CALTEL Alternative Proposal to Staff Proposal 3.3: Eligibility Criteria for Services CTF-eligible products include voice and data lines, and internet services - either standalone or integrated – utilizing ISDN, T1, DS3, Ethernet, Fiber, MPLS, cellular/mobile, cloud-based or equivalent technology, and including necessary ancillary services such as firewalls to ensure the safety and security of the network and information. For schools and libraries, staff recommends that eligible services mirror requirements set by the FCC for ERate funding,29 including: allowing use of Erate subsidized services for after school hours; funding only the oncampus portion of Erateeligible wireless internet service; and supporting services using lit or dark fiber provided by government and nonprofits. CTF service providers will maintain a list of all CTF-eligible products on a separate page of their public company websites. The requirements and parameters of a web-based self-certification process, including exploration of the components and functionality of the types of systems sold to CTF participants, will be discussed in a future workshop.
CALTEL Alternative Proposal to Staff Proposal 3.5: Cost Containment Mechanisms CALTEL is open to further discussions regarding alternative discount mechanisms, but neither a flat dollar discount nor a fixed discount based on lowest price is equitable or practical. These proposals fail to take into account that geography is the greatest factor influencing cost of delivering high-speed internet to CTF participants throughout California. An efficient, non-gold-plated system provided to a CTF participant that is located in downtown Los Angeles will likely cost far less to deliver than one that is provided in a rural area where no middle-mile or last-mile fiber has been deployed. CALTEL therefore proposes that the discount mechanism remain unchanged (i.e. 50% of the service price), but also wholeheartedly supports Staffs desire to minimize fraud, waste and abuse, and agrees that this topic should be discussed in a future workshop.