Late Friday, the FCC released the FY 2024 Eligible Services List (“ESL”) (DA 24-1104), a necessary step that will allow USAC to open the Form 471 application window as it has traditionally done in mid-January. Most importantly this year, the ESL establishes the basic eligibility rule for school and library hotspots by simply expanding the language on eligible wireless services to read:
The latest ESL also added a useful note on school bus Wi-Fi to clarity that basic “technical support (i.e., software updates including bug fixes and security patches, and remote technical support) appropriate to maintain reliable operation of school bus network equipment is eligible for support under Category One.
What the FCC did not do in the latest ESL — as it has not done in years past — is expand the eligibility of firewalls beyond the term “basic.” We find this particularly disappointing this year because, in establishing the Cybersecurity Pilot Program, the FCC has clearly acknowledged the need for greater network protection. The FCC’s inaction on the E-Rate eligibility of advanced firewalls is further annoying because, as pointed out in the comments of both LAUSD and SECA, the ESL language under Category Two has long indicated that firewalls — without any definitional limitation — are eligible. Admittedly, the ESL does suggest that “basic firewall protection provided as a standard component of a vendor’s Internet access service” is ineligible, but that is as a Category One service.