FY 2018 Filing Window:
The Form 471 Filing Window for FY 2018 has not yet been announced. For planning purposes, a workable assumption is that the Filing Window will open in mid-January and close in late-March.
As an important first step, USAC announced that it has completed the updates on applicant profiles based on PIA review of FY 2017 applications. Applicants can now review and update their entity profiles in EPC. This is the beginning of what in the past has been known as the “Administrative Window.” Once USAC begins accepting FY 2018 applications, entity profiles will be locked for the duration of the Filing Window.
Upcoming 2017 E-Rate Dates:
| December 4 |
Form 486 deadline for FY 2017 funding committed in Wave 10. Upcoming FY 2017 Form 486 deadlines include:
Wave 11 12/11/2017
Wave 12 12/18/2017
Wave 13 12/26/2017
Wave 14 01/02/2018
Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” in EPC. The Reminders will afford applicants with 15-day extensions to submit their Form 486s without penalty.
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| December 13 |
USAC webinar reviewing this fall’s training sessions (see below). |
| December 13 |
Second FY 2017 Emergency Hurricane Application Window (opened November 13th) closes. For additional information, see USAC’s Summary of the Orders and Important Deadlines. |
FCC Decision Watch:
The FCC issued another set of “streamlined,” precedent-based decisions (DA 17-1130) last week. Applicants facing similar problems as addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes. The original appeals and waiver requests can be found online in the FCC’s Search for Filings.
In summary, last week’s FCC decisions:
- Dismissed:
- Two Requests for Waiver deemed moot because the invoicing records indicated that the applicants had been fully compensated.
- Four Petitions for Reconsideration (a) failing to provide any arguments not already fully considered by the FCC, or (b) not submitted within the 30-day Reconsideration filing window.
- Granted:
- One Grant of Reconsideration for a late-filed Form 471 as the result of an unexpected serious illness and resulting medical leave.
- Three Requests for Waivers for invoice deadline extensions based on delays induced by USAC procedures.
- Four Requests for Waiver for applications involving ministerial and/or clerical errors.
- One Request for Review on a long-standing (FY 2002) issue involving alleged improper service provider involvement in the competitive bidding process which was finally resolved based on a sworn statement by the applicant.
- One Request for Waiver concerning missing the 28-day bidding period by only 1-3 days.
- Denied:
- One longstanding (dating to 2009) Request for Review and Waiver of improper service provider involvement in the competitive bidding process. The FCC also again rejected an argument that USAC had not pursued the action within five years.
- Thirty Requests for Waiver for invoice deadline extensions — the first of a number of similar waiver requests received or expected following the October 30th invoice deadline for FY 2016 recurring service invoices.
- Three Requests for Waiver for late-filed Form 471 applications filed more than two weeks late.
- One Request for Waiver of a denial for services requested not covered by the applicant’s competitive bidding process.
- Three Requests for Waiver not filed within the 60-day appeal window.
Awaiting Formal Guidance on Form 470 Internet Options:
Status: Ridiculous.
As discussed in our newsletter of November 6th, USAC continues to avoid the release of written guidance on the proper use of the Form 470 menu options when applying for fiber-based Internet services — an avoidance strategy probably reflecting the lack of guidance from the FCC itself. Until long-promised clarifications are provided — perhaps in USAC’s December 13th webinar noted below — our best advice is as follows:
- Always include the “Leased Lit Fiber” option, whether or not transport is required.
- Use either the “Internet Access & Transport Bundled” or the “Internet Access: ISP Service Only” option, as appropriate (the only two options that mention “Internet”).
- Use the “Narrative” section to fully describe what is required and upload a detailed RFP.
Updated Hurricane Relief Entities Report:
Last week’s USAC News Brief notes that its EPC-generated hurricane relief report has been updated and renamed with the catchy title: “Entities Within Counties Eligible for FEMA Individual Disaster Assistance Report, DA 17-984 (WCB Hurricane Relief Order).” The revised report can be downloaded from the Actions tab in EPC.
USAC Fall E-Rate Training:
USAC’s annual fall training sessions were held this year in Charlotte, Minneapolis, Portland, and Washington DC. Presentation slides for the most recent training are available online. Other useful instructional videos and webinar recordings may be found in USAC’s Online Learning Library.
USAC will hold a live webinar at 3:00 p.m. EST on Wednesday, December 13th, to review the highlights of this fall’s four training sessions. Advanced registration is recommended.