their homes and communities. Other EBS licensees lease their excess spectrum to implement programs, which provided affordable internet service to schools, libraries, and other nonprofit entities that, in turn, extends access to students who otherwise lack a home internet connection. For example, EBS programs are used today to provide wi-fi on school buses and for libraries to loan the internet through hotspot lending programs that connect unserved students across the country. The Commission should not abandon these programs nor should it give up on one of the few tools it has to help close the homework gap.

The commercial sector has not, and will not, close the digital divide

There can be no dispute that despite the fact that the overwhelming majority of non-federally-reserved spectrum is available for commercial purposes, rural schools and communities remain unconnected. Nearly 30 percent of rural Americans and 36 percent of those living on tribal lands lack access to LTE service with a median speed of 10Mbps/3Mbps. Even where infrastructure has been deployed, millions of low-income individuals and families cannot afford commercial service. Priority licensing of unassigned EBS spectrum to educational and tribal entities is needed to drive deployment and help close this divide. That’s why over 250 individuals, schools, libraries, and nonprofits from across the country have written to the Commission to urge that EBS remain educational, many explaining that they rely on high-quality, low-cost EBS-enabled services today that are not available from commercial providers.

A significant portion of the 2.5 GHz band is already available for commercial use, and the Commission's existing rules enable EBS licensees to enter into leases that make this spectrum available for extensive commercial use while providing for educational benefits through its educational use rules. At a time when broadband for education is more critical than ever, the Commission should not commercialize the only remaining portion of the only remaining band dedicated to advancing education.

Much is at stake in this proceeding. Broadband is today’s essential platform for learning and opportunity. By preserving education in the EBS band the Commission can ensure this public resource serves its highest and best use—connecting students, families, and communities that would otherwise lack internet access.


Cc: Commissioner Jessica Rosenworcel
Commissioner Michael O’Rielly
Commissioner Brendan Carr
Commissioner Geoffrey Starks


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