Wave 15 Delayed Until March
Instead of releasing FY4 Wave 15 funding letters this Friday, on its normal two-week cycle, the SLD announced that the next wave would be issued on or after March 1, 2002. There are several reasons for this delay.
Under FCC rules, FY4 applicants receiving awards on or after March 1 will have an additional year to utilize funding for non-recurring services. Up to now, through Wave 14, applicants awarded installation service funding have until September 30, 2002 to utilize their discounts. After March 1 - over eight months into the funding year - newly funded applicants will have until September 30, 2003, to use non-recurring service discounts. (Note: In all cases, recurring service funding can be applied only to services used during the actual funding year - July 1, 2001, to June 30, 2002.)
The SLD is hoping that it can make Wave 15 the last regular funding wave for FY4. By waiting an additional week or two, more of the final applications can be processed. Applicants who are not funded in the final regular waves will receive letters from the SLD notifying them that their applications are still under review. Funding of the remaining applications, after the final wave, will occur at irregular intervals in smaller batches (or "ripples").
Another benefit of waiting is to give the SLD more time to make a final determination on the funding threshold for Internal Connections. As of Wave 14, Internal Connections are being funded only for 87% discount levels and above. Our current view is that funding may drop to 86%, but that 85% is unlikely.
The SLD has now implemented a policy of formally notifying both applicants and vendors of approved SPIN changes and corrections. In the past, an applicant was simply phoned when a change request was approved (in our experience, a somewhat hit-or-miss process). Applicants and vendors are now beginning to receive written "Administrator's Confirmation of SPIN Change/Correction" notices. New service providers will also receive Funding Commitment Decision Letters ("FCDLs") indicating funding levels and discount rates.
The FCC's Notice of Proposed Rule Making ("NPRM"), that deals with possible changes to the E-rate program and that was released in January, was published in the Federal Register on February 19. Formal publication sets the deadline for comments as April 5, 2002 (and for reply comments as May 6).
The E-rate NPRM (Docket No. 02-6) requests comments on a number of topics involving the application process, discount payment and equipment transferability issues, the appeal process, enforcement tools, and treatment of unused funds (see Docket No. 02-6).
True E-rate aficionados may wish to comment on other NPRMs that could have at least a bearing on the E-rate program. One recent NPRM (Docket No. 02-33) deals with regulatory issues involving broadband access to the Internet, including the controversial issue of whether all facilities-based broadband Internet access providers - telephone wireline as well as cable, wireless, and satellite operators - should be obliged to contribute to the Universal Service Fund that supports E-rate and other industry subsidy programs. Any FCC changes that promote more neutral regulatory treatment of different types of broadband facilities and providers may serve to broaden the eligibility of Wide Area Network ("WAN") services for E-rate discounts (see Docket No. 02-33).