The goal of the proposal is to extend funding beyond the 90 percent schools that would likely be the only applicants to qualify for internal connections support in the coming year. However, for more than 460 applicants, it appears the effect would be to deny funding to any school within their district or any member of their consortium that had been cited as a recipient of shared internal connections services in Year 3.
Districts typically apply on a shared basis for services such as network maintenance.
In the proposed rule change, the FCC said its preference would be to change the rules so that applicants that qualified for support in Year 3 would not be eligible in Year 4. Under the proposal, for both shared services and site-specific services, the Schools and Libraries Division would be instructed to examine each application to determine which individual sites within that application had not received funding for internal connections in the prior funding year. The proposed change would thus deny Year 4 funding for internal connections to any applicant who qualified for internal connections support at a 90 percent discount rate. In addition, it could conceivably deny internal connections funding to all of the schools and libraries covered by the applications of at least 460 school districts and consortia that apparently qualified for Year 3 internal connections support on a shared basis at discounts ranging from 89 to 82 per cent, according to an analysis by the E-rate consulting firm Funds For Learning. FFL analyzed Year 3 commitments that had been made through last December.