The Federal Communications Commission is designing a new digital literacy program right now, and they need your input.
Broadband adoption is a complex issue that involves questions of access, affordability, quality of infrastructure, and social aspects such as outreach, training, and support. The Open Technology Institute (OTI) has repeatedly called for federal broadband adoption policies that reflect these nuances. In particular, we have emphasized the importance of digital literacy training as a key component of effective adoption policy. We are still waiting for a program that fully captures the complexity of broadband adoption, but we hope that the latest digital literacy training effort proposed by the Federal Communications Commission (FCC) will provide an opportunity to build on existing digital literacy training efforts. The program is still in development, however, which means that our input can affect its success.
There are two existing federal efforts underway that focus heavily on the need for digital literacy training. The first, Connect to Compete, is a collection of public-private partnerships initiated by the FCC that combine discounted Internet service, the option to purchase new or refurbished discounted computers, and basic digital literacy training in select cities.
The second federal digital literacy effort, the Broadband Technology Opportunities Program (BTOP), is a part of the American Recovery and Reinvestment Act (ARRA, the Obama Administration’s federal stimulus legislation). BTOP is administered by the Department of Commerce’s National Telecommunications and Information Administration (NTIA) and provides funding for a variety of projects across the country. The BTOP supports the deployment of broadband infrastructure and encourages sustainable broadband adoption. OTI is an evaluator and an implementing partner in BTOP projects in Philadelphia and Detroit.
The FCC recently proposed an additional digital literacy training program as part of its efforts to reform the Lifeline and Link Up Fund. This fund, a subset of the larger Universal Service Fund, was created in 1985 to provide affordable phone service to low-income households. As part of a broader effort to transition the Lifeline and Link Up fund to support broadband service in addition to telephone service, the FCC has proposed to allocate $50 million to a digital literacy program. We see the program as a potentially valuable complement to other efforts, but we do have some concerns about the program’s details.
In our work as a BTOP partner in Philadelphia and Detroit, we have observed first-hand the need for digital literacy efforts that are responsive to community needs and that reflect a high level of trust between teachers and program participants. Often, the institutions that provide effective digital literacy training are multi-purpose facilities that house additional support programs and community-based organizations. They may be community centers where the homeless gather during the day; they may be job-training and assistance centers that also house public computers; they may be non-profit community organizations with varying missions, or they may be libraries where librarians are already providing informal support for patrons in the form of one-on-one assistance. What matters is that these are places where members of the community feel safe to experiment with technology in a non-threatening, supportive environment.
These BTOP-supported public computing centers will soon face an additional challenge -- the need for sustained funding to support their efforts going forward. ARRA provides support for these projects currently, but that support will end in 2013. In order to continue providing the services on which members of their community rely, these projects need new, viable options for sustainability.
The FCC’s proposed digital literacy program should be designed both to support projects like those in BTOP and to provide a mechanism for continued support to BTOP projects themselves. However, there are two main problems with the FCC program. The FCC currently finds itself a bit of a legal quagmire within the Universal Service Fund, and it also incorrectly views existing projects as sufficient to meet the needs of the communities they serve.
First, the legal quagmire – because the Universal Service Fund was originally designed to support universal phone service, there is a pesky provision in the Telecommunications Act that limits support for programs within certain portions of the Fund to only Eligible Telecommunications Carriers (ETCs). In other words, this provision means that the only entities that can receive support within certain portions of the Universal Service Fund are phone-service providers.
While many of those submitting comments to the FCC, OTI included, have offered various legal arguments to support broader eligibility, the FCC has thus far been unwilling to extend funding to non-ETCs, particularly within the Lifeline Fund. In fact, even in this digital literacy training program proposal, they suggest that one way that the program could be administered would be to provide support to an ETC, which would then send one of its employees to a community library or school to provide the training. For a variety of reasons that are explained in detail in our recent FCC filing, we think that funneling support for digital literacy training efforts through a phone company is both inappropriate and incompatible with our understanding of how successful digital literacy efforts work, and we have suggested that the FCC should structure the program in a way that provides digital literacy training support to a wide range of entities and programs.
The FCC also, somewhat emphatically, proposes to limit support within the digital literacy training program “only to entities that do not already offer formal digital literacy training services” (emphasis theirs). In fact, they go on to ask whether they should limit funding to only those communities that are not already served. From a practical standpoint, this limitation would mean that if a community already has a digital literacy training program that serves some segment of the population (the elderly, perhaps, or one neighborhood within a larger geographical area), then that entire community would be ineligible for an FCC-supported digital literacy training center. As a result, this proposal ignores valid and pressing sustainability questions for existing digital literacy efforts like BTOP. And by preventing successful existing programs from participating, it will ultimately limit their ability to share their experience and knowledge base with new digital literacy projects.
The good news is that there is still an opportunity to provide input to the FCC on this important issue. OTI filed comments that pose these concerns to the Commission. Your voice is important as well, and filing a less formal submission to the FCC is relatively easy – just go to the FCC’s electronic filing page, click “Submit a Filing (Express),” then click “11-42” (the docket number for this proceeding). There, simply fill out the web form telling the FCC why funding a broad range of entities and programs, new and existing, is critical in ensuring that this digital literacy training program is successful. A letter or a statement from your organization is all you need -- your filing doesn’t have to be in formal legal language.