October 9, 2017(2)

(E-RATE, ADVOCACY TOOLS) Permanent link

E-Rate Call to Action: FCC Considering Cut to Category 2 Funding

Quick Summary: The FCC is considering a policy change which would deeply cut--if not eliminate--it support for Category 2 (internal connections) within the E-Rate program. Adopted as part of the 2014 modernization, this is a premature policy consider that would undermine the intent of the 2014 vote and threaten the ability of schools and libraries to access and afford high speed connectivity in their classrooms. We need to create a groundswell of feedback from schools and libraries; please take the time to file comments.

Background: E-Rate provides $3.9 billion in discounts annually to ensure that all public libraries and K-12 public and private schools gain access to broadband connectivity and robust internal Wi-Fi. As of December 31, 2015, schools and libraries have received over $31 billion in E-Rate funds. In fact, E-Rate is the third largest stream of federal resources in the country, after Title I and IDEA. Check out E-Rate funding in your state! The promise of the E-Rate program is straightforward: to assure that all Americans, regardless of income or geography, can participate in and benefit from new information technologies, including distance learning, online assessment, web-based homework, enriched curriculum, increased communication between parents, students and their educators, and increased access to government services and information. The E-Rate program provides discounts to public and private schools, public libraries and consortia of those entities on Internet access and internal networking. (E-Rate’s previous support for voice services terminates after Program Year 2018.) E-Rate discounts are provided through the Federal Communications Commission by assessing telecommunication carriers for a total of up to $3.9 billion dollars annually. This methodology follows a long-established Universal Service Fund model, used to ensure affordable access to telephone services for residents in all areas of the nation since 1934. (Source: EdLiNC)

Policy Context: While Congress is not poised to make any changes to E-Rate, the Federal Communications Commission (FCC) is, and we want to make sure Congress knows what E-Rate, how schools and libraries use it, why the program matters, that it is working and is important, and what would happen to schools if the program were reduced or cut. Congress needs to understand that the changes of the 2014 modernization are just starting to meaningfully reach schools and libraries, and that any substantive changes would be premature and poor policy. 

Specific to what the FCC, under the leadership of Chairman Ajit Pai, are considering: When the FCC modernized the E-Rate program in 2014, it focused funding on broadband Internet service (Category 1) and Wi-Fi and internal connections (Category 2). For Category 2, E-Rate provides schools with a formula distribution of $150 per pupil, which is supposed to last schools for 5 years. Since the modernized E-Rate with a higher spending cap rolled out in 2015, schools have made active use of their Category 2 allotments. Evidence suggests that, as of today, 94% of schools meet the FCC’s interim broadband goal of 100 Mbps/1000 students, a considerable jump from 2013 when that number stood at only 30%.

Recently, the FCC’s Wireline Bureau launched a Public Notice seeking comment on Category 2 budgets. Specifically, this public notice asks how schools have used their allotments and whether schools made Wi-Fi purchases without E-Rate support. The public notice also asks why some schools have not used their allotments yet and whether they planned to do so before the end of the 5-year formula cycle. This last question may arise from data gathered by Funds for Learning that shows that “more than a third (37%) of participating sites have not touched their Category Two (“C2”) budgets, and another quarter (23%) have used less than half of their budgets. Only a relatively small percentage of sites (18%) have maxed out their C2 discounts.” In total, $2.35 billion in Category 2 funds remain unclaimed and unspent by schools.

What’s at stake? There is a growing concern that the FCC is not asking these questions merely for data-gathering purposes but for another end in entirely. The Connect America Fund (CAF), a universal service program (like E-Rate is) that provides subsidies for rural telecommunications carriers, remains underfunded and could use a funding increase. The apparent surplus in Category 2 dollars may look tempting to the FCC and CAF supporters, leading to calls to transfer unused E-Rate dollars to CAF. The data collected in this rulemaking may stand as evidence that schools are not using or do not need some or all of their Category 2 funds, providing the FCC pretext to transfer E-Rate dollars to CAF. Once those dollars are transferred out of E-Rate, they may be gone forever and stand as a precedent for lower overall funding for E-Rate for years to come.

Call to Action: The FCC has asked for the public to submit initial Comments on this Public Notice by October 23rd and Reply Comments by November 7th. Schools, districts, educators and parents should file comments in the next month that tell the FCC: Hands-off E-Rate Category 2 funds. A strong response from the education community might prevent the FCC from taking action to transfer E-Rate funds.

How to File Comments with the FCC

  • COMMENTS ARE DUE October 23
  • Draft your response comments. You can create your own comments or work from AASA’s template. Format your response as a Word/PDF document (include district letter head!).
  • Go to https://www.fcc.gov/ecfs/filings 
  • For the Proceeding Number, enter the following proceeding numbers: 13-184
  • Complete the rest of the information on the form.
  • Upload your comments at the bottom of the form.

If you are pressed for time or need help submitting the comments, I can submit them on your behalf. Please email me (nellerson at aasa.org) your final comments no later than Friday October 20, with the subject line ‘Please file E-Rate comments.’


October 9, 2017(1)


Save SALT-D: Tax Reform Impacts Schools!

Call to Action: Save #SALT-D! (Tax Reform Impacts Schools)




BACKGROUND: When it comes to tax reform, AASA is engaged in an effort to preserve the State and Local Tax Deduction (SALT-D). AASA Executive Director Daniel A. Domenech responded to the proposed elimination of SALT-D in a statement last month: "AASA is deeply opposed to the proposed elimination of the State and Local Tax Deduction (SALT-D). We believe any comprehensive tax reform legislation must preserve this deduction. As one of the six original deductions allowed under the original tax code, SALT-D has a long history and is a critical support for investments in infrastructure, public safety, homeownership and, specific to our work, our nation’s public schools. SALT-D prevents double taxation for local residents. Elimination of this deduction would increase tax rates for certain tax payers, reduce disposable income, limit ability and support for local taxes, and damage local, state and national economies." AASA is a proud member of the Americans Against Double Taxation, a coalition of state and local government organizations, service providers and other stakeholders dedicated to protecting the state and local tax deduction (SALT), a federal tax deduction claimed by 44 million American taxpayers that supports vital investments in infrastructure, public safety, home ownership and education.

CALL TO ACTION: There were multiple reports last week suggesting that a variety of alternative proposals may be on the table to restrict, limit or modify SALT rather than eliminate it entirely as the “Big Six” first proposed. Our allies in the House have confirmed these reports, and told us these talks are progressing rapidly.  

This is the first of several critical crossroads we expect to face, and we need your help to make calls to Congress immediately, urging Members to fully preserve SALT, and reject proposals that undermine this deduction which has been a central tenet of our federalism for over 100 years.  

The good news is that the talk of alternatives to eliminating SALT means our voices are being heard by Members of Congress, and they now know there is strong and widespread opposition to taking away SALT.  However, we must remain vigilant and fully engaged because so-called compromise proposals can sound reasonable, but they also can be harmful to homeowners, middle class taxpayers, state and local governments and the public services they provide, much like full repeal of SALT.  

The SALT messages we need to deliver are:  


  1. We stand firmly for the preservation of the full deduction for state and local taxes, and urge you speak out in favor of SALT and vote against any tax reform plan that eliminates, restricts or modifies this deduction.
  2. SALT has been a fixture of the federal tax code and our nation’s fiscal federalism for more than 100 years to guard against double taxation of households and protect the fiscal integrity of state and local governments, and it should remain in the tax code without limitation.  
  3. Any limitations, restrictions or changes to SALT would undermine these fundamental principles of our federalism and create a slippery slope that would subject SALT to continued erosion whenever Washington needs more money – at the expense of 44 million middle class households and homeowners who now claim this deduction. 
  4. The elimination of SALT is one of the largest sources of revenue in the “Big Six” tax plan, estimated at $1.3 trillion dollars taken from 44 million households.  Thus, any compromise and anything less than preserving the full deduction, is sure to cause millions of taxpayers to pay higher taxes, undermine funding for state and local government and the services they support, and possibly cause home values to decline as well.  

Targets: Calls to any Members of Congress are helpful. Please don’t be shy; more calls are better than fewer. We can’t overdo it. We need to mobilize. The phone number for the Congressional switchboard is (202) 224-3121. If you need contact information for your Congressional delegation, let us know. Thanks so much.


October 9, 2017

(GUEST BLOGS) Permanent link

Guest Blog: Update on LGBTQ Student Rights and Policies

Today's guest blog comes from our friends at GLSEN. Please direct any questions or requests for additional information to Sarah Munshi (sarah.munshi@glsen.org).

Much has transpired over the past year related to transgender students’ rights – in the courts, in public policy, and in public debates. At GLSEN, we want every student, in every school, to be valued and treated with respect, regardless of their sexual orientation, gender identity or gender expression. We believe that all students deserve a safe and affirming school environment where they can learn and grow.

With so much happening in America today, it is more important than ever that every student, including transgender and gender nonconforming students, understand that their school is a safe, welcoming place in which they can learn and thrive. As superintendents and school leaders are faced with critical decisions in their communities that deeply impact students’ school experiences and their success, we want to be sure that accurate information for creating inclusive and non-discriminatory schools and classrooms is readily accessible. Even as the law continues to evolve regarding protections for transgender students, there is clearly nothing that as a matter of law should preclude policy and practice that is educationally grounded and research-based.   

Resources to support your schools include the U.S. Department of Education’s guide, “Examples of Policies and Emerging Practices for Supporting Transgender Students,” and GLSEN and the National Center for Transgender Equality’s “Model District Policy on Transgender and Gender Nonconforming Students.” Policies such as these have transformed the educational experience for transgender students while critically avoiding any disruption or harm to the educational experience of other students. Thousands of schools across the country have successfully implemented these policies.*   A growing body of evidence shows that districts and schools that adopt and implement all-inclusive policies and practices – including restroom policies – are effective in establishing physically and psychosocially safe schools, resulting in better health and education outcomes for transgender students. 

As the leading national education organization working to create safe and affirming schools for all students, regardless of sexual orientation or gender identity, or gender expression, GLSEN is proud to lead the effort. Working with school leaders, teachers, parents, and students—as well as national education organizations and associations whose memberships and constituents work directly in schools every day—we seek to provide practical and actionable support for lesbian, gay, bisexual, transgender, and queer and questioning (LGBTQ) students. And with an extensive Chapter network, currently comprised of nearly 40 Chapters across the country, GLSEN and our volunteers stand ready to work with you ensure that schools are safe and affirming for all, through the resources listed above, direct support, and professional development from GLSEN staff and Chapters.

* GLSEN and Movement Advancement Project, “Separation and Stigma: Transgender Youth & School Facilities,” April 2017.  http://lgbtmap.org/transgender-youth-school.