If you’re considering making the leap to wireless connectivity, one factor you’ll want to consider is whether–and how much–the eRate can help you get there.
As created by Congress under the Telecommunications Act of 1996 and implemented by the Federal Communications Commission via the Universal Service Administrative Company’s Schools and Libraries Division (SLD), the eRate wasn’t intended to pay for all your schools’ technology needs.
In fact, the $2.25 billion annual fund is specifically focused on connecting classrooms to the internet by making the telecommunications link affordable–and then assisting with the inside-the-building infrastructure needed to bring the ‘net to where the kids are. By providing discounts on these costly necessities, the reasoning goes, the eRate stretches your technology budget to cover the stuff it doesn’t.
However, exactly what is–and isn’t–directly “eRatable” can sometimes seem mysterious.
The published Eligible Services List (available on the SLD’s web site at http://www.sl.universalservice.org/Reference/eligible.asp numbers about 120 items at the moment, up significantly from the original list developed when the program was launched in 1998. But with technology changing more rapidly than any mechanism the FCC could have in place to review and officially rule on every new innovation, both the SLD and eRate applicants have to rely on certain basic principles to determine service eligibility.
This may be particularly true of anything coming from the brave new world of wireless–examples of which are finding their way into an increasing number of eRate applications, some successfully, others not.
Basic eRate principles
To determine the eligibility of any service or product, you have to start with certain eRate fundamentals.
For example, the Eligible Services List is divided into three categories, often referred to as buckets (perhaps because you have to get a handle on them before they can be at all useful). The buckets are:
Telecommunications services, which includes virtually any commercially available service–including voice, data, or video–from a telecommunications carrier officially recognized as such by your state and/or the FCC. When you are considering any kind of wireless service, your first question ought to be: Is this company a telecommunications carrier? If not, the services you receive from them will have to fit into one of the other two buckets to be eligible. And the key word here is “services,” as distinguished from “equipment.”
Internet access, which is also a service category, but with no restrictions as to who can provide that service to you. Again, the focus here is on the recurring internet service (and in some cases, the monthly cost of the lines to tap into that service) as opposed to any equipment you need to buy to take advantage of that service. This is also a fairly narrow category of service, for the time being: it really means internet access only, and not all the other stuff you might run over the same pipe, whether the pipe is in the ground or a channel in the air. As you’ll see below, if you are considering wireless access to the internet, it’s important to keep these distinctions in mind.
Internal connections, which is equipment that you buy (or lease) to distribute the world of information to your classrooms. This is behind-the-scenes stuff–wiring, routers, servers, hubs, private branch exchange equipment–rather than end-user equipment; it is also by definition on your premises, as opposed to being housed in a remote location that may serve more than one school.
Which leads us to a couple of other eRate fundamentals:
LAN vs. WAN: One of the most important–and in times of changing technology, the slipperiest–eRate distinctions is the one between a local area network and a wide area network. The connections among rooms in a school building make up a LAN; the connection from one building to another across any public right of way is considered a WAN.
Leased vs. purchased: While you can use eRate funds to buy any eligible piece of LAN equipment, you cannot purchase a WAN or any piece of a WAN with eRate dollars. To be eligible for the eRate, your WAN must be leased (in other words, it must be a service) and meet one of these requirements: it is either provided by a telecommunications carrier, or it is the most cost-effective way for you to access the internet (and the eRate will only cover the internet access part).
Technology neutral: Some might argue that much in the design of the eRate is based on traditional wireline telecommunications technology, but the program is, in principle, technology-neutral. This means that the same restrictions (such as the prohibition against owning a WAN) that apply to the wireline world also hold for wireless.
Where wireless fits in
So, is there room in the eRate for wireless? The answer is many flavors of “yes”:
Voice services: It’s no secret that one of the biggest eRate boons to schools is the spread of phone service beyond the main office to the classroom and other learning spaces–and that much of this service is cellular. The rush to cell service–often as a supplement to wireline service–continues unabated.
What to watch out for: Make sure that your cellular service provider is a recognized telecom provider, and know that the SLD will look askance on any deployment that supports uses far beyond the “shared network of services for learning.” Limit your eRate-funded cell service to those fairly close to instruction (and then use your savings to equip the entire janitorial staff, if that’s important to you). And remember that the eRate pays for service only, not the phones themselves.
Wireless private branch exchange (PBX): Still pretty rare in schools, this provides the equivalent of cordless phone service throughout a school building, all powered by a piece of equipment housed on the school property that the school buys or leases.
What to watch out for: Because this is user-premise equipment and not a service, a wireless PBX–like its wireline equivalent–is considered internal connections, not telecommunications service.
Cell access to eMail and the ‘net: This is parallel to dial-up internet access; if you are charged separately for such service, you should list those costs as “internet access” on your eRate application.
What to watch out for: The eRate specifically does not pay for either telecommunications services or internet access from homes, so make sure that your cell-based services are primarily for use at school.
Wireless LAN: Schools are beginning to investigate the possibilities of local area networking without drilling holes in walls, raising floors, and otherwise grappling with the dilemmas of retrofitting. If your wireless LAN really is local–meaning that the transmission and reception gear is dedicated to serving the inside of your building–it is eligible for purchase under the eRate as internal connections.
What to watch out for: If any of your transmission gear is, or appears to be, for connecting buildings beyond your campus, you will run into trouble getting eRate funds for it. It’s pretty tough to sell a tower outside your building as a piece of LAN equipment. Also, remember that end-user equipment generally is ineligible for discount; for example, network interface cards are only eligible if they are part of an eligible product or service. Similarly, the SLD would have to look at wireless handhelds and the server they synch with the same way the agency would view a wireless PBX: the handsets are not eligible, but the server (with its central antenna) would be.
Wireless access to the internet: For many schools in particular geographic areas, moving beyond dial-up internet access is problematic, because wireline service is not available or not economically feasible. Often the best solution is some combination of satellite and other wireless technology.
What to watch out for: You can only lease the transmission gear as part of your monthly service, not buy it outright. And unless you are receiving this service from a recognized telecommunications provider (see Wireless WAN, below), your use of the service must either be dedicated for internet access, or–if you receive voice or other non-internet service over the system–you must allocate out the non-internet costs.
Wireless WAN: As is true on the wireline side, you can lease a multi-use wireless wide area network from a recognized telecommunications provider. If your telecom provider can offer you the wireless equivalent of a T-1 connection among the buildings in you district, for example, you can use eRate dollars for that service.
What to watch out for: You cannot use eRate funds to buy outright (or lease-to-buy) any piece of transmission equipment for this wireless WAN. In past years, this was seen by some as a barrier to wireless involvement in the eRate, because the economics of the wireless industry didn’t necessarily support leased service. But as with many aspects of the eRate, savvy vendors are finding legitimate ways to bring their services into line with the program’s requirements. And where they can’t, some schools are finding ways to pay for that equipment with non-eRate funds.
It’s a safe bet that wireless services will continue to evolve very rapidly, at the same time that media convergence continues to blur the lines that separate voice from data, video from the ‘net, telephone from television, computer from radio.
When a new service not clearly covered by the Eligible Services List crops up on an application (or is presented by a vendor), the SLD will bring that service to the FCC’s attention for an eligibility ruling. Since the deliberative wheels turn slowly, however, smart eRate applicants will always cover themselves by breaking out new or unresolved services on their applications and having a backup plan in case the funding answer is “no.”
Like so much of working with technology, it’s a matter of having one foot in the future and one foot firmly in the present–and somehow keeping your balance.
Mickey Revenaugh is former vice president for outreach at the Schools and Libraries Division and currently serves as K-16 Marketing Director for Broadband Networks Inc.