Federal Communications Commission DA 11-1600
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Schools and Libraries Universal Service ) CC Docket No. 02-6
Support Mechanism )
ORDER
Adopted: September 28, 2011 Released: September 28, 2011
By the Chief, Wireline Competition Bureau:
I. ThTRODUCTION
1. In this order, we release the eligible services list (ESL) for funding year 2012 for the schools
and libraries universal service program (B-rate).' The ESL identifies the services and products that are
eligible for E-rate funding. In the ESL Public Notice, we proposed minor changes and other edits to the
ESL to provide clarifications or additional information only, and did not change the eligibility status of
any services in the B-rate program.2 By this order, we adopt most of the clarifications we proposed in the
ESL Public Notice, with some minor modifications as described herein.
II. BACKGROUND
2. Through the B-rate program, eligible schools and libraries may receive discounts for eligible
services, including telecommunications services, telecommunications, Internet access, internal
connections, and basic maintenance of internal connections (BMIC).3 Section 254 gives the Commission
authority to designate "telecommunications services" and additional services eligible for support through
the B-rate program.4 The Commission also has authority to designate services eligible for B-rate support
as part of its authority to enhance, to the extent technically feasible and economically reasonable, access
to advanced telecommunications and information services for all public and non-profit elementary and
secondary school classrooms and libraries.5
3. The Commission releases the ESL each year so that applicants may have notice of the services
and products eligible for B-rate funding prior to applying for E-rate discounts. Pursuant to section 54.502
'See Eligible Services List For Funding Year 2012 (rel. Sept. 28, 2011) (2012 ESL).
2 Wireline Competition Bureau Seeks Comment on Draft Eligible Services List for Schools and Libraries Universal
Service Pro grain, CC Docket No. 02-6, Public Notice, 26 FCC Red 8714, 8714-8718 (Wireline Comp. Bur. 2011)
(ESL Public Notice).
47 C.F.R. § 54.502(a).
47 U.S.C. § 254(c)(1), (c)(3), (h)(2)(A). Congress charged the Commission with establishing competitively
neutral rules to enhance access to advanced teleconiinunications and information services for all public and
nonprofit elementary and secondary school classrooms and libraries; and also provided the Commission with the
authority to designate "special" or "additional" services eligible for universal service support for schools and
libraries. 47 U.S.C. § 254 (c)(3), (h)(2).
See Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Report and Order, 12 FCC Red 8776,
9008-9015, paras. 436-449 (1997).
Federal Communications Commission DA 11-1600
of the Commission's rules, USAC must submit a proposed ESL for the upcoming funding year by March
30 of each year, and the Wireline Competition Bureau (WCB) is required to seek public comment on the
proposed ESL.6 After the public has had an opportunity to comment, the final ESL for the upcoming
funding year must be released at least 60 days prior to the opening of the E-rate application filing
window.7 Last year, the Commission removed the requirement in the rules that the final ESL be released
by public notice.8
4. In the ESL Public Notice, we proposed updates to the ESL in accordance with recent
Commission and WCB orders, including the 2009 ESL Order, the Sixth Report and Order, the Sixth
Report and Order Guidance Public Notice, the 2010 Basic Maintenance ClarfIcation Order, and the
Chicago Public Schools Order.9 We also proposed miscellaneous changes to streamline the ESL and
provide additional guidance to applicants, including a clarification that mobile-hotspot service is a type of
eligible Internet access service.'0 WCB sought comment on the ESL Public Notice on June 24, 2011.11
The comment cycle closed on July 25, 2011.12
III. DISCUSSION
5. In this order, we release the ESL for funding year 2012 and adopt most of the proposals made
in the 2011 ESL Public Notice. By this order, we also authorize USAC to open the annual application
filing window no earlier than November 28, 2011 •13 We address herein the changes we adopt today.
A. ESL Updates and Clarifications Based on Recent WCB and Commission Decisions
1. ESL Introduction
6. We first update the ESL introduction to clarify that the services funded under the "Learning-
on-the-Go" wireless pilot program are services used for an "educational purpose."4 The Commission's
current rules presume that services used on school or library premises are serving an educational purpose,
6 See 47 C.F.R. 54.502(b)(1).
71d.
8 See 47 C.F.R. § 54.502(b)(l); Sixth Report and Order, 25 FCC Rcd at 18811 and 18813, Appendix A, Final Rules.
Schools and Libraries Universal Service Support Mechanism, CC Docket No. 02-6, Report and Order and Further
Notice of Proposed Rulemaking, 25 FCC Rcd 6562 (2009)(2009 ESL Order); Schools and Libraries Universal
Service Support Mechanism, A National Broadband Plan for Our Future, CC Docket No. 02-6, GN Docket No. 09-
51, Sixth Report and Order, 25 FCC Rcd 18762 (2010) (Sixth Report and Order); Wireline Competition Bureau
Provides Guidance Following Schools and Libraries Universal Service Support Pro grain Sixth Report and Order,
CC Docket No. 02-6, GN Docket No. 09-51, Public Notice, 25 FCC Rcd 17332 (Wireline Comp. Bur. 2010) (Sixth
Report and Order Guidance Public Notice) (providing effective dates for adopted proposals and answers to a list of
frequently asked questions (FAQs) regarding rules adopted in the Sixth Report and Order); Schools and Libraries
Universal Service Support Mechanism, A National Broadband Plan for Our Future, CC Docket No. 02-6, GN
Docket No. 09-51, Order, 25 FCC Rcd 17324 (Wireline Comp. Bur. 2010) (clarifying the funding procedures for
basic maintenance of internal connections (BMIC) contracts and gifts rules) (2010 Basic Maintenance Clar(Jication
Order); Requests for Review ofDecisions of the Universal Service Administrator by Chicago Public Schools, SLD-
288954 etal, Docket No. 02-6, Order, 26 FCC Rcd 4114 (2011) (Chicago Public Schools Order).
10 See ESL Public Notice.
' Id.
'21d.
13 C.F.R. § 54.502(b).
'4Sixth Report and Order, 25 FCC Rcd at 18785-18787; F-rate Deployed Ubiquitously 2011 Wireless Pilot
Program, WC Docket No. 10-222, Order, 26 FCC Rcd 9526 (Wireline Con1p. Bur. 2011) (Learning-on-the-Go
Order).
2
Federal Communications Commission DA 11-1600
and therefore services used off school or library premises are generally presumed not to be serving an
educational purpose.15 As such, funding for portions of those services that are utilized off-campus must
generally be cost-allocated.'6 The applicants participating in the Learning-on-the-Go wireless pilot
program, however, were selected to receive E-rate funding for Internet access services for portable
devices, even the portion of such services that will be delivered off-campus.'7 Consistent with our
conclusions in the Learning-on-the-Go order, we clarify in the ESL that the services funded under the
Learning-on-the-Go wireless pilot program satisfy the educational purpose requirement despite the fact
that they may be used off-campus.'8 Accordingly, funding for such services utilized off-campus need not
be cost-allocated.
2. Telecommunications Services
7. We remove from the ESL the explanation for including interconnected voice over Internet
protocol (interconnected VoIP) in the Telecommunications Services category. We make this change
because the Commission affirmatively added interconnected VoIP to the ESL in the 2009 ESL Order and
therefore the explanation is no longer necessary.'9
8. We revise the entry in the ESL for "Other Miscellaneous Components that are Not Eligible" to
clarify that services such as T-l lines no longer need a technology plan.2° In the Sixth Report and Order,
the Commission removed the technology-plan requirement for all priority one services.21 The original
sentence in the ESL, however, mistakenly implied that a technology plan was in fact required for
recipients to obtain T-1 services.22 Contrary to our proposal in the ESL Public Notice, however, we
decline to include dark fiber as an additional example of services that no longer require technology plans
in the ESL; we find that the current language in the ESL is sufficiently clear on this point.
3. Telecommunications
9. We update the entry for dark and lit fiber service in the Telecommunications category. After
the Commission released the Sixth Report and Order last year, the WCB released a public notice to
address frequently asked questions (FAQ) to further clarify the Commission's decisions regarding fiber
and dark fiber, among other things.23 Specifically, the FAQ explains the eligibility of dark fiber special
construction charges and costs associated with modulating electronics.24 We make minor updates in the
15 Schools and Libraries Universal Service Support Mechanism, CC Docket No. 02-6, Second Report and Order and
Further Notice of Proposed Rulemaking, 18 FCC Rcd 9202, 9208, para. 17-18 (2003).
'61d
17 Learning-on-the-Go Order, 26 FCC Rcd at 9528-9529.
18 Id.
' See 2009 ESL Order, 25 FCC Rcd at 65 67-6570. For the same reason, we also removed this explanation from the
Internet Access category of the ESL.
20 This is in the Miscellaneous category of the ESL.
21 Sixth Report and Order, 25 FCC Rcd at 18789-18791.
22 j stated that "[s]ervices that provide necessary bandwidth requirements consistent with an applicant's Technology
Plan, such as multiple T-1 lines when appropriate for the population served and the services to be received, are not
duplicative." See Eligible Services List, Schools and Libraries Support Mechanism for Funding Year 2011, dated
Sept. 23, 2010 at 23 (see USAC webpage
p://www.usac.org/res/docurnents/sl/pdf'ESL archive/EligibleServicesListi 109 10.pdf, last visited Sept. 21,
2011) (2011 ESL).
23 Sixth Report and Order Guidance Public Notice, 25 FCC Rcd at 17334-17337.
24 Id.
Federal Communications Commission DA 11-1600
ESL to the entry for fiber and dark fiber in the Telecommunications category to be consistent with the
information provided in the Sixth Report and Order and the subsequent FAQ.25
4. Internet Access
10. We clarify the introduction to the Internet Access category to include the Commission's
definition of "Internet access" from section 54.5 of the Commission's rules.26 This is consistent with the
Sixth Report and Order, in which the Commission included in section 54.502(a)(3) the definition for
"Internet access" contained in section 54527 We also delete the words "Internet-based" before the word
"e-mail" in the ESL entry for e-mail because section 54.5 states that e-mail is an element of Internet
access, and does not use the term "Internet-based e-mail."28
11. We next adopt some of the changes proposed in the ESL Public Notice to clarify the eligibility
of web hosting. These proposed changes to the ESL were intended to provide additional consistency with
the Sixth Report and Order but, based on our review of the record, we do not make all of the clarifications
initially proposed.29 The revisions we adopt eliminate outdated terminology while maintaining the
provisions that allow applicants to seek funding for the ability to post their website to the Internet.
12. We provide further clarifications from the Sixth Report and Order regarding features that
facilitate the ability to communicate, (such as blogging, e-mailing over a school or library's hosted
website, discussion boards), and services that may facilitate real-time interactive communication (such as
instant messaging or chat).3° Among other revisions, we remove the phrase "content editing" from the
ESL section explaining the ineligible features of a web hosting service. This clarification addresses
questions in the record on whether the term "content editing" applied to teachers or students using the
interactive features of a school's web page such as blog or discussion board.3' Collectively, the
25 But see CenturyLink Comments at 2-3. The Sixth Report and Order has also directed applicants to select either
the telecommunications service or Internet access box on the FCC Form 471 for type of service requested when
applying for funding for leased dark or lit fiber, based on the type of provider they select to provide the leased dark
fiber service. Sixth Report and Order, 25 FCC Red at 18767. Therefore, in the introduction to the Miscellaneous
category of the ESL, we clarified that "Miscellaneous" services and products related to services requested in the
Telecommunications category should be requested (via FCC Form 471) in the Telecommunications Services or
Internet Access category, depending upon the nature of the service provider.
26 C.F.R. § 54.5 (stating that "Internet access" includes the following elements: (1) The transmission of
information as common carriage; (2) The transmission of information as part of a gateway to an information service,
when that transmission does not involve the generation or alteration of the content of information, but may include
data transmission, address translation, protocol conversion, billing management, introductory information content,
and navigational systems that enable users to access information services, and that do not affect the presentation of
such information to users; and (3) Electronics mail services (e-mail).); 47 C.F.R. § 54.502(a)(3). In the Sixth Report
and Order, the Commission consolidated all of the rules pertaining to eligible services into section 54.502. Sixth
Report and Order, 25 FCC Red at 18810, n. 325 and 18814.
27 C.F.R. § 54.502(a)(3) and 54.5; see also Federal-State Joint Board on Universal Service, CC Docket No. 96-
45, Report and Order, 12 FCC Red 8776, 9013, para. 444 (1997), aff'd in part, Texas Office of Public Utility
Counsel v. FCC, 183 F.3d 393 (5th Cir. 1999) (subsequent history omitted).
28 "Internet-based e-mail" is not defined elsewhere in the ESL. Because e-mail is listed as a component of "Internet
access" in the Commission's rules, we decline to include it in the "Internet-Related Services" section. See Edline
Conunents at 3-5 and Attachment 1.
29 See, e.g., Letter from Jennifer L. Richter, Counsel to Edline, to Marlene Dortch, Federal Communications
Conimission, dated Sept. 19, 2011.
30 Sixth Report and Order, 25 FCC Red at 18 806-18807.
' See Edline Comments at 4-7 (questioning whether the fact that content editing features are ineligible meant that
blogging and some of the other real-time interactive communication aspects of web hosting would be ineligible).
4
Federal Communications Commission DA 11-1600
clarifications to this section provide that a web hosting service that provides for the display of a school's
or library's website on the Internet and the portions of a web hosting package that provide for interactive
communication, such as blogging, web-based email, and discussion boards, as explained in the Sixth
Report and Order, remain eligible.
13. We reiterate that, consistent with the Commission's decision in the Sixth Report and Order to
continue to fund web hosting services under E-rate, any clarifications to the ESL do not change the
eligibility of particular services or features.32 Ineligible services continue to include any content-based
services from any provider, web-site design or web-creation services, end user file storage, databases for
grades, student attendance files, or other reports, and the applications necessary to run online classes or
collaborative meetings.
14. Finally, we clarify that firewall services may not be provided by a vendor other than the
Internet access provider and may not be priced separately.33 The Sixth Report and Order stated that E -
rate discounts are available for basic firewall protection, but such discounts would not be extended to
support firewall protection beyond that which is included as part of an Internet access service.34 We also
clarify that firewall components remain eligible in the Internal Connections category in the "Data
Protection" and "Servers" entries. Changes made to the ESL last year inadvertently suggested that these
components were no longer eligible.35 The Sixth Report and Order did not change the eligibility for
firewall components that had been funded as part of Internal Connections.36
5. Internal Connections
15. We clarify that the restrictions on remote access to homes or other non-school or non-library
sites do not apply to residential schools that serve unique populations.37 Under the entry for "Servers,"
previous versions of the ESL stated that remote access cannot be provided to homes or other non-school
or non-library sites.38 In the Sixth Report and Order, however, the Commission decided to support
eligible services to the residential portion of schools that serve students with special circumstances.39
Thus, we clarify in the ESL that remote access components for eligible school-based dorms and
residences would be eligible for E-rate funding.
6. Basic Maintenance of Internal Connections
16. We revise the introduction to the BMIC category to allow cost-allocation for the ineligible
portion of a BMIC contract.40 In the past, if applicants sought support for a technical service contract that
32 Sixth Report and Order, 25 FCC Rcd at 18806. Our intention was to provide more specific language to clarify
what will continue to be eligible or ineligible.
u Sixth Report and Order, 25 FCC Rcd at 18808-18809. The mention of firewall service not being priced out
separately had been listed in the entry for ineligible Internet Access services but we find that it is more appropriate
to mention this as part the explanation of eligible firewall services.
341d.
See 2011 ESL at 12 and 14.
36 Sixth Report and Order, 25 FCC Rcd at 18808-18809.
ESL Public Notice, 26 FCC Rcd at 8717.
38See, e.g., 2011 ESL at 14. The 2011 ESL defined remote access components (such as a remote access router or
communications server) as a component that allows users to access network resources by dialing in from an off-site
location in order to connect their local computer with network devices. It stated that dialing in most cases typically
utilizes standard telephone lines but, in some cases, may be based on other technologies.
Sixth Report and Order, 25 FCC Rcd at 18778-18779.
40 . .See ESL Public Notice, 26 FCC Rcd at 8717. Funds for Learning, LLC supports these changes. Funds for
Leaming, LLC Comments at 2.
Federal Communications Commission DA 11-1600
included services that went beyond BMIC, the entire contract was ineligible.41 The Commission,
however, determined in the Chicago Public Schools Order released March 2011, that technical support
contracts may be cost-allocated.42 We therefore clarify the introduction to the BMIC section in the ESL
by stating that "[f]unding will be provided for the eligible portion of a technical support contract that
includes services that exceed BMIC, if the ineligible portion of the contract can be cost-allocated."
Consistent with the Chicago Public Schools Order, however, technical support contracts that cannot be
cost-allocated to remove costs that are beyond BMIC are ineligible in their entirety.43
17. We also clarify that on-site BMIC requests may be eligible for B-rate support if applicants can
present sufficient evidence demonstrating that on-site technical service is more cost-effective than off-site
technical support for that specific situation.44 This change is also prompted by the Chicago Public
Schools Order and clarifies the previous presumption that on-site BMIC is not necessary to the operation
of the internal network when off-site technical support can provide technical support on an as-needed
basis.45
18. Finally, we revise the "Maintenance and Technical Support of Internal Connections" entry for
the BMIC category to confonn to the requirement that BMIC reimbursements be paid only for work that
is actually performed under the contract.46 Specifically, to conform to the WCB 's 2010 Basic
Maintenance Clarification Order, the ESL states that "[r]eimbursements for BMIC will be paid for the
actual work performed as verified by invoice."47 In addition, although not proposed in the ESL Public
Notice, we add to the BSL examples of specific types of BMIC for which applicants may be reimbursed
but for which applicants will not be required to demonstrate that work was actually performed. These
include: (1) software upgrades and patches, including bug fixes and security patches; (2) online and
telephone-based technical assistance and tools that are typically standard fixed priced offerings (not
including ineligible help-desks) 48
41 See, e.g., 2011 ESL at 20.
42 Requests for Review of Decisions of the Universal Service Administrator by Chicago Public Schools, SLD-288954
et al, Docket No. 02-6, Order, 26 FCC Rcd 4114, 4118-4119 (2011) (Chicago Public Schools Order).
' This is required by the Chicago Public Schools Order because the Commission stated that USAC should deny
funding for an entire BMIC contract if applicants are unable to separate the eligible and ineligible services in a
BMIC contract. Chicago Public Schools Order, 26 FCC Rcd at 4118-4119. But see Cisco Systems, Inc. Comments
at 4-7.
44ESL Public Notice, 26 FCC Rcd at 8717.
n Chicago Public Schools Order, 26 FCC Rcd at 4121.
46 See Sixth Report and Order, 25 FCC Rcd at 18809; 2010 Basic Maintenance Clarification Order, 25 FCC Rcd
17325. See Cisco Systems, Inc. Comments at 2-3 (highlighting that the proposed ESL did not include the language
"or hours of labor actually used").
' 2010 Basic Maintenance Clar(uIcation Order, 25 FCC Rcd 17325-17326. Consistent this change, we also
clarified the entry for "Miscellaneous Fees and Charges" in the Miscellaneous category that contingency fees will be
reimbursed based on actual work performed. We made this change so that the policy regarding reimbursements for
upfront charges for contingency fees would be consistent with the Commission's recent decisions regarding upfront
charges for BMIC.
48 Id. at 17326. The WCB indicated that it made this distinction for these types of fixed-priced offerings as a matter
of "administrative convenience" because in many cases the costs and frequency of these types of services can be
difficult to quantify. Id. Although Cisco offers that the WCB "implicitly recognized [that] the modification reflects
current industry practice to have all enterprise customers share the cost of software upgrades and bug fixes, as well
as technical support (on line and live), [because] those costs are not incurred on behalf of a single customer,"
"administrative convenience" was WCB 's stated explicit reason for this decision. Cisco Conirnents at 9.
6
Federal Communications Commission DA 11-1600
B. Miscellaneous Clarifications
19. We adopt other miscellaneous changes proposed in the ESL Public Notice as described herein.
We update the ESL introduction to provide information about the fact that E-rate funds are allocated in
accordance with rules of priority and provide the definition of priority one and priority two services.49.
We also update the ESL introduction to remind applicants that any service that meets the definition of
"telecommunications service" is eligible for E-rate funding but that, for other services, funding is limited
only to those products and services specifically listed in the ESL.5° These explanations are not new but
were omitted from recent versions of the ESL. Finally, we provide definitions in the glossary section for
certain terms that are used in the ESL, such as "failover" and "enhanced multimedia interface."5'
20. In addition, we change the name of the "Other Eligible Internet Access Services" entry to
"Internet-Related Services" because the services listed in this entry do not, on their own, provide basic
conduit access to the Internet.52 We also clarify that satellite service is one of the access teclmologies that
applicants could use to receive eligible Internet access. Finally, we clarify the descriptions for certain
examples of ineligible software. For example, instead of stating that softphones and reading programs are
ineligible, we use the more generic terms "curriculum and productivity software" to capture software we
previously deemed ineligible as well as the broader range of software products that are not eligible.53
21. We also clarify that mobile hotspot service designed for portable devices is a type of eligible
wireless Internet access service that may be funded by E-rate.54 We find that mobile-hotspot service is
eligible because it is a type of eligible wireless Internet access that provides basic conduit access to the
Internet.55 Although we clarify in the ESL that mobile-hotspot service is an eligible wireless Internet
access service, we remind applicants that the end-user devices associated with providing and using
wireless Internet access service are not eligible for B-rate funding.56 Recognizing the recent proliferation
of new mobile devices, we also add smart phones and tablets to the ESL as examples of end-user
equipment that are not eligible for B-rate discounts •r
" See 47 C.F.R. § 54.507(g).
50 Not every service listed on a telephone bill is a telecommunications service. For example, directory listings, 1-
900 number services and related content, and directory advertising (Yellow Pages) are ineligible. See 2012 ESL at
6. Applicants or services providers should not seek reimbursement for these services from USAC.
' See 2012 .ESL at 35-36.
52 Web hosting is one of the services listed in the entry for Internet-Related Services. While we recognize Edline's
concem about e-mail not being included in the same entry as web hosting, we noted above that the Commission's
definition of "Intemet access" explicitly includes e-mail. See Edline Comments at 9. One of the reasons we
separate e-mail from some of the other services funded under the Internet access category of the ESL is this
definition. See 47 C.F.R. § 54.5. See supra para. 10.
53See 2012 ESL at 19.
" ESL Public Notice, 26 FCC Rcd at 8716. In the glossary to the ESL, mobile-hotspot service is defined as a
service that allows certain mobile devices to share their high-speed mobile broadband with other users wirelessly.
Examples of mobile hotspots include the MiFi family of devices and their competitors, and a number of wireless-
enabled smartphones. See, e.g., Brian Nadel, Mobile hotspots: AT&T, Sprint and Verizon compete on price,
features, speed; Which carrier's mobile hotspot packs the most punch?, Computerworid, Jun. 17, 2011, available at
http://www.computerworld.com/s/article/92175 82/Mobile hotspots AT T Sprint and Verizon compete on price
_features speed (last visited Aug. 9, 2011). There were no comments filed in response to this proposal.
55See2OI2ESLat9.
56 See, e.g., Sixth Report and Order, 25 FCC Rcd at 18805 (stating that the E-rate program does not provide support
for content or end-user devices such as computers or telephones).
2012 ESL at 20.
Federal Communications Commission DA 11-1600
22. Finally, we adopt changes to streamline the ESL. Where possible, we moved language into
more appropriate or relevant sections and attempted to eliminate any redundancies. We also deleted,
where practical, references to ineligible products in sections discussing eligible services.58 The following
are examples of some of the other streamlining changes we adopt in this order: (1) deleting the entry for
"Other Eligible Telecommunications Services" and moving that information to appropriate sections of the
Telecommunications Services category;59 (2) deleting the entry for "Distance Learning and Video
Conferencing" from the Internet Access category and moving those descriptions to the entry for "Internet
Access;"6° and (3) consolidating all of the special eligibility conditions pertaining to wide area
networks 61
C. Designating New Services Requested in the Comments
23. Although several commenters requested that we add services to the ESL, we decline to add
new services to the ESL at this time.62 This is consistent with our statement in the ESL Public Notice
emphasizing that this proceeding was not intended to be a vehicle for changing any eligibility rules.63
IV. ORDERiNG CLAUSES
24. ACCORDINGLY, IT IS ORDERED, that pursuant to the authority contained in sections 1
through 4, 254, 303(r), and 403 of the Communications Act of 1934, as amended, 47 U.S.C. § 151-154,
254, 303(r), and 403, this order IS ADOPTED.
FEDERAL COMMUNICATIONS COMMISSION
Sharon E. Gillett
Chief
Wireline Competition Bureau
58 For example, we moved the statement regarding the ineligibility of certain kinds of antennas to the entry for
Internal Connections components that are not eligible. 2012 ESL at 19. We did the same for "client access
licenses." Id.
2012 ESL at 4-6.
601d. at9.
611d at28.
62 Several commenters requested that new services be added to the ESL including (1) intrusion detection and
prevention systems (IDS/IPS), Funds for Learning LLC Comments at 5-6; (2) on-line collaboration, web meetings
and distance learning applications, AT&T Reply Comments at 4; (3) labor costs for two hours of after school
personnel and end-user training and professional development for teachers and staff National Hispanic Media
Coalition Comments at 2-5 (stating that funding for the labor costs would address the gap in many low-income
districts where opportunities to use the equipment and services is restricted by a lack of computers and limited time
in the computer lab which is especially difficult for the students who lack home Internet access); (4) all operating
telecommunications surcharges and fees (e.g., administrative fees), SECA Comments at 2-5; and (5) a special
appliance as part of firewall architecture solution, George Riesco Comments (stating that the Riverbed device can
host up to five services to help schools and libraries reduce the size of the broadband link they need to purchase).
63 See ESL Public Notice, 26 FCC Rcd at 8718.
Federal Communications Commission DA 11-1600
APPENDIX A
List of Commenters
Comments and Reply Comments in Response to the
E-rate Draft Eligible Services List for Funding Year 2011
CC Docket No. 02-6
Commenters
1. CenturyLink
2. Cisco Systems, Inc.
3. Edline
4. Funds for Learning, LLC
5. National Hispanic Media Coalition
6. George Riesco
7. State E-rate Coordinators' Alliance
Reply Commenters
1. AT&T Services, Inc.
2. Edline
3. Funds for Learning, LLC
9
Federal Communications Commission DA 11-1600
APPENDIX B
Eligible Services List for Funding Year 2011
(view as .pdf document released with this Order)
10