The North American Catholic Educational Programming Foundation, Inc. (NACEPF) and Mobile Beacon commend the Federal Communications Commission (FCC) for its decision to expand E-Rate Program funding eligibility to Wi-Fi hotspots and mobile broadband services for off-premises use. This is a critical step toward closing the digital divide and addressing the persistent homework gap. However, we strongly urge the FCC to refrain from setting specific lending-period limits or punitive usage requirements. Instead, the FCC should continue giving educators and library administrators the flexibility they need to not only set appropriate lending-period limits for the various populations they serve, while also allowing them to revise or modify their policies in response to changing needs or unique challenges faced by the students or library patrons they serve. 

NACEPF, a Rhode Island-based 501(c)(3) nonprofit organization, is the largest nonprofit licensee of 2.5 GHz spectrum (formerly Educational Broadband Service (EBS)) in the United States. Mobile Beacon, NACEPF's subsidiary, provides affordable mobile broadband internet access to the institutions that serve communities—nonprofits, schools, libraries, and healthcare organizations.

"Through our work with thousands of schools and libraries nationwide, we have seen firsthand that at-home connectivity is essential for ensuring equitable access to educational opportunities," said Katherine Primeau, Vice President of NACEPF and Executive Director of Mobile Beacon. "Schools and libraries, especially during the COVID-19 pandemic, have proven they can be trusted to effectively manage the distribution of necessary technology and support their communities in its use. We urge the Commission not to hinder their effectiveness by setting ‘one size’ overly-prescriptive requirements that will certainly not ‘fit all.”

To support the FCC’s core objective of addressing the ongoing remote learning needs of today’s students, school staff, and library patrons, NACEPF and Mobile Beacon urge the FCC to maintain the incentives and safeguards established in its recent Report & Order. We also recommend continuing to rely on schools and libraries to set and adapt their lending periods, usage requirements, cybersecurity standards, and support services to address the specific needs of their communities. 

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About Mobile Beacon: Mobile Beacon provides high-speed, low-cost, mobile internet access to the anchors of communities: the nonprofits, schools, libraries, and healthcare organizations that provide vital services to millions of Americans every day. Through this broadband service, organizations have an essential tool to fulfill their missions and maximize their philanthropic impact, which allows organizations to access more information, reach more people, and help more in their communities. Learn more at www.mobilebeacon.org. 

About NACEPF: North American Catholic Educational Programming Foundation, Inc. (NACEPF) is a Rhode Island-based 501 (c) (3) nonprofit organization and the second-largest Educational Broadband Service (EBS) licensee in the United States. NACEPF’s broadband service, religious and educational programming, and advocacy efforts support education at every level. NACEPF’s worldwide philanthropic efforts focus on providing access to the resources essential to human development and well-being. This includes access to healthy food, clean water, safe housing, education, healthcare, and faith-based services. NACEPF’s wholly-owned subsidiary, Mobile Beacon, provides broadband service to educational, nonprofit, and community anchor institutions throughout the United States. To learn more, visit www.nacepf.net.

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• NACEPF and Mobile Beacon FNPRM Comments

Lauren Yergeau
Mobile Beacon 
401-934-0500
lyergeau@mobilebeacon.org