Comments on Proposed E-Rate FY 2025 ESL Due Aug. 30

The Federal Communications Commission’s Wireline Competition Bureau (Bureau) released the Funding Year 2025 E-rate Eligible Services List (ESL) on July 31, 2024.  Comments are due August 30, 2024; reply comments are due September 16, 2024. 

The Bureau seeks comment on the FY2025 ESL as well as the following proposed revisions to the ESL:

1. The Bureau proposes to revise the description of “wireless” service under Category One to read “Wireless (e.g., fixed wireless; microwave; mobile service for use on school buses; or mobile service for use with Wi-Fi hotspots)” to reflect the Commission’s adoption of a Report and Order making eligible the off-premises use of Wi-Fi hotspots and mobile wireless Internet access services.

2. The Bureau proposes to amend the explanation of “Wireless services and wireless Internet access” in the “Eligibility Explanations for Certain Category One and Category Two Services” to clarify a number of issues from the Wi-Fi Hotspot Report and Order: 

o First, the proposed explanation includes language noting the eligibility of off-premises use of Wi-Fi hotspots and mobile wireless Internet services.  It also includes an explanation of Wi-Fi hotspot eligibility, consistent with the Wi-Fi Hotspot Report and Order.

o Second, the proposed explanation modifies and moves the sentence clarifying eligibility of off-campus wireless service on a school bus to the second paragraph. 

o Third, the proposed explanation modifies the sentence to make clear that cost allocation of off-campus use of E-Rate-funded services is required. 

o Finally, the proposed ESL clarifies the cost-effectiveness test required for data plans and air cards.  In 2014, the Commission recognized that there are a few locales where a wired local area network is impracticable, such as a library bookmobile and set out a cost-effectiveness requirement for on-premises use of Wi-Fi hotspots.  Since then, the ESL has explained that “[s]eeking support for data plans or air cards for mobile devices for use in a school or library with an existing broadband connection and WLAN implicates the E-Rate program’s prohibition on requests for duplicative services,” but explains that if, however, a bookmobile, which is eligible as a library in its state, requires mobile connectivity, it may demonstrate that it is the most cost-effective option for delivering service to the bookmobile.  The proposed language change to this explanation clarifies that this requirement applies only to on-campus use. 

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