The North American Catholic Programming Education Foundation (NACEPF) and Mobile Beacon submitted comments on August 8, 2018, in response to the Federal Communications Commission’s Notice of Proposed Rulemaking Transforming the 2.5 GHz Band. NACEPF and its subsidiary Mobile Beacon welcome the Commission’s decision to initiate this EBS proceeding, which has the potential to facilitate 5G wireless deployment, free up additional spectrum for rural deployment, and close the digital divide. However, some of the Commission’s proposals, if taken together, would effectively eliminate education from the EBS band. We submit that the Commission need not abandon its long commitment to educational use to achieve its objectives.
NACEPF has licensed Educational Broadband Service (EBS) spectrum in 51 markets across the U.S., including 9 large metropolitan areas, 18 mid-size markets, and 24 rural, underserved parts of the country. Mobile Beacon, as the service organization of NACEPF, provides EBS service to 799 schools, 739 libraries, and 4,322 nonprofits across the country. These organizations often use Mobile Beacon’s broadband service to expand program services in their communities and help meet the broadband needs of their constituents and program beneficiaries. We estimate that anchor institutions are using Mobile Beacon’s internet service to benefit more than 425,000 individuals throughout the United States. Without any reliance on the universal service fund or other government subsidy program, Mobile Beacon’s service is helping to close the “homework gap”, reach underserved communities, and expand access to lifelong learning, fulfilling the objectives the FCC had over 50 years ago when they reserved the EBS spectrum for educational use.
NACEPF and Mobile Beacon support the Commission’s decision to end the decades-long filing freeze for new EBS licenses, and we urge it to adopt rules that will quickly put unused EBS spectrum into the hands of currently eligible educational and nonprofit entities who will use it to achieve its highest and best use. We look forward to working with the Commission and other commenters in this proceeding to reform and revitalize the EBS band to advance educational and commercial broadband across the country.