Funds For Learning and other commenters provided input on the following themes:

Shorten the duration of the pilot: The FCC should expedite the pilot, allowing it to institute E-rate changes or create a private cybersecurity program sooner. Three years is too long of a pilot, and the FCC might consider running the program for 12 to 18 months. We believe this would still allow the FCC to collect adequate data while speeding up the opportunity to support more schools and libraries through future E-rate applications.
Add more funding: The current $200 million funding level would not be enough to fund the number of projects required to establish enough data for analysis. We suggested the FCC raise the budget by $112 million to provide the right level of funding needed, based on a previous analysis we conducted in 2021. We estimated the average cost per cybersecurity applicant would be $146,682. If you multiply that number by the 21,000 applicants who submitted in 2023, $312 million over two years would allow for an adequate pilot program sample size of about 5% of all applicants. This would allow the FCC to evaluate a range of applicants and solutions.
Keep a broad definition of eligible services: We also suggested that applicants be asked to follow a set of guiding principles rather than ascribe to a set menu of eligible products and services. This would allow them to innovate, while still keeping the scope of projects narrow enough to review. Several commenters also suggested the FCC refrain from creating an eligibility list of specific products, services, or technologies schools could seek funding to support via the pilot program.
Track successes: Some comments proposed that the FCC measure pilot program success by requiring applicants to commit to a specific cybersecurity framework, reporting the effect pilot funds would have on their progress towards full implementation. They argue that this tracking method would be more objective given the uncertain nature of cyberattacks on schools and libraries.
Address privacy concerns: The FCC should carefully consider the information they collect in pilot program applications and the information they make public, commenters said. Public disclosure of applicants' cybersecurity systems could expose them to attack vectors that were previously undisclosed.

Although it's a positive sign that the FCC considers off-site internet access and cybersecurity as key priorities, the commission must act quickly. We can only close the digital divide if we can do so quickly, safely and securely.

Instant Insights /

Bridging the digital divide with more Wi-Fi and tighter security

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