The comment period for the FCC’s second draft Eligible Services List closed on Thursday, November 30, with more than twenty comments submitted by E-rate applicants, service providers, consultants, and industry groups. A vast majority of the comments received by the Commission were supportive of the inclusion of school bus Wi-Fi as an eligible service in the E-rate program. Popular topics of discussion in the comments included:
- Equipment – a large majority of commenters support classifying school bus Wi-Fi equipment as an eligible Category One purchase. Comments drew comparisons to existing Category One network equipment purchases, indicating that antennas, radios, and other equipment is required for mobile broadband connectivity to be functional.
- Average costs – while the FCC’s Public Notice discussed an average cost of $1,840 to outfit a school bus with Wi-Fi service based on experience with the Emergency Connectivity Fund program, commenters generally found that cost to be too low. Four commenters proposed alternative calculations using ECF and other data, with average costs suggested in a range of $2,500 to $4,000 per bus in Wi-Fi hardware, licensing, and maintenance and another $400 to $600 per year in mobile broadband service. Based on an estimated 500,000 school buses in the United States and an average E-rate discount rate of 80%, several commenters postulated that it would cost the E-rate program between $350M and $450M to outfit every bus in the country.
- Competitive bidding – a number of commenters suggested that the FCC include school bus Wi-Fi in the $3,600 per year competitive bidding exemption, arguing that commercially available business class internet service for each bus could be purchased at rates below the current bidding exemption.
- Procedural issues – several comments encouraged the FCC not to require applicants to obtain Billed Entity Numbers (BENs) for Wi-Fi enabled school buses. Support was also shown for ensuring that bus Wi-Fi is eligible for both applicant-owned and leased school buses.
Comments to the draft Eligible Services List may be viewed in the FCC’s Electronic Comment Filing System here.
