The proposed E-rate Eligible Services List for funding year 2015-2016 has been released for public comment. The proposed list is intended to implement the changes made in the FCC’s recently-released E-rate modernization order, but the FCC’s Wireline Competition Bureau (“WCB”) has asked for comments on whether the proposed list accurately implements those changes. Aside from reflecting the rule changes that we summarized in our prior blog post the draft list makes a number of purportedly non-substantive changes, including eliminating some explanatory text that the WCB believes may mislead service providers, schools and libraries into believing that certain ineligible services or equipment are eligible. But changes to long-standing language in the list could have unintended consequences, such as introducing new ambiguity to what is already a complex and administratively burdensome program. We strongly encourage stakeholders to carefully review the draft list and submit comments to the FCC if you believe that the draft fails to accurately implement the program changes in the order or otherwise misinterprets applicable E-rate rules.
Comments are due September 3, and reply comments are due September 18.