Eligible?

 With all the brouhaha about the NPRMaFNPRM, will anyone notice that the draft Eligible Services List is out? We don't have much time to comment ("file comments on or before July 30, 2026, and reply comments on or before August 14, 2026."), and most of us will be focusing our attention on the NPRMaFNPRM.

The draft ESL is usually a snorefest, anyway, so perhaps it's OK that the comment period falls in the midst of our existential crisis.

This year, the FCC really is asking for comments on two items:

1. MIBS. Nothing new here; they were asking questions about MIBS last year, too. And they targeted it in the NPRMaFNPRM (paragraph 84). I think maybe it's the end of MIBS as we know it. I'm not betting on total MIBSageddon, but they'll put such restrictions on it that the few applicants that were using it will be unable to shoehorn their service into the new definition of MIBS. But perhaps a service provider will contort their offering to fit the new definition.
2.  Network-as-a-service (NaaS). Basically, a WAN where the circuits are dynamic, increasing and decreasing bandwidth to meet demand, with a concomitant increase or decrease in the cost. I don't see a great way to apply for this in E-Rate. You'd have to guess at the max bandwidth you'll need, and use the cost of that for the year, which would certainly mean actually spending less than you applied for. Not a problem unless everyone does it, then the annual Demand Estimate will be inflated. I don't see the "heavy administrative burdens" that the FCC says come with NaaS, and it would probably lower disbursements from the program (though probably increase commitments). Let some applicants try it and see how it goes.

Can we take fractional T-1s and Switched Multimegabit Data Service off the list? Has any applicant out there used either of those in the last 25 years? And telephone dial-up? Can you imagine trying to connect a school or library at 0.000056 Gbps? (You can check me on the number of zeros there; my brain seized up.) And that's assuming you could still get an analog phone line; the phone companies are all trying to get rid of their analog copper in favor of digital connections with voice riding over IP.

They've integrated the new definition of C2 to include connections between buildings on one campus from the recent Report and Order and Order on Reconsideration. Good, more clarity is better.

Is anybody paying for caching equipment? Every now and then I see someone offering a caching solution, but it usually turns out to be caching in the cloud, not in the closet. Still, no harm in leaving it on there, and maybe one day it will make sense to put a caching device in your rack. (If it makes sense anywhere, it will be at a school: "All right, everyone go to....") But it will probably be part of your firewall, further tangling the eligibility of the firewall.

 Is it just me, or does the ineligibility of "unbundled warranties" feel like rubble left over from a fight long ago? It seems to me that the FCC just moved unbundled warranties into IC where they're treated like licenses. Or does the FCC think "warranty" only means "hardware replacement"? At least some clarification is in order.

Is anyone getting "support for data plans or air cards for mobile devices"? Hard to see how that's going to be cost-effective when cellular hotspots can serve multiple devices for the same cost.

Wait a minute. Under the preamble to Category Two (p. 7), it says: "broadband connections used for educational purposes within, between, or among instructional buildings that comprise a school campus" is C2. That agrees with the recent reconsideration order. But under "Connections between buildings of a single school" (p. 9). it says: "Connections between different schools with campuses located on the same property (e.g., an elementary school and middle school located on the same property) are considered to be
Category One data transmission services, unless they share the same building." The reconsideration order changed the §54.500 definition of Internal Connections to: "A service is eligible for support as a component of an institution’s 'internal connections' if such service is necessary to transport or distribute broadband within one or more instructional buildings of a single school campus or within one or more non-administrative buildings that comprise a single library branch. Multiple schools with the same billed entity may share a single school campus." Doesn't that mean connections between schools on a single campus is Internal Connections?

 As usual, more questions than answers.