EMERGENCY CONNECTIVITY FUND FOR EDUCATIONAL …

1101 Stadium Drive, Ada, OK 74820 phone 580.332.1444 fax 580.332.2532 www.kelloggllc.com

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of )

Establishing Emergency Connectivity

Fund To Close the Homework Gap

Addressing the Homework Gap through

the E-Rate Program

Modernizing the E-rate Program for

Schools and Libraries

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WC Docket No. 21-93

WC Docket No. 21-31

WC Docket No. 13-184

EMERGENCY CONNECTIVITY FUND FOR EDUCATIONAL CONNECTIONS AND

DEVICES TO ADDRESS THE HOMEWORK GAP DURING THE PANDEMIC

REPLY COMMENTS OF KELLOGG & SOVEREIGN® CONSULTING

Kellogg & Sovereign® Consulting (K&S) submits these comments in response to the Commission’s

request for comments released March 16, 2021 regarding Section 7402 of the American Rescue Plan,

establishing the Emergency Connectivity Fund1 (ECF).

K&S is an E-Rate consulting firm that has managed E-Rate applications for schools and libraries since the

inception of the program. At present, K&S assists over 350 E-Rate applicants in seventeen states. These

applicants range in size from a total of 41 students to applicants with 60,000+ students. The diverse client

base provides K&S with the ability to see a wide range of schools and libraries and gives them a unique

understanding of their various needs from a broad perspective.

1American Rescue Plan Act, 2021, H.R. 1319, 117th Cong., tit. VII, § 7402 (2021) (enacted), available at

https://www.congress.gov/bill/117th-congress/house-bill/1319/text (American Rescue Plan Act) (enrolled bill).

http://www.kelloggllc.com/

Kellogg & Sovereign® Consulting –Emergency Connectivity Fund Reply Comments

4/23/2021

K&S is a founding member of the E-Rate Management Professionals Association (E-mpa.org) and

actively participated in the development of the comments submitted by E-mpa. We support the comments

submitted by E-mpa2 in this proceeding dated April 5, 2021.

TABLE OF CONTENTS

I. Comments Supported ............................................................................................................................ 3

II. Comments Provided from Schools and Libraries ................................................................................. 5

A. Equipment and connected devices for remote learning .................................................................... 5

B. Advanced Telecommunications and Information Services ............................................................... 8

C. Application Process and Other Issues ............................................................................................. 14

III. Conclusion ...................................................................................................................................... 17

Exhibit 1 - Survey Respondents .................................................................................................................. 18

2 Comments submitted by the E-Rate Management Professionals Association, WC Docket No. 21-31, available at

https://www.fcc.gov/ecfs/filing/10405558528674 (filed April 5, 2021)


4/23/2021

Kellogg & Sovereign Consulting submits reply comments as follows:

I. Comments Supported

Implement a Funding Cap

KSLLC supports the comments previously submitted by E-mpa3, E-Rate Central4, Infinity5, and SECA6

along with the Notice of Exparte filing submitted by Funds for Learning7 regarding implementing a

funding cap.

We encourage the FCC to consider implementing a funding cap on a per-student basis for schools or per-

square foot basis for libraries. SECA’s proposal of a simple and clear budget will enable applicants to

easily understand the funding amount available to them. However, as described by Funds for Learning,

as well as by our survey respondents (see below), there needs to be exceptions for applicants who can

demonstrate a greater need than the funding cap allows.

We agree with the previous commenters that there are significant benefits to the cap which include

providing an opportunity for all applicants to participate in the funding as well as easing concerns about

waste fraud and abuse in the program.

Simplify the Application Process

We also agree with SECA’s comments that, “FCC can and should develop a program with simple funding

formula, an easy-to-understand application process and simple-to-complete application, and a quick and

efficient streamlined review and reimbursement process. The key purpose of the ECF is to get the

funding—and thus connectivity—out to where it is needed, not to establish procedures and regulations

that prevent the timely dispersal of these funds.”

3 Ibid.

4 Comments submitted by the E-Rate Central, WC Docket No. 21-31, available at

https://www.fcc.gov/ecfs/filing/10326326803555 (filed March 26, 2021)

5 Comments submitted by the Infinity Communications & Consulting, Inc.(“Infinity”), WC Docket No. 21-31, available at


6Comments submitted by the State E-rate Coordinators’ Alliance(“SECA”), WC Docket No. 21-31, available at


7 Notice of Exparte filed by Funds for Learning, LLC, WC Docket No. 21-93, available at

https://www.fcc.gov/ecfs/filing/1041682589484


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Ease Audit and Compliance of individual equipment and off-site locations

The audit and compliance portions of the program need to be streamlined in order to ensure funds are

safeguarded but not make compliance too complicated or cumbersome that it will discourage applicants

from applying for the funding. Since the funding is to support equipment and services at locations other

than a school or library, the beneficiaries will have a very difficult if not impossible task of tracking all

equipment to each individual user’s location plus there are privacy laws that may be violated if equipment

has to be identified at its exact location. We therefore recommend that audits focus on validating

certifications made by the beneficiary and verifying that products and services were properly ordered,

purchased and received rather than the exact location of a specific device or final end user. For example,

the auditor could follow audit procedures to validate the certifications that were made such as asking for

the beneficiary’s local procurement procedures, confirm the financial transactions by reviewing invoices

and payment documentation, and verify that the beneficiary has a process for issuing the equipment to

end users and reporting usage statistics. There would not be a fixed asset review of equipment at the end

user location or identifying the individual end user since this would be outside the ability of the

beneficiary to provide without traversing complicated privacy laws. As E-mpa explained in their

comments, the equipment that is issued to students or patrons for off-site use will most likely be lower

priced items that need to be purchased and kept at the school or library to be checked out on an as-needed

basis. The off-site equipment often breaks, needs repair, is misplaced or lost. These items can be tracked

with software monitoring systems that are currently used by libraries. However, the actual location of the

device at any given time would vary constantly and identifying the exact location or individual user may

be in violation of privacy laws. A better approach for the equipment funded with ECF would be to treat

it as supplies that are necessary for remote learning but do not need to be audited and tracked like fixed

assets installed at the school or library.


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II. Comments Provided from Schools and Libraries

As we have done in previous requests for comments, K&S sent a survey to interested schools and libraries

to gather their thoughts regarding the FCC’s proposed rules for distributing the funding from the ECF. The

following comments were gathered from the survey we conducted April 8, 2021 through April 19, 2021.

A. Equipment and connected devices for remote learning

Q1

Based on the list of eligible equipment above but excluding end-user ("connected") devices, please

provide details on any other equipment or similar equipment such as wireless routers that the FCC should

clarify as eligible equipment for connecting students, school staff, and library patrons.

• I think this is sufficient.

• Mobile Hot Spots

• Satellite receivers/equipment. example: starlink.com

• Wireless or a fixed option would be preferred for our staff.

• Power Supplies

• For rural areas like we serve, WI-FI hotspots or cellular connected devices are the number 1 need

to serve our students

• Layer 3 switches

• I believe due to the strange situation of distance learning and the varied situations each

community should be given leeway to utilize funding for their unique situation. In ours the use of

WIFI hotspots and cellular towers is the easiest and quickest way to connect our students, then

thin clients with connectivity to the wifi would be optimal

• Any infrastructure that supports the extension of a districts network into their community to

support distance learning. Thinking around LTE/CBRS

• Cell towers in areas with low connectivity or internet access. Outdoor capable wireless access

points.

• Citizens Broadband Radio Service (CBRS) is a 150 MHz wide broadcast band of the 3.5 GHz

band (3550 MHz to 3700 MHz) .

• Point to point and wireless mesh setups

• Any equipment necessary for connecting the end-user device to the internet. This would include

network cable, router, modem, and any customer charged line filter (if required).

Q2

Provide details on any connected end-user devices that are similar to "laptop computers or tablet

computers" that the FCC should clarify as eligible end-user equipment necessary for remote learning.

• Chromebook laptops, chrome tablets, iPads, portable Windows devices should all be included

here.

• Laptops, chromebooks, and ipads for our early childhood program

• Chromebooks

• I do not know of specific models but due to management costs at most small schools the

chromebooks would be the best choice, and if they could be LTE capable that would be best.

• Chromebooks, Chromeboxes, devices for staff/teachers, docking station for laptop, device cases,

carts, replacement parts for damages.


4/23/2021

• CBRS enabled device (tablet or laptop). With the SIM card built into the device. For devices that

are not CBRS enabled, we would need CBRS routers for each student household.

• Eligible end-user equipment should include desktop computer equipment as they can cost

less than laptops. A maximum cost constraint with a customer portion would be

necessary. There should be an exclusion for high-end computing equipment (Macbooks,

Gaming PC's, high-performance equipment, etc.). All eligible devices must be fully

assembled; individual component equipment should not be eligible (memory, graphics

cards, and other internal upgrades. Additionally, high-performance and gaming monitors

should negate eligibility of the device.

Q3

Provide any details you have on a commonly understood definition of a tablet computer that the FCC

should use.

• To me, the term tablet is too specific. When I think of a tablet, I think of something without a

keyboard, such as an iPad or Chrome/Android touchscreen device. I don't really consider a

Chromebook a tablet, but it should absolutely be included in funding.

• Depending on the district, iPads or Android tablets, we use iPads due to educator’s choice for

lower grades where a keyboard is not appropriate, we use iPads due to the durability they have

shown along with longer years of updates compared to Android products.

• Touch screen devices not requiring an attached keyboard

• Chromebook or full function tablet.

• Any device that has touch screen capabilities and wireless connectivity.

• Chrome tablet or ipad. Not a kindle or type of device that cannot be monitored or filtered. No

Android devices.

• A laptop or laptop computer is a small, portable personal computer (PC) with a "clamshell" form

factor, typically having a thin LCD or LED computer screen mounted on the inside of the upper

lid of the clamshell and an alphanumeric keyboard on the inside of the lower lid.

• A tablet computer is an electronic device that is capable connecting to a wireless or cellular

network without the use of a physical cable. These devices are mobile and use apps to connect the

user to the internet and other resources.

Q4

Should desktop computers be eligible for funding as connected devices?


4/23/2021

Yes

• While we acknowledge the world is mobile, there are instances where it is cheaper to purchase a

desktop workstation for "power users" who require more options and computing power that can

be purchased at a fraction of the cost of a mobile device.

• Especially in areas of considerations such as vision impairment

• For students with disabilities desktop computers allow for more custom ability to the individual

students needs.

• Sometimes a desktop is the most appropriate device for a user to connect to others.

• Yes, if these desktop units are placed in "shared" spaces like Libraries, Municipal Buildings, and

other Community Locations where they can be "shared" with many people from that area.

No

• We have migrated to laptops and docking stations for most of our use. Encompassing staff and

teachers would be very beneficial.

• I really think the price of a desktop computer could use a lot of funds up in a hurry. Therefore,

only students who have a need based on IEP assessment should be allowed to purchase a laptop.

• I can only speak from our experience, but our District did not send any desktop computers home

with either staff or students.

• If the goal is to connect students to in a way, that better supports distance learning, provides the

greatest flexibility, desktops do not make sense.

• Desktop devices are not easily transportable.

Q5

Should the Commission require that connected devices be Wi-Fi enabled and have video and camera

functions to enable remote learning?

Yes –

• Maybe the term internet enabled or something. WiFi enabled assumes no wired connectivity

which in many cases is necessary for "power users"

• Best practices prove that students do better with remote learning which includes some face-to-

face instruction time.

• We required each student to check in at least daily to a Zoom/Meet call.

• Our students need to be able to see and communicate with their instructors

• Sometimes it was necessary to take attendance through meets.

• For distance learning for some children this is their only contact outside the household

with others

• If they must be cellular capable, funding will have to be provided.

• Younger student are visual learners that are more successful when face to face instruction is

present.

• Video functionality is now a standard requirement for schools and people working from home.


4/23/2021

No –

• For instances where a student only needs to view online content, but not video chat, a desktop

computer with wired ethernet and a set of speakers are sufficient.

• Leave the option up to school districts. These features are pretty standard already.

• Some scenarios dictate the end-user use a wired network connection instead of a wireless one due

to environmental restrictions.

Q6

What software, assistive technology, or equipment should should the Commission consider when

adopting requirements for connected devices to ensure access and use by people with disabilities?

• Consideration for accommodations as recommended by special ed.

• ipads, and or other communication devices. apps; The LAMP program. Specifically. This app is

proven to be successful for our nonverbal communicators and or students building their

vocabulary.

• The only limitation should be for the purpose of utilizing the internet. To cherry-pick how a

student with disabilities does that would be limiting to the IEP team and their ability to meet the

Least Restrictive Environment responsibility they are charged with under IDEA. Basically, the

funds shouldn't be used for a chair but could be used for a mount that attached to the chair that

held an internet-connected tablet in the visual range and physical reach of the student

• Wired devices, headsets, blue tooth, speakers

• Assistive speech devices, Coughdrop App as example of software

• zoom, go to meeting, microsoft meeting. one of these is necessary. Remote management software

is important for the IT people to remotely support them also connectwise or something similar

• Mice and headphones are a must for ADA and IEP accommodations.

• Screen readers. Magnification applications. Text-to-speech synthesizers. Alternative keyboards.

On-screen keyboards. Keyboard filters. Electronic pointing devices. Sip-and-puff systems.

• No disability is the same with each individual. Leaving the minimum requirements loose can help

in allowing flexibility for schools. Too many rules reduce buying power when schools are trying

to find the right device.

• Adaptive technology such as screen-readers, braille equipment, etc. Requirements should include

providing documentation of the necessity of the equipment, which must be approved.

B. Advanced Telecommunications and Information Services

Q7

Do you agree that the construction of new networks is not supported by the statutory text enumerating

eligible equipment in section 7402 of the American Rescue Plan? In other words, the funding is not

intended to provide support for dark fiber, construction of new networks or self-provisioned networks?


4/23/2021

Yes

• A "rescue" plan (to me) implies a a response to an emergency. I don't believe that new networks

built in neighborhoods go beyond emergency response.

• I believe in some settings(communities) that will be the only way to propagate connectivity in a

given region.

• The items included have a relatively short life span. CBRS and LTE are much longer lasting and

should be included.

Q8

Should the FCC include the equipment necessary to deliver data transmission and internet access services

to connected devices as eligible?

Yes –

• This may be a good opportunity to build infrastructure.

• Devices issued to students are of greater value when data transmission and internet access is

included.

• f Dark Fiber is available in the area, then this funding would help bring it to light. Otherwise, we

would have a tremendous resource not be utilized.

Q9

Regarding eligible equipment for data transmission and internet access services, should this include

wireless towers, antennas, and other equipment necessary for a wireless network such as LTE or CBRS?

-Yes

• The goal is to reach the student where they live not just while at school.

-No

• Schools should not be in the business of providing internet across a large geographic area because

of poor service being provided by ISPs/Telecommunications Companies. Moneys should be

directed to those privately held companies to help defray the cost of building out an infrastructure

in areas where these companies can show where there is a very low or negative ROI. Then

schools could purchase those services from them using Erate or other funds.


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• This should be a utility provided by local governmental entities, versus school districts. However,

schools have the burden to address this gap until this becomes a reality.

Q10

Regarding eligible equipment for data transmission and internet access services, should this include

outdoor wireless access points or pop up wireless access points that extend the reach of the school or

library's internet access?

Yes

• Yes, small scale devices and services that use available infrastructure should be allowed.

• Yes, if they are on District property.

• It should include the ability for the schools to find the most cost effective broadcast of broadband

to its clients.

• The goal is to extend the reach from the school grounds and into the home when possible.

Q11

What should the minimum standard be for download/upload speed for off-site bandwidth? (The FCC is

recommending 25 Mbps down/ 3 Mbps up but is concerned it may not be enough for multiple users at the

same household.)

• 25Mbps down/3Mbps up is usually sufficient

• I think 25 down is fine, but up should be higher. Maybe 10-15. Zooms and Meets require about 3

Mbps

• 3Mbps up is limiting with multiple devices trying to do online meetings. I think the goal should

start at 25Mbps in both directions and go from there

• 50 Mbps

• Agreed some of our students have 6 devices in their home

• 25 down might be the minimum, but 3 up would not allow for more than one video uplink for

distance learning, for 2-3 students in one household this is not enough.

• I think it should be higher if possible, but in our area, some providers (ISP's) dont' deliver that

much.

• Hard to determine as there are any number of variables to factor. Number of users, application

requirements, etc.

• 50 Mbps down/ 10 Mbps up

• This is definitely not enough for Zoom meetings or synchronous learning. 400 / 25

• 25 Mbps down/ 3Mbps up should be the minimum. But allow for greater bandwidth in the case of

a household with multiple students.

• 25 is sufficient for multiple users. Content filtering will remove abuse by doing non educational

things with education resources.

• 30 Mbps down/5 Mbps up

• 100 Mbps down / 40 Mbps up


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Q12

Should the FCC limit one connection per location for fixed broadband services?

Yes –

• The hotspots have been a nightmare. Fixed broadband service would be much better.

• Yes, but who and how will this be governed? Our kids move around a lot and this would create a

headache if school staff played a role in the facilitation of the service. It would be best utilized on

a government portal or website with a verification document from the district or school.

• Yes but only if "per location" represents the student home.

• Per home yes.

No

• In my community, in order to achieve the current standard of 25 Mbps down/ 3 Mbps up, I would

have to utilize two lines in my own home at $45 per line.

• This is a tough question. We had some families try to check out a hot spot for each student, and

other families with 5 or more students on one hot spot. Maybe there should be a limit of 4 per hot

spot, but I don't know how you track that.

• with a household of 2-3 students this limit would not work.

• They should focus on the delivery to each student at the location.

• From a household perspective, I think 5 would be a good number. I'm answering this based on a

family unit of 5 people each having a device to work or attend school/college. From a Library or

Common Municipal Building, I think 50 would be a good number.

Q13

Should the FCC impose restrictions on how many Wi-Fi hotspots can be funded?


4/23/2021

No

• Internet access in rural areas such as ours is not driven by those who qualify for "free and reduced

lunch" but by location of the home, therefor the need can be much greater in rural areas

• Lack of internet in rural communities isn't always an affordability issue but an infrastructure

issue.

• This is another tough one. Numbers that schools can provide on percentages of households

without Internet are based on parent surveys. They will not be accurate.

• We found that many of our teachers and staff did not have internet or high speed internet in their

homes.

• Depending on bandwidth it might require more than one per household if they are multi-user

households.

• Due to student mobility, blended families, it cannot be assumed that students are only in one

house. We have a number of students who move between multiple living locations.

• Allow the Districts to determine the need based on actual student demographics.

Q14

Should the funding include support for Wi-Fi on buses?

Yes –

• As one of many options to extend WI-FI services to small rural or underserved areas for internet

access.

• Many students are on buses some part of the day and could, at that time, get homework done.

• It is a good solution but if kids had a connected device it wouldn't be necessary. Bus WiFi is an

intermediate fix to an infrastructure problem but shouldn't be looked at as a silver bullet to fix a

bigger issue.

• In some cases not all cases, our students do not need wifi on buses unless they are going on trips.

• Yes, but only where it makes sense (long rural routes, field trips and activities). Many routes are

too short for actual learning to take place and wouldn't make sense from a instructional

perspective. Maybe from a behavior aspect it might help.

• This would be very beneficial for us in a large city where bus routes take longer or where kids

participate in extra-curricular activities

• The goal is to provide students internet access wherever they are at the time of learning. Whether

at school, home, UIL event, field trip, in transport.


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No –

• I am OK with the concept, but I don't think this can be counted on as a reliable source of

connectivity.

• As a bus driver, no learning will take place on the bus...

Q15

Should the FCC provide support for management tools for checking out, tracking, and/or monitoring end-

user connected devices? If so, what do you recommend?

Yes –

• Management and monitoring - Yes / these have to be purchased on a per device basis for the most

part. The rest, no because we should already have that capability somehow.

• Cost recovery for MDM solutions

• we utilize bark and goguardian, both excellent tools for managing chrome and chrome browsers.

• Not only do we need management tools, but additional personnel is necessary to manage the

devices. It is an unbelievable undertaking in districts where staffing is thin. We are already

having an issue.

• Follette Destiny, TipWeb, JAMF, iVanti, Smart Agent inline filters, content filters.

• LanSchool

No -

• This is something that Districts should already have a handle on, though I doubt that most do. I

don't think throwing money at it will make the accountability any better.

• I would leave this up to districts to determine as they will want to use. GoGuardian, Securly,

Lightspeed are a few good options.

Q16

The Commission proposes to provide 100% reimbursement with no competitive bidding. If the

Commission requires the school or library to certify that they have complied with their local procurement

rules, is this sufficient assurance that the school or library has taken steps to ensure costs of their

purchases are reasonable?


4/23/2021

Yes

• While I think there is a lot of room here for abuse, it is quite possible that federal oversight in this

particular area could cost more in the long run.

• Providing they provide and keep records of the procurement steps and bidding process used in the

decision. And, of course, subject to audit if costs seem much higher than the local area.

• Local procurement rules say that we have to have competitive bidding -- a detailed process needs

to be lined out. It is difficult at some point to ensure the supply chain can keep up.

• Most school districts have more stringent rules than those required from the State and Federal

Government. As long as we are complying with Local regulations, we are sure that all costs are

reasonable and vendors have been vetted.

No

• Stick to best practices in saving funds. Must do competitive bidding to ensure fair access

C. Application Process and Other Issues

Q17

Several organizations are recommending that the Commission adopt for this program funding caps similar

to the E-Rate category 2 budget caps for schools and libraries. The budget caps provide assurance to the

FCC that the costs are reasonable as well as provide a fair distribution of the funds. Do you agree?

Yes

• Follow the same rules for category 2

• This will help keep it fair, and would help prevent possible procurement abuse.

• Either student count or per school class size (ex.. 2A or 5A)

No.

• I believe costs for these services is very community based and is driven by the service provider.

That may be tough to normalize across the nation.

• Some districts have schools and students that have been underserved due to lack of funding for a

long time. No caps would ensure equity.

• More affluent districts often pass bonds that cover much of the cost for network that

economically disadvantaged districts do not have. Districts should be able to purchase what is

NEEDED without limits due to enrollment or cost of solution.


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Q18

Should the FCC extend CIPA requirements to include all school or library devices supported by funding

through the Emergency Connectivity Fund that are used off-campus and outside the traditional E-Rate-

supported networks?

Yes

• Yes I do agree if school is providing the internet access or devices.

• If it is a school-issued device or school-issued account, it should be governed and monitored

accordingly.

• If CIPA compliancy is required. FCC should allow for the purchase of content filters.

They should also be made eligible as this will increase the cost to districts beyond what is

in the existing budget. • Content filtering YES. Selective list of sites that the school can Manage YES.

No

• CIPA compliance on these remote devices will force the schools into even more costs that they

don't normally incur, and will add another layer of support that they are most likely not staffed to

support.

Q19

Should the FCC provide any requirements for the disposal of equipment or continued use of the

equipment after the emergency period?

Yes

• We are concerned on how to disinfect the chrome devices once they're returned to our district.

We have had situations where the devices and cases are covered in pet/human dander, roaches,

and other unidentifiable debris. Cracking open each device case to make sure there are no roaches

or bed bugs hiding in the chassis will be a huge undertaking. I would hate to recheck out a device

and their home get infested from the previous users home environment.


4/23/2021

• Keep the rules the same as Erate. Equipment stays at the designated location for 3 years and must

be accounted for 5 years. After that, the district can replace or dispose as needed.

• Simple 2-3 year use period. Have exceptions for damaged devices

• The biggest concern for our Library is the "ongoing" costs for many of these items (e.g. monthly

cell phone bill for WiFi hotspots for example.) We need to understand how the FCC expects us to

continually pay for these services beyond the Emergency Period and how we can "stop" or

"discontinue" the services should we decide that we can no longer afford them.

No

• This is such a different and hectic and changing time that we are now in. I do not believe that the

schools and libraries should be mandated, but allowed to dispose or continue use of the

equipment according to the school or library's usage needs and policies.

• After a certain point the equipment becomes school property, allowing them to continue to use

the equipment or disposal as designated in local rules.

• After schools are completely opened back up, these devices purchased for remote use can be used

in the schools. Schools should be left on their own for purging and/or recycling of devices.

• Not at all because this is all relevant to the growth of virtual learning. So these gains, even though

driven by an epic disaster should be gains we don't abandon totally.

• If there is no money to sustain the equipment, there should be no disposal timetable.

Q20

Please provide any further suggestions regarding the Emergency Connectivity Fund that you would like

for K&S to include in our reply comments to the FCC.

• It is critical that Smart Agents and content filters be included. It would be a great one-time

approval to update Telco equipment. Phones have become invaluable in communicating with

parents and students.

• While the move to a more cloud -based network is progressing, having internal server based

networks are still popular and these resources are expensive. Servers should be added back to the

list as internal networking is vital to providing a stable network to students and staff.

• Providing assistance to schools is good, many schools already have received money and may be

perceived as double dipping for funds


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III. Conclusion

KSLLC sincerely appreciates the opportunity to submit reply comments regarding the Emergency

Connectivity Fund. As is evident from the responses, the funding is greatly needed and will be of significant

value for our nation’s schools and libraries during the pandemic. We appreciate the work the Commission

has and continues to do to reduce the “Homework/Learning Gap” and provide the support needed to keep

the lights of learning on for students across the country.

Respectfully submitted,

KELLOGG & SOVEREIGN® CONSULTING, LLC

Deborah Sovereign, CPA, CEMP

1101 Stadium Drive, Ada, OK 74820

(580) 332-1444

[email protected]

April 23, 2021

Exhibit 1 – List of Survey Respondents

mailto:[email protected]


4/23/2021

Exhibit 1 - Survey Respondents

Name: Organization: City/Town: ST Email Address:

Jeff Powell Southwest ISD San Antonio TX [email protected]

Kurt Stevens Kent District Library

Comstock

Park MI [email protected]

Justin Annis Cushing Public Schools Cushing OK

Robert Grigg Vanoss Public School Ada OK [email protected]

Myrna Martinez Harlandale ISD San Antonio TX [email protected]

Toni G McPherson Beaumont ISD Beaumont TX [email protected]

Joe Jennings Tulsa Public Schools Tulsa OK [email protected]

David white Idabel Public Schools Idabel OK [email protected]

Grant Wilson

Banner School District

31 El Reno OK [email protected]

Stephen Howard

Wewoka Public

Schools Wewoka OK [email protected]

Dianna Warren Poteau Public Schools Poteau OK [email protected]

Troy Rhoads

Cleveland Public

Schools Cleveland OK [email protected]

Cody Tanaka

Red River Technology

Center Duncan OK [email protected]

Kathy Ingram Tupelo Public Schools Tupelo OK [email protected]

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