Originally published by the Benton Foundation on behalf of Joanne Hovis on January 4, 2017.  The original post can be found by following this link.

The SHLB Coalition developed Connecting Anchor Institutions: A Broadband Action Plan to provide ideas and actionable policy recommendations for government leaders at the federal, state, and local levels to address the broadband needs of anchor institutions. The ten policy papers highlight connectivity gaps and explain why broadband access is vital to communities nationwide. In the coming weeks, the Benton Foundation will be highlighting each of the Action Plan policy papers. The following is an excerpt of the third paper. Be sure to register for Partnerships and Rural Broadband Needs, a webinar coming on January 10.

Introduction

Partnerships, aggregation, and coordination in securing broadband services are valuable tools for community anchor institutions (CAIs). Aggregating buying power on a regional or statewide basis is a tested best practice that can enable anchor institutions to achieve lower per unit pricing, higher bandwidth, and improved service quality. Policymakers should encourage anchors to consider joint procurement and coordination with entities representing other anchor sectors in their state or region. Aggregated procurement also encourages broadband providers to collaborate and bid with other providers—which could flatten pricing and reduce geographical disparities.

The Aggregated Purchasing Model

Under the aggregated purchasing strategy, multiple anchors (such as school districts and/or libraries) on a regional or super-regional basis—or ideally, on a statewide basis with support of one or more state agencies—combine their request for proposal (RFP) processes to solicit and contract for Internet bandwidth and wide area network (WAN) connections, dark fiber, wavelengths, Ethernet, or any other service. (The RFP process established by the Federal Communications Commission (FCC) in its E-rate program is conducive to this model, but the strategy can also benefit CAIs that do not participate in E-rate.)

In this approach, the anchors cooperate to develop the joint RFP and select the vendor(s). Ideally, the buying group would be as large as possible and would include both rural and metropolitan-area anchors—thus enabling, on the one hand, rural communities to benefit from the substantial buying power of higher-volume urban districts and, on the other, enabling urban communities to benefit from the buying power afforded rural stakeholders by federal funding programs. Establishing a joint urban-rural consortium for the purchase of broadband services can also permit the CAIs to adopt a “postalized rate” pricing regime that allows rural CAIs to pay the same per-unit rate as the urban CAIs.

The FCC encourages consortium buying in both the E-rate program(1) (for schools and libraries) and in the Rural Healthcare program.(2) In the Rural Health Care Pilot program, originally adopted in 2007, the FCC found that “the flexible, consortium-based approach of the Pilot Program fostered a wide variety of health care broadband networks that enabled better care and lowered costs, . . . enabling smaller HCPs [health care providers] to draw on the medical and technical expertise and administrative resources of larger HCPs.” As a result, the FCC has directed the Universal Service Administrative Company (USAC) to prioritize consortium applications for expedited review in both the E-rate and Rural Healthcare programs.(3)

Statewide or Regional Procurement

Aggregated buying is a best practice that has also been utilized powerfully at the state and regional level. A large-scale state or regional procurement strategy can leverage the collective buying power of several anchor institutions, which together represent a massive customer for commercial service providers. Significant leadership and organization are necessary to implement aggregated buying, including convincing stakeholders at the local level to participate. But the challenge can be overcome by pointing out the significant cost benefits. These benefits include:

• Lower per unit pricing across the full range of key services, including Internet bandwidth and WAN
• transport costs;
• Potential increased investment and improved services by private sector providers;
• Reduced (per CAI) administrative and processing costs; and
• Additional management expertise that could benefit participants with limited technology resources.

Lower Unit Pricing

An anchor institution, when acting alone, often is a relatively small purchaser, particularly in smaller communities in rural areas. Indeed, even if an anchor — such as a school district — is one of the bigger buyers in the region, it still has relatively modest buying power. Dramatically compounding this problem is the fact that, in many areas, there may be only a single broadband provider with the facilities to serve the anchors. As a result of the modest buying power and the effective lack of competition, rural and single anchors have little to no leverage to secure pricing comparable to that of larger buying groups or metropolitan area districts that may be fortunate enough to have slightly more competition.

In contrast, the aggregate of the communications purchases made by all anchors in a region or state is substantial—and in total likely represents one of the largest communications purchasing sectors in that area. Greater purchasing power can deliver better pricing because bidders offer lower per unit costs in order to secure the volume business opportunity.

The aggregated purchasing strategy is also likely to have positive impacts on commodity Internet bandwidth costs. The cost of bandwidth varies dramatically depending on location (i.e., it will be significantly less costly in Chicago or El Paso than in Peoria or Farmington) and the size of the total purchase (i.e., large bulk purchases of bandwidth will result in lower per-megabit costs than will smaller purchases). The ability of the broader anchor community to buy commodity bandwidth in bulk and then distribute it across a region or state to locations where it is needed can dramatically decrease the per-megabit price of that bandwidth.

Increased Private Sector Investment

The opportunity to realize more revenue and improve long-term business opportunities can convince commercial providers to make additional network investments to serve consortium purchasers. The scale enabled by large group buying is likely to create a business opportunity so appealing to the service provider community that it may organize itself to build additional fiber and offer improved services. Service providers may also offer certain benchmarks for service and upgrade service levels in order to win such a large opportunity.

The new E-rate rules, which explicitly allow E-rate funding for special construction and dark fiber, also present new opportunities for aggregate purchasing. The prospect of receiving substantial ongoing E-rate subsidy for services, and the opportunity to obtain upfront payment for network expansion (particularly for fiber construction), amplify the business opportunity for service providers.

The development of new infrastructure would serve not only the anchor customers, but also many other users in the surrounding area. Indeed, fiber built to currently unconnected anchors can serve as a “middle-mile bridge” into areas where the anchors are located—and then provide a means of extending service over time to business and residential customers. At the same time, the construction will have direct economic development benefits, as well as catalyzing long-term indirect benefits that flow from the new communications services.

Reduced Administrative and Processing Costs

Another significant benefit of regional, super-regional, or statewide procurement is lower (per anchor) net administrative costs, including RFP preparation, RFP review, contract negotiations, contract administration, invoice review and payments, and, very significantly, interaction with the E-rate administration. One of the E-rate program’s biggest challenges is the considerable administrative cost involved at the local level. While the FCC has made efforts to reduce the administrative burden, some of the components of the E-rate application process have become more complex as a result of the significant E-rate rule changes in the two E-rate orders adopted in 2014, particularly for “big-ticket” applications. Collaborative purchasing leads to the opportunity to share the costs of an E-rate consultant or consultants, thereby lowering administrative costs for all participants in the consortium.

Bringing Additional Resources to Help

Consortia applicants can also benefit from shared management and technological expertise. Either the purchasing cooperative itself, or service providers, can provide management services to help even out the technological skill and capacity of the membership. This benefits all members of the purchasing group in that it makes sure that all members are able to benefit evenly from the purchase, installation, and management of connectivity for their organization. This benefit is particularly important for rural CAIs that may not have the resources to hire engineering and legal support necessary to ensure the application meets all the criteria for approval.

Notes:

1. Federal Communications Commission, In the Matter of Modernizing the E-rate Program for Schools and Libraries, Report and Order and Further Notice of Proposed Rulemaking, WC Docket 13-184 (July 23, 2014) (“First E-rate Modernization Order”), ¶168. [The FCC stated, “Consortium purchasing can drive down the prices paid by schools and libraries for E-rate supported services. In this section, we reduce or eliminate some of the existing barriers to applicants’ participation in consortia.”]
2. Federal Communications Commission, In the Matter of Rural Health Care Support Mechanism, Report and Order, WCDocket 02-60 (December 21, 2012) ¶50.
3. First E-rate Modernization Order, ¶168.