Ex parte part 1

What's been going on in the ex parte world? What's ex parte, you ask? Well, the FCC sometimes takes  a meeting or gets a letter to an open docket outside a prescribed comment period. When they do, the commenter sends them a summary of the meeting and the FCC publishes it, and puts out a daily list of all the ex parte presentations and post-reply comments. The E-Rate doesn't come up often, but there were a couple of interesting items in yesterday's ex parte list. Here's the first one.

Infoblox wants the E-Rate to cover DNS and DHCP services, and did a nice PowerPoint presentation describing DNS and DHCP and why they should be eligible. 

I agreed with everything they said, except for one omission on the eighth slide, where they give reasons why schools and libraries don't rely on their ISP for DNS and DHCP. In my experience, the main reason schools don't use their ISP's DNS is Web filtering. A lot of schools are using products like ThreatLocker to filter Web content at the DNS level. (By the way, if you aren't using DNS Web filtering at home, check out Cisco's OpenDNS Family Shield; it's free and it's effective.)

And then we got to the last slide, where they got down to brass tacks on eligibility, and I thought, "Nooooo!" First, they said that DNS services should be listed as "Category 1: Network Equipment." Huh? The beauty of third-party DNS services is that you make a simple change on your DHCP server (or DNS server if you have one), no equipment required. Then standalone DNS and DHCP services should be listed as "Category 1: Network Equipment with Mixed Eligibility" and "Category 2: Internal Connections and/or Managed Internal Broadband Services."

What the what? Why "mixed eligibility"? Unless they're acknowledging the can of worms that got DHCP and DNS kicked out in the first place. See, most of the time, DNS and DHCP are running on servers that also serve other purposes (because DNS and DHCP are not very demanding on a server). So allowing them is the camel's nose under the tent for making servers eligible again. It would allow applicants to put DNS or DHCP on a server that had some other (ineligible) function, and poof! it's 50% eligible, even though it's spending 5% of it's time answering DNS queries. And it would be easy to make a case for a DNS server in each building to decrease latency, so now you're getting 50% off a bunch of servers.

My bottom line: I'm OK with allowing DNS and DHCP services in Category 1, but not for equipment, unless the service provider is dropping an appliance that they manage onto your network. I don't like it for Category 2, because it's easy to abuse, but you know what? C2 budgets are so ridiculously small that it's fine to let applicants make a bunch of servers 50% eligible, because it just means they're going to run out of C2 funds for switches and APs faster. I just dread getting back into server cost allocations.

One last tangent: How did Infoblox shoehorn in comments about something that should be eligible? The FCC hasn't asked about that in ages. They made a comment on an NPRM clarifying the Wi-Fi Hotspot Report and Order. Gotta love that creativity.