News of the Week

The FY 2014 application window opened January 9, 2014, and will close on Wednesday, March 26, 2014 at 11:59 p.m. EDT.

Wave 36 for FY 2013 will be released on Thursday, January 30, 2014, for $26.3 million.  Funding is currently being provided for Priority 1 services only.  Cumulative funding for FY 2013 will be $1.77 billion.

Last Friday, the Official FCC Blog carried an article by Chairman Wheeler entitled “Helping American Students Compete in a Digital World.”  The article stressed the FCC’s commitment to President Obama’s ConnectEd initiative to connect 99% of America’s students to high-speed broadband within five years.  Most intriguing was the following statement:

As part of our top to bottom review of E-Rate, the opportunity has opened to use existing funds to immediately begin to expand E-Rate funding targeted to high-speed connectivity to students in schools and libraries. These additionally available funds will begin to be put to work this year for schools and libraries. This will be done without affecting the program’s existing structures and the 2014 program application process that is now underway.

It is not clear from this statement if the Chairman is referring simply to normal roll-over funding from previously unused E-rate funds or to a new source of E-rate funding. Additional information on the potential for FY 2014 roll-over funding should be available within the week when USAC releases its next Quarterly Fund Size Projection.  The previous projection, as of September 30, 2013, showed an accumulation (after two quarters) of $400 million.
If new funding is contemplated, more definitive information may come from the Chairman’s planned presentation at Digital Learning Day on February 5th. 

FCC Protective Orders re. E-Rate 2.0:

The FCC has released two “Protective Orders” (DA 14-79 and DA 14-80) in connection with its proposed modernization of the E-rate program as embodied in the E-Rate 2.0 NPRM process.  The Orders are a clear recognition by the FCC that much of the information it will need to develop a complete record may be deemed proprietary or confidential — particularly as it might apply to service provider network deployment and competitive strategies.

The primary difference between the two Orders is the degree of confidentiality involved, with the second (DA 14-80) providing additional limited access to “particularly competitively sensitive information” deemed “Highly Confidential.”  Both Orders set forth specific procedures for marking information as confidential, requesting access to that information, handling information accessed, and appealing access decisions.  Most pointedly, access to all such information is limited to those “not involved in Competitive Decision-Making.”

Form 470 Deadline:

Technically, this year’s deadline for filing a valid FY 2014 Form 470 and/or RFP is February 26, 2014.  However, waiting until the deadline leaves no room for error.  Because a Form 470 must be posted for 28 days, a February 26th filing would mean that on March 26th the applicant would have to:

• Select vendors
• Sign contracts, if required
• File a Form 471 — the final day of the FY 2014 application window!

Applicants filing Form 470s on paper are reminded to use the revised version which became effective December 20th.  The revised paper version can be identified by the “December 2013” date in the bottom right-hand corner of each page.  A type-in PDF version of the revised Form 470 is available in E-Rate Central’s Forms Rack.

Form 486 Deadlines:

Typically, a Form 486 must be filed no later than 120 days from FCDL issuance or the start of service, whichever is later.  Assuming services started July 1, 2013, the deadlines for FY 2013 funding waves 1-19 have already passed.  The remaining Form 486 deadlines for January and February are:

                                          Wave 20                01/30/2014
                                          Wave 21                02/04/2014
                                          Wave 22                02/13/2014
                                          Wave 23                02/20/2014
                                          Wave 24                02/27/2014

The SLD News Brief for January 24, 2014, reviews the use of the recently updated SLD online Training Site.  The site permits applicants or E-rate trainers to practice or show others the online filing process for Forms 470, 471, and 486.  Online training versions for Form 472 (BEAR) and other utility tools are not currently available.

The Training Site is designed to look and function similar to the regular Apply Online section of the SLD’s website, including options to use both the expert Create and the Interview options for filing purposes.  The obvious difference is that forms prepared on the Training Site are not actually filed.  Another difference is that certain fields, such as the Billed Entity Number, must use specific data provided by the SLD on both the Training Site and in the News Brief instructions.