SLD Clarifies Eligibility Issues Regarding Remote Access Routers
Message Posted June 9, 2000
The SLD provided information on its Website this week www.sl.universalservice.org/whatsnew/default.asp that clarifies several issues regarding the eligibility of routers with remote access capability. The notice stems from an earlier PIA problem specifically related to Cisco 2500 series routers.
The SLD’s concern with remote access is that the capability could permit anyone, an eligible or ineligible entity, to dial in through a remote access router to obtain Internet access. As a result of this concern, the SLD had previously denied a number of internal connection funding requests involving routers (or series of routers) known to include remote access capability.
Based on a FCC decision late in 1999 (see White Sulphur Springs case at: www.fcc.gov/Bureaus/Common_Carrier/Orders/1999/da992537.doc , the SLD announced that eligibility of a router will depend upon its use. Specifically, the SLD will consider a remote access router eligible if the applicant certifies that the router will not be used to provide remote access or, if remote access is available, that the applicant has taken steps to ensure that "…access will not be available from homes or other non-school or non-library sites." Suggested language for this certification is provided in the SLD notice.
Applicants who were previously denied funding for routers that, in light of this clarification, might or should have been deemed eligible have only one recourse; they must appeal the earlier decision. The appeal should include the suggested certification and provide as much documentation as possible on router usage and/or configuration.
Because FCC rules require appeals to be filed within 30 days of a funding commitment decision, applicants who were denied funding over a month ago, and who have not yet appealed, may have no recourse, although we are part of a group of states that is actively fighting for a better resolution. Pending any instructions from the SLD to the contrary (which we hope may be forthcoming), our recommendation to applicants in this situation is to file an appeal with the FCC referencing, as the "decision date," the SLD’s May 25th announcement.
Julie Tritt Schell
Executive Policy Specialist
Pennsylvania Department of Education
333 Market Street, 10th Floor
Harrisburg, PA 17126
(717) 705-4486
(717) 787-7222 - fax
jtritt@state.pa.us
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