First, let me say that the new Web hosting rules, listed in the April 10 News Brief are better than the old rules. And USAC is being more open about what's eligible and what's not, with a narrative and examples in the April 24 News Brief.
But the rules are still weak. Let's go rule by rule:
Eligible features and services include:
Provision of website traffic (bandwidth)
OK, this is pretty clear.
Provision of disk space for storing applicant-provided content
So if the applicant provides content to be stored in a database, is that eligible? I don't see how you write this rule to be specific enough, yet flexible enough.
Provision of FTP transfer capacity so that files can be maintained
So applicants can't use WebDAV or FrontPage Server Extensions? I think what this rule is trying to say is that Web hosting cannot include interactive page editing, only the upload of content. Why? And where can you find that? Even a $24/year Web hosting account has some kind of online page editing feature. If a service is ancillary on all commercially available products, why make us prove ancillary over and over?
Ineligible features and services include:
Webpage design/creation
This rule is reasonable clear, and is paying someone to create Web pages should be ineligible.
Access to software applications (e.g., blogs, homework, chat, student information systems, content management systems)
This is the rule that kills me. First of all, it renders all Web hosting ineligible. The Web hosting world breaks down into two camps: Microsoft IIS and Apache (sorry Mac people, but I have never seen a commercial Web host offer OS X hosting). All IIS Web sites are "applications." And while it is technically possible to build an Apache Web server that only hosts static Web pages, no one builds a server that way. This rule is made for the Web 1.0 world, and we live in a Web 2.0 world.
And some of the the e's that are g'n don't make sense to me. Why are blogs ineligible? Does that mean that if a teacher wants to write a paragraph a day about happenings in the classroom, that's ineligible? And why is "homework" ineligible? If a teacher maintains a page that shows the homework assignments for the week, that's ineligible? Making chat ineligible makes a little more sense to me, but when you get right down to it, if a district decides that chat is the most effective way to provide information to parents, why make it ineligible? "Student information systems" come up over and over; OK, we got it, they're ineligible. And "content management systems" (CMS) should be ineligible, but when the rest of the world says CMS, they are talking about software to sift through existing documents and getting the information in them up on the Web, not systems that assist people in writing Web pages.
My local library offers me access to periodical databases, etc. Does that make the whole site ineligible? Not that it matters: the E-Rate process is too onerous for the vast majority of libraries.
Access to storage features such as "virtual hard drives"
Why does this rule start with "Access to"? What should be ineligible is the storage, not the links to the storage. Otherwise, this rule's OK.
Access to content creation/editing features including templates
Again, delete the "Access to." And again, this makes every Web host ineligible; you can't find a Web host that doesn't offer templates and online page editing. Even worse, this rule hamstrings Web sites: we should encourage schools and libraries to have Web sites where staff can easily post information.
This web is still too tangled. It's clear that trying to pin down which Web hosting services are eligible is not working satisfactorily. I'm not sure it could ever work satisfactorily, even if they put me in charge.
Don't worry, I have a solution:
Give schools an annual Web hosting budget of $2,000 plus $0.50 per student (pre-discount). Give libraries $2,000 plus $0.03 per person in the town they serve. And make clear that the purpose of the Web site has to be to provide information to the public.
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