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Cost Objections Raised

Most Comments Support Making School Bus Wi-Fi a Category One Service

Most commenters supported adding the equipment and services needed to use Wi-Fi on school buses to the FY 2024 eligible services list for the FCC E-rate program as a category one service. Comments were posted Friday in docket 13-184. FCC Republican Commissioners Brendan Carr and Nathan Simington dissented last month on an NPRM asking about the change (see 2311090028).

This clarification will create a significant opportunity for many of our nation’s students,” said the Schools, Health & Libraries Broadband Coalition. “The COVID-19 pandemic shed light on the disparities Americans still face when it comes to having access to reliable, affordable broadband at home,” SHLB said.

The State E-rate Coordinators’ Alliance (SECA) said the Wireline Bureau and the Universal Service Administrative Co. must move quickly to implement changes. “Not only is prompt action necessary to identify exactly what non-recurring equipment and related costs as well as recurring service costs will qualify for E-rate funding, applicants also need to know precisely what other special conditions and requirements, if any, will govern the procurement and use of the equipment and services, including, but not limited to, competitive bidding, eligible use restrictions, applicability of [the Children's Internet Protection Act], and document retention,” SECA said.

T-Mobile said Wi-Fi on buses should be treated as a category one service under the ESL. “T-Mobile agrees with the Bureau’s conclusion that mobile broadband connectivity is a Category One service, and we encourage the Bureau to treat all related equipment as also falling within Category One,” the carrier said: “Providing connectivity to school buses is the same as providing connectivity to bookmobiles, which the Commission deems an E-Rate Category One service.”

Verizon urged flexibility in the rules. School systems should be allowed to use 4G LTE or 5G to satisfy the program's requirement, Verizon said. In a common configuration, “schools provide Wi-Fi service to students on a school bus using an external antenna mounted on the bus, a specialized router designed for mobile applications (which typically includes the modem and Wi-Fi functionality), and a cable connecting the antenna to the router,” the carrier said: “But the Bureau should not specify a particular equipment configuration in the ESL; schools should have the flexibility to choose how to provide Wi-Fi or similar access point service on school buses.”

Funding should support the equipment needed to provide service, the cost of installation, an unlimited data plan and a firewall to “ensure that the traffic is compliant” with the Children's Internet Protection Act, said NCTA. It called for a competitive bidding regime to select companies to provide service and said the gear should be classified under category one. “NCTA advocates that the Commission carefully delineate the scope of the covered service and ensure that competitive bidding requirements are followed,” the group said.

But consultant E-Rate Provider Services warned against the program's potential cost and advised the FCC to look more closely at the use of private networks. “Allowing private cellular networks to be built using E-Rate funds would be a critical step toward managing the anticipated increase in the demand for Category 1 funds in the program,” the company said.

Several school districts supported making school bus Wi-Fi a category one service under the ESL. “Requiring school bus Wi-Fi equipment to be classified as Category Two will develop competing priorities for schools wishing to close the Homework Gap,” said the Los Angeles Unified School District: “This would force schools to have to choose between on-campus Wi-Fi and school bus Wi-Fi. This is impractical from an implementation standpoint and contrary to the program’s objective,” the district said.