Industry Wants VoIP to Stay on E-Rate Support List

The FCC should keep interconnected VoIP on the eligible services list, said AT&T, Verizon and other wireline carriers. VoIP saves schools and libraries money, and has enhanced features like video conferencing and long-distance learning, Verizon said. Maintaining VoIP support is consistent with the Telecom Act whether or not the FCC decides, in its IP-enabled services docket, to classify interconnected VoIP as a telecom or information service, AT&T said.

Cable operators agreed. NCTA, not surprisingly, advocated treating VoIP as a “miscellaneous” service eligible for E-rate support. “The Commission observes correctly that millions of consumers have chosen VoIP services in recent years and that ’schools and libraries could benefit from the same cost efficiencies and services features that have led many consumers to choose this technology,'” the group said. NCTA said treating VoIP as an eligible service is “fully consistent with the purposes of the E-Rate program” since it “enhances the options available to schools and libraries to effectuate meaningful communications among parents, teachers, and school and library administrators.”

Comcast’s arguments resembled NCTA’s. “The removal of interconnected VoIP from the 2009 eligible services list would harm the many schools and libraries that, like the millions of individual VoIP subscribers, benefit from the advantages that VoIP service provides over traditional telephone service,” Comcast said.

The FCC should add firewall and anti-spam/anti-virus services to the list of eligible services, some said. Those capabilities are “critically important” for “safeguarding reliable data delivery, and protecting the equipment and network operating systems over which Internet access is provided,” and thus “appear to be ‘integral, immediate, and proximate to the education of students or the provision of library services to library patrons” using the Internet, AT&T said. The services are needed to protect children, the E- Rate Service Providers Association said. The FCC must fund filtering services as a matter of “fundamental fairness,” said the State E-Rate Coordinators Alliance. “An ongoing complaint that applicants voice is that they are legally required to install filtering and to incur this cost as a condition of receiving E-rate funding for Internet access service, but there generally is no E-rate funding available for filtering,” it said.

Verizon opposed adding filtering services. “Currently, any school or library can obtain E-rate support for filtering, firewall, and anti-virus or anti-spam services by purchasing e-mail software or other eligible components that include such features,” it said.

Most commenters opposed eligibility for dark fiber. “Dark fiber is not a ’service’ at all,” Verizon said. “It is merely a network facility, which is not eligible for E-rate support.” Embarq said “applicants sophisticated enough to seek dark fiber to operate their own networks do not warrant E-rate support.” E-Rate discounts may only be justified for dark fiber bought in conjunction with lit fiber, Qwest said. But the Council of Great City Schools, representing 66 of the nation’s largest inner-city schools, endorsed adding dark fiber, if it’s lit immediately. “Allowing beneficiaries to lease dark fiber and light it themselves typically results in a far more cost-effective and strategic investment than leasing a comparable [lit] circuit from a carrier,” the Council said. “By making dark fiber eligible, the ‘middle man’ can be eliminated, and applicants will be able to lease dark fiber directly from the carrier that owns the physical infrastructure.”

Verizon urged the FCC to make “a variety of services used for educational purposes” eligible for E-Rate support. The agency should include “wireless text messaging, telephone broadcast messaging, wireless Internet access applications, and wireless modems, laptop cards and routers,” it said. Blackboard, which develops software for schools, urged the FCC to add phone broadcast messaging. Schools can use messaging for attendance notification, community outreach and emergency communications, it said. Scheduling services should stay eligible for E-Rate funding, Embarq said, calling them “instrumental” for distance learning and video service.

Wireless Internet service should be supported, but the list should be expanded to include other wireless data services as well, Sprint Nextel said. It cited gear on school buses for automatic alerts. Readers tracking student movements might be funded, Sprint said. A student boarding a bus or entering a classroom might be required to swipe a card with an RFID chip or bar code, it explained. In another example, it noted that school systems could use GPS to track buses or change routes to accommodate emergencies or inclement weather.

“All of these capabilities can reasonably be considered to be ‘integral, immediate and proximate’ to the education of students, and thus eligible for E-rate funding,” Sprint said. The FCC should clarify that EV-DO cards used for educational purposes should specifically be eligible for support, Sprint said. It was the lone national wireless carrier to file in the comment round. AT&T filed joint wireline and wireless comments. Verizon and Verizon Wireless also filed together.

The FCC should be selective in weighing services for eligibility, warned the American Library Association. “We are concerned that many of the proposed changes do not appear to directly support” the purpose of E-Rate “and will therefore negatively impact the ability of libraries and schools to receive the fundamental services that are so essential to their core functions.”

E-Rate needs more funding, said the E-Rate Service Providers Association. The FCC should raise the funding cap, now $2.25 billion, by realigning the four USF funds and altering discounts for priority two services, ESPA said.