School Bus Wi-Fi Eligibility, Requirements & Bidding Details
December 18, 2023
The FCC previously released a Declaratory Ruling to make school-bus Wi-Fi eligible for E-rate discounts beginning in FY 2024 but deferred the details after seeking public comment through draft the Eligible Services List (ESL). Late Friday, the FCC adopted the FY 2024 ESL that contains eligibility, usage and bidding details, and USAC has already provided additional guidance for filing the Form 470 and Form 471.
Below is a summary of the ESL and USAC guidance. If have additional questions that are not addressed below, please send them to me using this Google Form: https://forms.gle/CQt8GJJGSHtgmsb6A. I’ll then compile and seek answers from the FCC/USAC that will then be shared as an FAQ to the listserve.
Equipment and Service Eligibility
- All school bus Wi-Fi equipment, mobile service and installation will qualify as Category 1.
- Eligible equipment includes modems, routers, antennas as well as the installation of the equipment.
- Maintenance and operation services are not eligible, although the FCC “may revise these eligibility determinations in a future funding year upon further review of the costs associated with these services and equipment.”
- Schools may enter into service contracts with multiple service providers, but only applicants with a rural designation can request E-rate funding for multiple services providers for the same bus.
Eligible Vehicles
- Only school buses used primarily for transporting students to and from school and school-related activities are eligible. Other school vehicles, such as vans or cars, are not eligible. Likewise, other buses such as occasionally-chartered buses (think field trips), city or municipal buses are not eligible.
- School buses may be leased by, contracted for, or owned by the school.
- If leasing buses or contracting for busing services, schools are reminded that the school will own the E-Rate-funded equipment and are expected to work with their leased or contracted school bus providers to maintain an accurate asset inventory of the E-Rate-funded equipment.
Use Restrictions and Requirements
- When buses are not being used for educational purposes, the Wi-Fi must be disabled. This includes renting buses for private and for-profit events, as well as after-hours community usage (parking buses for community Wi-Fi).
- Content filtering and user network restrictions are required consistent with the school’s Acceptable Use Policy for internet usage inside school buildings.
- There is no monthly minimum usage requirement as long as the equipment is installed and the service is activated. This includes summer months when buses are not being used.
- Warehoused or spare equipment are not eligible for reimbursement, nor is service that has not been activated.
- Bus Wi-Fi equipment purchased with E-rate funds may not be resold, etc. for at least five years, consistent with E-rate rules.
- All document retention requirements apply, consistent with the 10-year requirement.
E-rate Bidding Requirements
- Competitive bidding is required for all equipment and services, and a bid evaluation must be conducted to select the most cost-effective option(s).
- The FCC surprisingly declined to make an exemption for pre-existing multi-year contracts; however, your current service contract may be used as a bid response that may be part of your evaluation process.
- The FCC also declined to allow the CABIO bidding exemption to be used for school bus Wi-Fi recurring services.
- Note: The PEPPM mini-bid process may be an option to bid the equipment and I will provide additional details after researching and consulting with PEPPM staff.
Filing the FCC Form 470:
- Although not a requirement, I encourage schools to issue a separate Form 470 for bus Wi-Fi service and use the nickname: “School Bus Wi-Fi Service” or “School Bus Wi-Fi Service and Equipment”.
- Due to EPC system requirements, schools must upload an RFP document to EPC when starting a bus Wi-Fi Form 470.
- This can be a simple 1-page document and I’ll draft and share a template to make it as painless as possible.
- Schools should include the number of buses being outfitted for Wi-Fi, whether you are seeking bids for services only, or equipment and services, and the geographic location of the buses so providers can determine if they have service in that area.
- Suggested Form 470 narrative language: “Seeking bids for wireless school bus service and (if applicable) associated equipment to make the service functional to provide Wi-Fi. See RFP for additional information.”
- Use these Form 470 Drop Down Selections, regardless of whether you’re seeking just monthly service or both equipment and service. The RFP is where you’ll list the details of what you need.
Filing the FCC Form 471
After waiting 28 days and selecting the most cost-effective service provider(s), the next step is to submit and certify the FCC Form 471 during the upcoming FY2024 application filing window (January 17 – March 27). USAC is working on making updates to the FCC Form 471 that will allow applicants to apply for Bus Wi-Fi Service.
Many more details will be made available about which options to select on the Form 471, but initially, USAC has made these suggestions that will make expedite and ease review of school bus Wi-Fi funding requests:
- Submit a separate FCC Form 471 for Wireless School Bus Services.
- Submit a separate funding request for each contract or vendor for these services.
- Use “School Bus Wi-Fi” or similar name as the FCC Form 471 nickname.
- Select all schools as recipients of service that will be served by the buses.
- Clearly explain the number of buses on your request in the FRN Narrative.
Don’t forget, if you have additional questions that are not addressed in this summary, please send them to me using this Google Form: https://forms.gle/CQt8GJJGSHtgmsb6A. I’ll then compile and seek answers from the FCC/USAC that will then be shared as an FAQ to the listserve.
– Julie
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org