FY2015 ESL News

Eligible Services List for FY 2015:
On 8/5/14, the FCC Commissioners published the DRAFT of the ESL (Eligible Services List) with a six-page cover letter describing the list’s contents and requesting comments from the public (available from the FCC ’s website). The ESL is radically different from prior years – for starters, the list itself is six pages vs. last year’s 49 page document. And it is truly a list, or series of lists, with most of the supporting sections and descriptive verbiage stripped away. So the good news is that the Modernized ESL is simpler, but this could be the bad news as well.

Here’s what it contains:
• A few paragraphs describing the new Category One and Two system.
• For Category One (two pages):
    o A general description of what Category One contains.
    o A half-page list of “Eligible data transmission services and Internet access
    o A short list of “Eligible voice services
    o A half-page of descriptions of limitations on Fiber, Internet Access, and Wireless Services
• For Category Two (a bit more than two pages):
    o A general description of what Category Two contains.
    o A list of “Eligible Broadband Internal Connections Components
    o A paragraph describing the limitations on broadband internal connections.
    o A half-page description of “Eligible Managed Internal Broadband Services” and their limitations.
    o A short description of “Basic Maintenance of Eligible Broadband Internal Connections Components” and its limitations.
• A page of descriptions of two Miscellaneous items: “Fees” and “Installation, activation, and initial configuration”.

That’s it:
• no list of ineligible services (if it ain’t listed it’s ineligible; they say that describing the complexities of ineligible services is too confusing so they won’t do it),
• no description of related program requirements (but no explanation of where to find this information),
• no extra information regarding components of complex services such as digital transmission service, distance learning, video, interactive television, and voice or video conferencing (seemingly because they are too complex for the ESL, but no alternative information source is mentioned),
• no description of “Special Eligibility Conditions” (because they are already contained somewhere in the FCC;s rules, orders, etc.),
• no glossary of the various services and terms. This will be moved to the SLD website as a reference tool (good!) which is unfortunately described as “just for informal guidance” (not very encouraging).

Regretfully, it seems that little has been done to eliminate the complexity of the eligible services, and the FCC has opted to duck the issues as much as it has actually simplified them. We will do our best to fill in the missing information, either on this section of our website or by personally answering your questions. We will look into the details of the ESL as well as other aspects of the Modernization.

Cellular Service (Voice and Data), Aircards, Mobile Hotspots:
These services are of particular concern to us all:
Cellular voice is on the list of services to be phased out by reducing the discount 20% per year.
Text messaging is ineligible as of FY 2015.
Cellular data plans, air cards, and mobile hotspots are ineligible as of FY 2015 UNLESS they are:
    o Used on-campus (off-campus use, even if used for an educational purpose, is ineligible for support). Nothing new – this has been the rule for a while now.
    o Cost effective versus a wireless local area network (WLAN) within the school. Since this is rarely the case, expect a tough Cost Effectiveness Review if you request any of these services.
    o If you do not have a WLAN, you may have to consider installing one versus using a wireless data plan. CATCH 22: If your district/school/library does not have at least an 80% discount, you may not get funding for a new WLAN in FYs 2015 or 2016 – and then maybe not at all.

Existing multi-year plans
• May be stripped of much of their funding as of FY 2015 by having data and text services removed from E-rate funding and having funding for the remaining voice services reduced year-by-year.
• Wireless data plans will not be Grandfathered – their funding will be denied as of FY 2015 unless they meet the on-campus and cost-effectiveness criteria.

You may need to review your cell, smartphone, and air card policies and schedule a conversation with your service provider soon NOW.