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April 14, 2025

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.

E-Rate for FY 2025:

The Form 471 filing window for FY 2025 closed on March 26th.  Preliminary demand, as summarized in USAC’s annual letter to the FCC was $3.2 billion.  This is well below the year’s $5.06 billion funding cap set earlier this month by the FCC.  This demand total will increase over the next month or two as the FCC grants waivers on late-filed applications certified within two weeks of the window closing, then decrease as pending requests are reduced during the PIA review process.  We would expect the first wave of FY 2025 funding commitments to be issued by USAC by the end of this month.

E-Rate for FY 2024:

Wave 51 for FY 2024 was released on Thursday, April 10th, for $3.38 million.  Total funding is now $2.65 billion.  Currently, USAC has funded 98.3% of the originally submitted applications, representing 91.8% of the dollars requested.

Cybersecurity Pilot Program – Application Window:

The Form 471 application window for the Cybersecurity Pilot Program opened on March 18th and will close on September 15th, 2025.  Total pilot funding is capped at $200 million for 707 applicants.

Upcoming Dates:

April 18 FY 2024 Form 486 deadline for Wave 35.  The Form 486 deadline is 120 days after the FCDL date, or the service start date (typically July 1st), whichever is later.  The next Form 486 deadlines for FY 2024 are:
Wave 36              04/25/2025
Wave 37              05/02/2025
Wave 38              05/09/2025
April 28 Reply comments due on the FCC’s “Delete, Delete, Delete” initiative.
May 28 Extended invoice deadline for FY 2023 non-recurring service FRNs with approved extensions beyond the original January 28, 2025, deadline.
June 30 Last day to light fiber (or request an extension for) FY 2024 special construction projects.
June 30 Last day to receive (or file service substitutions for) FY 2024 recurring services.
July 1 Withdrawal deadline for Cybersecurity Pilot participants opting not to continue in the Program.
September 15     Close of the Cybersecurity Pilot Form 471 application window and deadline for filing the Form 484 Part 2.

Delete, Delete, Delete E-Rate Comments:

Last Friday was the deadline for submitting comments in the FCC’s proceeding entitled “Delete, Delete, Delete” (DA 25-219) designed to eliminate unnecessary FCC rules and regulations (see our newsletter of March 17th).  The Delete3 initiative was FCC-wide, not specifically targeted to E-Rate.  Indeed, the consensus of many in the E-Rate community is that substantive rule changes as a result of this proceeding are unlikely.  The few E-Rate comments that were filed, such as those by ALACENIC, and SHLB, reiterated suggestions that have been made in the past.  SHLB’s filing, for example, made the following points:

SHLB filing

One inventive exception to this approach was filed by On-Tech Consulting that filed an extensive set of comments that, were they to be implemented, would significantly change the entire E-Rate process.  While the likelihood of any of these changes being implemented in the near future are nil, the On-Tech filing provides an interesting perspective as summarized in the following listing of the filing’s contents:

On-Tech Consulting filing

The deadline for submitting reply comments in the Delete3 proceeding is April 28th.