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In This Week's Issue
» Funding Status Update
» SLD Fall Training Updates
» E-Rate Updates and Reminders
» Schools and Libraries News Brief for October 4 – Entity Numbers

E-Rate Central News for the Week
October 7, 2013

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 (516-801-7814), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.

Funding Status

Wave 21 for FY 2013 will be released on Monday, October 7, 2013, for $67.3 million, including $3.63 million for 23 New York applicants.  Funding is currently being provided for Priority 1 services only.  Cumulative funding for FY 2013 will be $1.01 billion, including $43.4 million for New York. 

USAC has picked up the pace on FY 2013 funding, but is still behind last year’s $1.28 billion as of the first October wave.  An update on the status of FY 2013 application processing is included in last week’s SLD News Brief (see link below).  The critical sentence is: “Our target is to have at least 90% of all Priority One applications completed and committed by December 31, 2013.”  Note that this projection refers to number of applications, not to dollar value of applications.

Wave 63 for FY 2012 will be released on Thursday, October 10, 2013, for $688 thousand, including $82 thousand for one New York district.  Priority 2 funding is being provided at 90%, and is being denied at 89% and below.  Cumulative funding for FY 2012 will be $2.76 billion, including $145 million for New York.

SLD Fall Training Updates

The first of the SLD’s 2013 fall training workshops was held in Washington, DC, last week (see links below for fall schedule, agenda, and presentation slides).  For the most part, the material presented was largely review of existing rules and procedures.

Two exceptions included updates on a number of FCC forms which are in the process of being revised, and a potentially critical interpretation (not covered in the presentation slides) of the definition of an “RFP.”

In July, the FCC released for comment two sets of proposed form revisions, FCC Forms 470 and 471 (DA 13-1590) and FCC Forms 479, 486 and 500 (DA 13-1636).  Although the revised forms have not yet been officially approved and released, the SLD discussed a number of expected changes — some of which were not included in the revisions previously proposed.  The most important changes are summarized below.

  • Block 2 of Form 470 has been updated to reflect the combination of Telecommunications and Internet Access as a single category.
  • The RFP language in Block 2 of Form 470 now permits applicants to indicate that an RFP is available for “one or more” of the services listed.  This means that it will no longer be necessary to file two Form 470s when some services are covered by an RFP and others are not.
  • Record retention certifications on Forms 470, 471, 479, and 486 have been changed to indicate whatever retention period is required by FCC rules.  This change reflects an outstanding proposal in the NPRM to change the retention period requirement from five to ten years.
  • Block 2 of the Form 471 is being eliminated, but additional circuit information will now be required on all Priority 1 FRNs to report broadband connectivity (including information on wired vs. Wi-Fi connections).
  • The technology plan certification on Form 486 has been clarified to indicate that plans are no longer required for Priority 1 services.
  • The Form 500 has been updated to include blocks for changes in service start dates, contract expiration dates, and service delivery dates.

Barring an extended government shutdown, the revised Form 471 should become effective with the opening of the FY 2014 application window expected to open this December.  The revised Form 470 should become effective at the same time, until which time the current version can continue to be used.

The most controversial issue at the DC training, arising during the discussion period (not reflected in the presentation slides), dealt with the definition of an “RFP” for Form 470 purposes as the result of a recent FCC appeal decision (see the discussion in our newsletter of September 30, 2013).  The SLD initially indicated that any supplementary information provided by an applicant would constitute an RFP but later clarified that there will be no change in current application review procedures.  We hope that this position will be revisited and better explained once the FCC is back open for business.

E-Rate Updates and Reminders

FCC Shutdown Plan:

FCC activities during the government shutdown are governed by the FCC’s Plan for the Orderly Shutdown Due to Lapse of Congressional Appropriations.  The plan effectively furloughed 98% of the FCC staff.  USAC, which is not funded through Congressional appropriations, is not being directly affected by the shutdown except for activities relying on FCC action and/or guidance (including final approval of the Eligible Services List for FY 2014 and the revised forms discussed above).

FCC Public Comment Schedule:

Reply comments to the FCC’s Notice of Proposed Rulemaking: Modernizing the E-rate Program for Schools and Libraries (FCC 13-100) are due by October 16th — assuming the government shutdown has ended.  If not, the due date for reply comments, pending further notice, will be the first business day following the end of the shutdown.  In the interim, the FCC’s “filing window, mail room, and all electronic filing systems…will be unavailable.”  This means that E-Rate 2.0 comments, which have already been filed, are also unavailable for review on the FCC site.

For those seeking access to previously filed comments, E-Rate Central has posted a list of E‑Rate 2.0 NPRM Initial Filings in an Excel workbook format on its website.  The workbook includes an FCC Data tab referencing every E-Rate 2.0 filing submitted as of September 20th, a Comments tab combining multiple filings by the same responders and eliminating duplications.  All entries include the initial FCC document links, which are currently inoperable.

The most important tab for review purposes is the Comments (2) tab, grouping all comments by size — one page, two pages, and three or more pages.  Our premise is that the most important comments are the longer ones.  Of those roughly 200 longer sets of comments, we have collected and reposted working copies of about 120 with working E-Rate Central web links.  We will be updating this list as we find additional comments which can be reposted.

A request to readers:  If you have electronic or scannable copies of any of the comments not currently available on our website, please e-mail them to nprm@e-ratecentral.com for inclusion.

SLD Fall Training:

As discussed above, the SLD began its 2013 fall training last week in Washington, DC.  The next workshop will be in Newark, NJ, on Tuesday, October 8th.  The agenda and presentation slides for the workshop are posted on the SLD website.

Schools and Libraries News Brief Dated October 4 – Entity Numbers

The SLD News Brief for October 4, 2013, reviews entity numbers, focusing primarily on Billed Entity Numbers (“BENs”).  The News Brief covers the following topics:

  • Locating an entity number
  • Requesting an entity number
  • Correcting the information on an entity number
Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.