ESL PDQ

Check it out! The proposed ESL for 2010-2011 has been posted. And we have 3 whole weeks to comment (plus another week for reply comments). This is great news! Could it mean an final ESL in the summer? Will we actually get 60 days between the release of the ESL and the opening of the filing window, as required by regulation?

I'll be filing fullsome comments later, but here's my shoot-from-the-hip reaction to the proposed changes, based on the Public Notice:

1. List Ethernet under digital transmission: Yup, not a rule change, just improved clarity on the list
2. Text messaging eligible: Good. How would we pull those charges out of cell phone bills?
3. Interconnected VoIP elegible under Telecom Services and Internet Access: Another fine clarification. Now let's get VoIP designated as "Basic Telecommunications" in order to be technology-neutral.
4. Password-protected Web pages eligible: I'll have to read the list to find out exactly what it says, but this whole Web hosting thing gives me a headache.
5. WLAN controllers eligible: These were eligible, so it's good to see them on the list.
6. Interconnected VoIP user licenses eligible under internal connections: Oy. I hope that this is just an error in the Public Notice. How are licenses to use interconnected VoIP, which is a Priority 1 service, an internal connections item? I'm hoping they mean licenses for applicant-owned VoIP phone systems, not interconnected VoIP service.
7. Unbundled warranties eligible: Again, putting something already eligible on the list is always good.
8. Virtualization software eligible: Virtualization is going to be a major headache, because the purpose is to allow several different servers to sit on the same hardware, and to allow servers to be moved between hardware platforms more easily. Server eligibility is already more complex and limiting than most clients want to deal with, and virtualization makes it much worse. Good thing I still remember how to multiply fractions.
9. Broadcast messaging ineligible: I'm OK with that, and happy to see the ineligibility of emergency notification system clearly delineated.
10. Power distribution units ineligible: I don't even know what they mean by this.
11. Video-on-demand (VoD) servers ineligible: Oh, this will be a firestorm. There are some VoD salespeople whose business plan is E-Rate-dependent. This would be a major change, and an unjust one.
12. Softphones ineligible: Not a rule change, just a clarification of a good rule.
13. Interactive white boards ineligible: Did people really need this spelled out? Those white boards are so end-user.
14. E-mail archiving: This is good, because there are some really expensive email solutions that schools would buy if they could get 90% off.

All in all, lots of clarification, not much change. Which I think is just fine.