BellSouth said in comments the FCC should clarify that its descri...

the Funding Year 2005 Eligible Services List (ESL), outlining which specific products or services could receive discounts under the Schools & Libraries Support Mechanism. The list addressed telecom services, Internet access, internal connections and special eligibility conditions. BellSouth said services such as 24-hour network monitoring, network management, help desks and related technical support were “customary and necessary in the provision of certain tariffed telecom services.” It said it was concerned that the distinctions between basic and other types of maintenance service and technical support services adopted to determine internal connections’ discount eligibility had “no similar relevance with respect to telecommunications service discount eligibility.” It said because of the similar descriptions of such services as “ineligible” in both the internal connections and special eligibility conditions sections of the list, and in light of the Cost Allocation Guidelines, it was “concerned that application of the draft list to a specific telecommunications services funding request for discounts for appropriate maintenance and technical support services for telecommunications services may erroneously be denied by USAC [Universal Service Administrative Co.].” In separate comments, Fibertech urged the FCC to “immediately” reinstate dark fiber as a service eligible for funding under the E-rate program. The Commission for the first time excluded dark fiber from the list of eligible services in funding year 2004, saying it had “not resolved whether unlit dark fiber [was] a telecommunications service.” But Fibertech argued that to reinstate dark fiber as an eligible service the Commission didn’t need to determine its regulatory classification. It said the agency had authority under Sec. 254 of the Communications Act to include dark fiber in the E-rate program, just as it previously found Internet access and internal connections eligible for the funding. Fibertech said “a new ‘dark fiber’ services category could be created, using the criteria similar to that used when dark fiber was an eligible service in determining whether a specific dark fiber funding request is eligible for funding.” Funds for Learning, an educational technology consulting firm, urged the FCC Wireline Bureau and the USAC to “solicit input from persons who are knowledgeable about technology solutions to make sure that the Eligible Services List correctly reflects the state of technological development, as well as the realities of the K-12 technology market.”