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September 3, 2012

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Funding Status

Wave 9 for FY 2012 will be released on Wednesday, September 5, 2012, for $33.0 million. Priority 2 funding is being provided at 90%, and is being denied at 89% and below. Cumulative funding for FY 2012 will be $1.07 billion.

Wave 59 for FY 2011 will be released on Thursday, September 6, 2012, for $3.1 million. Priority 2 requests are being funded at 88% and above, and denied at 87% and below. Cumulative funding for FY 2011 is $2.35 billion.

A very small Wave 100 for FY 2010 will be released on Tuesday, September 4, 2012, for $117 thousand. Priority 2 funding is being provided at all discount levels. Cumulative funding for FY 2010 is $3.05 billion.

Reply Comments on FCC's FY 2013 ESL Draft

Final comments on the FCC's draft of the Eligible Services List ("ESL") for FY 2013 were due last Wednesday. The following is a brief summary of the substantive reply comments received:

  1. Both AT&T and Sprint, perhaps not surprisingly, took exception to initial comments filed by E-Rate Provider Services to make cellular data plans ineligible. The arguments hinged, in large part, on the cost-effectiveness of on-campus use of Priority 1 cellular data services as opposed to Priority 2 wireless access points.
  2. AT&T also encouraged the FCC to review and clarify the eligibility of various taxes and surcharges, arguing that all surcharges and program fees required or permitted by federal, state or local governments should be eligible. Hopefully, such a clarification would address USAC's current position that any "administrative" fee, even if included as a normal cost of service, is ineligible. Similar requests for review and clarification had been suggested by several other parties during this year's and previous years' ESL comment periods.
  3. Montgomery County Public Schools supported a proposal by Funds for Learning to make uninterruptible Internet Access eligible. Montgomery also urged the eligibility of advanced conferencing, broadcast "blast" messaging, and emergency notification services.
  4. Quilt, an association of over thirty Research and Education ("R&E") networks nationwide (including NYSERNET in New York), urged the FCC to adopt SECA's recommendation to combine Telecommunications and Internet Access into a single Priority 1 category. Quilt also supported greater clarification on the treatment of fiber-based services from both telecommunications carriers and non-carriers.
  5. SECA's reply comments reiterated its proposal to combine the sub-categories within both Priority 1 and Priority 2, noting the absence of any arguments to the contrary. SECA also supported proposals by Funds for Learning to initiate a Notice of Inquiry on basic maintenance, make all telecom surcharges and fees eligible, and eliminate certain USAC review practices.

Comments on a related proceeding regarding SECA's petition seeking clarification on "free" bundled end-user equipment (see DA 12-1325) are due September 10th; reply comments are due September 24th.

Schools and Libraries News Brief Dated August 31 – HATS Update

The SLD News Brief for August 31, 2012, reviews USAC's Helping Applicants to Succeed ("HATS") program. This is a targeted outreach program designed to identify and provide guidance to applicants who may have had E-rate difficulties in the past and to others seeking help. The program, which has been around for over six years, may involve applicant visits, teleconferences, or e-mails by USAC personnel. Areas covered include:

  • General discussion of program requirements.
  • Specific discussions of difficulties or concerns identified by USAC or the applicant.
  • Identification of outstanding issues and steps for resolution.
  • Demonstration of search tools and other USAC Website resources.
  • Solicitation of feedback on USAC's outreach efforts.

While many joke about the phrase "We're from the government, and we're here to help you," the HATS initiative has, in fact, proved useful to many applicants. Most importantly, it is a true outreach effort. It is not a compliance or audit program. Indeed, participation is purely voluntary. Any applicant offered a HATS visit by USAC is free to decline — although, at a minimum, we'd suggest asking USAC why the offer had been made. Conversely, any applicant having problems with some aspect of the E-rate program is free to request HATS assistance by calling the Client Service Bureau 888-203-8100).