Vendors Seek Changes in New List of E-Rate Eligible Services

Equipment vendors such as Cisco and Citrix Systems said the eligibility rules in general tend to discourage less-costly equipment configurations. Cisco offered the FCC 2 configurations, using the same Cisco equipment, saying one arrangement was fully eligible under the rules but cost at least 70% more than the other configuration, which was only partially eligible. “Certain deployment configurations of hardware are considered eligible, while other -- more cost effective -- configurations, which realize the same goals, are considered ineligible under current program rules,” said Cisco.

Cisco asked the FCC to “adopt a balanced approach to eligibility determinations that takes into consideration the goals of the application and available technologies, and weighs this against the costs of various configurations.” Cisco said such individualized determinations “may add a layer of complexity to the eligibility determination process” but “the savings to E- rate beneficiaries and the provision of funding to additional applicants more than justifies this approach.”

Citrix said the FCC should add a new entry to the eligibility list - network access software -- because such products, which Citrix offers, “can mean major cost savings” over alternatives. “Network Access Software enables transmission of information within a school or library and is often the most cost-effective alternative for doing so,” Citrix said. It’s similar to a “terminal server” that was added in the proposed eligibility list, but the proposed language bars use of a terminal server to provide access to software. Citrix urged that language be eliminated.

Several entities expressed concern about a proposal to require school districts to file separate funding applications for bundled telecom and Internet access services. The State E-rate Coordinators’ Alliance (SECA) said dual filings would be “onerous and administratively burdensome.” Sprint Nextel said “as voice and data capabilities continue to converge, it will be increasingly difficult to distinguish between telecommunications and Internet access services.” Sprint Nextel said it doesn’t object to giving applicants an option of separate filings but requiring them “adds to the complexity of E-rate program rules and could discourage some schools and libraries from participating in the program.”

BellSouth said it supports a proposal to make Virtual Private Networks (VPN) eligible for funding but said eligibility shouldn’t be limited to CPE-based VPN but also open to network-based VPN. “VPN as a security service… should also be eligible to receive discounts if it is provisioned through technologies and protocols embedded in network service solutions,” BellSouth said.

Synovia recommended adding automatic vehicle location (AVL) to the eligibility list because it’s “used to facilitate real-time communication between school bus drivers and schools/transportation offices.” On-time arrivals increase and “in short, students will spend less time on the bus and more time in the classroom.”

The Tex. Office of Public Utility Counsel (OPUC) said electronic library services should be eligible for E-rate discounts, even if they're fee-based, because they meet the definition of “Internet access.” The OPUC also recommended adding filtering to the eligibility list “as long as it is an integrated service that may be provided by an [ISP].” The OPUC said “the availability of dangerous and/or inappropriate Internet sites conflicts with the purposes of education and the legitimate activities of public library facilities.”

SECA also recommended restrictions on eligibility of remote Internet access be eased to allow use of wireless Internet outside schools: “The language contained in the draft Eligible Services List seems to indicate that unless all Internet access and e-mail services are used on school property, they are not eligible unless an auditable record is available to determine what exact services are used each month at each location. We urge the Commission to rethink this decision.” SECA said the FCC also should look at how schools interpret the eligibility of web hosting. Some schools seek funding for web hosting that involves the routine activity of teachers putting their lesson content on a website. “We do not believe this is what the FCC envisioned when they determined that web hosting should be eligible,” SECA said.