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Friday, May 31, 2019


SECA (the State E-rate Coordinators’ Alliance) has submitted a list of proposed changes to the Eligible Services List (ESL) to the FCC.  Let's see what they're proposing:

  1. Make content filtering eligible
  2. Make more data security functions (anti-virus, anti-intrustion) eligible
  3. Allow applicants to choose multiple vendors to provide the same service to the same building
  4. Cabling should be eligible, regardless of what's plugged into it
  5. Make break/fix and time/materials maintenance contracts ineligible
  6. Fund multi-year support contracts in the funding year they're paid, not pro-rated across the length of the contract.
  7. Eliminate sub-categories (I think they mean getting rid of the Basic Maintenance category)
  8. Continue MIBS ("Managed Internet Broadband Service"; paying a company to provide equipment, installation, management, repair of an applicant network)
  9. Two suggestions
    • Bring back the Glossary of Terms
    • Include a CIPA (Children's Internet Protection Act) compliance reminder
  10. Allow Wi-Fi on buses (and other off-campus Internet solutions)
To which I say:
  1. I've been saying this since 2007.  It made it into an NPRM in 2008, but withered on the vine.
  2. See #1.  The most important reason: it's increasingly difficult to find firewalls that aren't called "total security appliances" and don't include all this stuff.  Let's not burn applicants who don't have the tech savvy to match manufacturer jargon with USAC jargon to figure out which features are eligible.
  3. Yes!  Buying connections from 2 different vendors is a cost-effective means to increase network availability.  "Redundant" is not a dirty word in IT; it's a virtue.  The GSA (the US gov't organization responsible for purchasing) has made it a requirement of Internet contracts since 2008 (if not earlier).  The GSA requires that even government agency backup sites for disaster recovery have "redundant access to the GSA data network."  Check out page 24 of the GSA's ordering guide for data services: it explains what to do if "[t]he agency wants to use one solicitation to select multiple contractors for the same requirements: such as for a primary and backup, or for network redundancy/diversity."
  4. I was going to get my hackles up a little, but the $150-in-5 Rule makes me just say "fine."  I don't feel good about security cameras and phones being funded if they're riding on their own network (with their own switches, separate from the data network used by students).  But forcing applicants to cost-allocate their cable plant just seems like a huge waste of time since C2 budgets don't allow applicants to get all the eligible equipment they need, especially since most of those devices are just going to be plugged into the same switch as the WAPs.
  5. Huh?  I'd be OK with dumping maintenance entirely, but why single out break/fix contracts?  I've always thought those contracts fit in better with the FCC's position of "we don't want to pay for warranties, just for services delivered."  And they definitely fit better with the E-Rate calendar, which forces applicants to start the year without maintenance funding approved.
  6. Yes.  Just another area where enforcement saves no money, and creates headaches.
  7. Agreed.  The only reason to have a separate Basic Maintenance was the 2-in-5 Rule.  Let's toss that distinction.
  8. Again, with C2 budgets, go ahead and make it eligible.  My only complaint is that I can get E-Rate funding for someone else to manage my network, but I can't get funding for the products I need to manage my network.  Let's make network management software and appliances eligible.
  9. Yes.  Shortening the ESL didn't simplify the rules, it just hid the rules.
    • The Glossary of Terms was important, because when I read the ESL, I hear Inigo Montoya in my head: "You keep using that word. I do not think it means what you think it means."
    • Let's take it a step further and tell applicants whether CIPA requires: 1) applicants to filter devices which are not applicant-owned if they are using the applicant network, and 2) applicants to filter applicant-owned devices if they are not on the applicant network.
  10. I have heard of some great uses of Wi-Fi on buses.  Back when we were hitting the funding cap for the program, I didn't think it was a good use of funding, but we're awash in funding, so I'm OK with it.
So I agree with 9 out of 10.  As usual, SECA delivers wise suggestions.

And they got me thinking.  Several times they mentioned how the 470 drop-down menus should work, and it occurred to me: the ESL should just be an explanation of how to use the drop-downs on the 470 and 471.  Organize the whole thing that way.  It would serve 2 purpose:
  1. It would increase the chances that 470s and 471s were done right, which is kind of the point of the ESL.
  2. It might make the FCC realize how freakin' hard it is to make reality fit into the drop-downs.

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